Privacy Policy

1 Definitions

Throughout this Privacy Policy, the following terms carry the meanings set out below:

• "vum606", "we", "us", "our" — the vum606 online gaming platform and its operating entity, accessible at https://vum606.cam.
• "Personal Data" — any information that identifies or can reasonably be used to identify a natural person, including name, date of birth, email address, IP address, payment details, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, transfer, or deletion.
• "Player", "you", "your" — any individual who visits the Platform, creates an Account, or otherwise interacts with vum606's services.
• "Account" — a registered user account on the vum606 Platform.
• "KYC Data" — identity and address verification documents submitted by Players as part of the Know Your Customer process.
• "Cookies" — small text files placed on your device by the Platform to enable functionality, analytics, and personalisation.
• "Third-Party Providers" — external companies that provide services to vum606, including game studios, payment processors, fraud prevention services, and analytics platforms.

2 Data Controller Identity

vum606 acts as the data controller for Personal Data collected from Indonesian Players and all other users of the Platform. As data controller, vum606 determines the purposes and means by which Personal Data is processed.

For all data-related enquiries, requests, and complaints, please contact our designated privacy team using the details set out in Section 14 of this Policy. We are committed to responding to all substantive data-related correspondence within 30 calendar days of receipt.

3 Personal Data We Collect

The categories of Personal Data that vum606 collects from Players are set out in the table below, together with the specific data types within each category:

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information, unless you voluntarily disclose such information in the context of a responsible gaming self-assessment or support interaction. Such disclosures are treated with the highest level of confidentiality.

5 Purposes & Legal Bases for Processing

vum606 processes your Personal Data only where a valid legal basis exists. The table below sets out the primary purposes for which we process Personal Data and the corresponding legal basis for each:

6 Data Sharing & Third Parties

vum606 does not sell your Personal Data. We share it only with the categories of third parties listed below, and only to the extent necessary for the stated purpose:

• Payment Processors: Indonesian bank transfer intermediaries and e-wallet platforms (OVO, DANA, GoPay) receive the minimum financial data required to process your transactions. These processors are contractually bound to handle your data securely and may not use it for any other purpose.
• Game Studios & Software Providers: Certified providers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft receive anonymised or pseudonymised session data necessary for game delivery, RNG certification, and regulatory audit trails. They do not receive your full identity or financial data.
• KYC & AML Service Providers: Third-party identity verification and anti-money-laundering screening services receive KYC documents and identity data solely for the purpose of regulatory compliance checks.
• Fraud Prevention Services: Specialist cybersecurity and fraud analytics firms receive Technical Data and transaction patterns to detect and prevent fraudulent activity on the Platform.
• IT Infrastructure Providers: Cloud hosting and data centre operators who provide the technical infrastructure on which the Platform runs. These providers process data under strict data processing agreements and may not access your data for their own purposes.
• Legal & Regulatory Authorities: We will disclose Personal Data to law enforcement agencies, regulatory bodies, or courts when we are lawfully required to do so. We will notify you of such disclosures wherever legally permitted.
• Affiliate Partners: Limited referral tracking data (player registration confirmation, no financial details) is shared with affiliate partners solely for commission calculation purposes.

7 Data Retention

vum606 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account & Identity Data: Retained for the duration of your Account and for a minimum of five (5) years after Account closure, in compliance with anti-money-laundering record-keeping obligations.
• Financial & Transaction Data: Retained for a minimum of five (5) years from the date of each transaction, as required by financial regulatory standards.
• KYC Documents: Retained for a minimum of five (5) years after the end of the customer relationship, or longer if required by applicable law.
• Technical & Usage Data: Retained for up to twenty-four (24) months from collection, unless retained longer for fraud investigation or legal proceedings.
• Communication Data (Support Records): Retained for up to three (3) years after the ticket or conversation is closed.
• Marketing Preferences: Retained until you withdraw consent or close your Account, whichever occurs first.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be linked to any individual. Where data is anonymised rather than deleted, it may be retained indefinitely for aggregate statistical analysis.

8 Security Measures

vum606 implements a layered security architecture to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Our key security measures include:

• Transport Security: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher (256-bit SSL encryption), ensuring that your login credentials, financial information, and personal details cannot be intercepted in transit.
• Storage Security: Data at rest is stored on hardened servers with AES-256 encryption for sensitive fields (passwords, payment data) and role-based access controls restricting which personnel can view each data category.
• Access Controls: Internal access to Personal Data is granted strictly on a need-to-know basis. All staff with data access undergo background checks and receive regular data security training.
• Penetration Testing: Our infrastructure is subject to regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• Incident Response: vum606 maintains a documented data breach response plan. In the event of a breach affecting your Personal Data, we will notify you and relevant authorities within the timeframes required by applicable law.
• Two-Factor Authentication (2FA): Players are strongly encouraged to enable 2FA on their Accounts. 2FA is available via authenticator app or SMS and provides an additional layer of protection against unauthorised Account access.

9 Cookies & Tracking Technologies

vum606 uses cookies and similar tracking technologies to operate the Platform effectively, improve the user experience, and deliver relevant content. The categories of cookies we use are as follows:

9.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be switched off. They include session authentication tokens, security cookies, and load-balancing cookies. No consent is required for these cookies as they are integral to the service.

9.2 Performance & Analytics Cookies

These cookies collect anonymised information about how Players use the Platform — which pages are visited most frequently, how long sessions last, and where errors occur. This data helps us continuously improve the Platform experience. The information collected is aggregated and not linked to individual identities.

9.3 Functionality Cookies

These cookies remember your preferences, such as language settings, display preferences, and responsible gaming configurations, so that you do not need to reset them on every visit.

9.4 Marketing & Targeting Cookies

With your consent, these cookies track your interactions with promotional content and may be used to deliver personalised offers based on your gameplay history and preferences. You may withdraw consent for marketing cookies at any time by updating your browser settings or contacting our support team.

Most web browsers allow you to control cookies through their settings preferences. Note that disabling certain cookies may affect the functionality of the Platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

10 Your Privacy Rights

As a data subject, you have the following rights with respect to the Personal Data vum606 holds about you. To exercise any of these rights, please contact our privacy team using the details in Section 14. We will respond within 30 calendar days and will not charge a fee for reasonable requests.

11 Protection of Minors

vum606 strictly prohibits the use of its Platform by individuals under the age of 21. We do not knowingly collect Personal Data from anyone under 21 years of age. Our registration process requires entry of a date of birth, and KYC verification confirms the age of all Players before withdrawals are processed.

If vum606 becomes aware that Personal Data has been collected from an individual under the age of 21 without verifiable parental or guardian consent (where applicable), that Account will be immediately suspended, all funds will be reviewed in accordance with our Terms & Conditions, and all associated Personal Data will be deleted as expeditiously as possible.

If you are a parent or guardian and believe that your minor child has created an Account on vum606, please contact us immediately using the details in Section 14. We will investigate and take appropriate action promptly.

12 International Data Transfers

As an internationally operated platform, vum606 may transfer your Personal Data to servers and service providers located outside of Indonesia. Such transfers may involve countries whose data protection laws differ from those applicable in Indonesia.

Whenever Personal Data is transferred internationally, vum606 ensures that appropriate safeguards are in place, including:

• Contractual clauses in agreements with receiving parties that impose data protection obligations equivalent to those described in this Policy.
• Transfers only to jurisdictions or organisations that provide an adequate level of data protection as assessed by our privacy team.
• Technical and organisational security measures applied consistently regardless of where data is stored or processed.

13 Changes to This Policy

vum606 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the structure of our business. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page.
• Send a notification to your registered email address at least seven (7) days before the changes take effect, summarising the key modifications.
• Display a prominent notice on the Platform for a period of no less than fourteen (14) days following the effective date of the change.

Your continued use of the Platform after the effective date of any revision constitutes your acknowledgement of the updated Policy. If you do not agree with the revised terms, you may request Account closure in accordance with our Terms & Conditions, and any remaining real-money Balance will be returned to you. The most current version of this Policy is always available at https://vum606.cam/privacy-policy.

14 Contact & Data Requests

For all privacy-related enquiries, data subject access requests, or complaints regarding vum606's data practices, please contact our privacy team through the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line and describe your request in detail.
• Live Chat: Available 24/7 on the Platform. For data subject requests, our agents will escalate to the privacy team within one business day.
• Response Commitment: We aim to acknowledge all privacy requests within 72 hours and provide a substantive response within 30 calendar days. For complex requests, we may extend this period by a further 30 days and will notify you accordingly.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to a relevant supervisory authority in your jurisdiction. Indonesian Players may seek further guidance from Kominfo (Indonesia's Ministry of Communication and Information Technology) with respect to electronic data protection matters.

For general enquiries unrelated to privacy, or for questions about your Account, bonuses, or gaming rules, please visit our FAQ page or contact our 24/7 customer support team directly.