cina78 Privacy Policy

1 Definitions

The following terms have the meanings set out below throughout this Privacy Policy:

2 Scope & Data Controller

This Policy applies to all Personal Data collected by cina78 in connection with the operation of the cina78 platform, including data collected through:

• The cina78 website at https://cina78.pro and all associated sub-pages;
• The Member account registration and login process;
• Deposit, withdrawal, and payment transaction workflows;
• KYC identity verification submissions;
• Customer support interactions via live chat and email;
• Promotional opt-in forms and bonus claim processes;
• Automated tracking technologies including cookies and log files.

cina78 acts as the Data Controller for all Personal Data collected through the platform. Where cina78 engages third-party service providers to process data on its behalf, those parties act as Processors and are bound by data processing agreements that require them to handle Personal Data only in accordance with cina78's instructions and this Policy.

3 Personal Data We Collect

The categories of Personal Data cina78 collects vary depending on your relationship with the platform — whether you are a first-time Visitor, a registered Member, or a Member completing KYC verification. The following table provides a comprehensive breakdown:

cina78 does not intentionally collect Special Categories of Personal Data (such as health data, racial or ethnic origin, religious beliefs, or political opinions) unless a Member voluntarily discloses such information in the course of a support interaction, in which case it is handled with the highest level of care and used solely to address the Member's immediate need.

4 How We Collect Your Data

cina78 collects Personal Data through the following channels and mechanisms:

4.1 Directly From You

The majority of Personal Data cina78 holds is provided directly by you during:

• Account registration — when you enter your name, date of birth, email address, and phone number;
• KYC verification — when you upload identity documents and proof of payment account ownership;
• Deposit and withdrawal transactions — when you initiate transfers via Indonesian bank accounts or e-wallets;
• Customer support interactions — when you contact cina78 via live chat or email;
• Promotional opt-in — when you consent to receiving marketing communications.

4.2 Automatically Through Technology

When you visit or use the cina78 platform, certain data is collected automatically via:

• Log files: Our web servers automatically record IP addresses, browser types, access timestamps, and pages requested as part of standard internet operation.
• Cookies and similar technologies: cina78 uses first-party cookies to maintain your session state (keeping you logged in), remember your preferences, and analyze platform usage patterns. See Clause 8 for full cookie details.
• Game server logs: Each bet, spin, or game round generates a server-side record for integrity verification, dispute resolution, and responsible gaming monitoring purposes.

4.3 From Third Parties

In limited circumstances, cina78 may receive Personal Data about you from trusted third parties, specifically:

• Payment processors: Confirmation of transaction status and, where required for fraud prevention, account holder name matching data from Indonesian banking partners;
• KYC verification partners: Results of automated identity document checks and age verification processes;
• Fraud prevention services: Risk scores and flagged indicators associated with your IP address or device fingerprint, used solely to protect platform integrity.

5 How We Use Your Personal Data

cina78 processes Personal Data for the following clearly defined purposes. We do not use your data for any purpose incompatible with those listed below without first obtaining your explicit consent.

6 Legal Basis for Processing

cina78 processes your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and cina78 — including account creation, payment processing, bet settlement, and KYC verification. Without this processing, we cannot provide you with Platform services.
• Legitimate Interests: Processing necessary for cina78's legitimate business interests, provided those interests are not overridden by your rights and interests. This includes fraud prevention, platform security, responsible gaming monitoring, and analytics for service improvement.
• Legal Obligation: Processing required for cina78 to comply with applicable legal obligations, including financial record-keeping requirements, anti-money laundering obligations, and cooperation with lawful authority requests.
• Consent: Processing based on your freely given, specific, informed consent — specifically for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

cina78 does not sell, rent, or trade your Personal Data. We share data only in the circumstances described below, and only to the minimum extent necessary for the stated purpose:

7.1 Service Providers (Processors)

cina78 engages the following categories of third-party service providers who process Personal Data on our behalf under binding data processing agreements:

• Payment gateways and banking partners: Including integrations with BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja — to facilitate deposit and withdrawal transactions;
• KYC and identity verification platforms: To automate document checks and age verification for withdrawal-eligible Members;
• Game content providers: Including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft, SA Gaming, and others — who receive the minimum data necessary (session tokens, bet amounts, RNG seeds) to deliver game content;
• Customer support technology providers: Live chat platform operators who host support conversations;
• Fraud detection and cybersecurity services: IP reputation, device fingerprinting, and behavioral analytics providers used to protect platform integrity;
• Cloud hosting and infrastructure providers: Who store cina78 platform data on encrypted, access-controlled servers.

7.2 Legal and Regulatory Disclosure

cina78 may disclose your Personal Data to competent authorities, courts, or regulators where required to do so by applicable law, valid legal process, or in response to a lawful request. Where legally permissible, cina78 will notify the affected Member of such a disclosure.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of cina78's business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer via an update to this Privacy Policy and, where required, will be given the opportunity to delete your account prior to the transfer taking effect.

7.4 Aggregate and Anonymized Data

cina78 may share aggregated, anonymized data (from which individual Members cannot be identified) with third parties for industry benchmarking, research, and marketing purposes. Such data sharing does not constitute disclosure of Personal Data.

8 Cookies & Tracking Technologies

cina78 uses cookies and similar technologies to operate the platform effectively and to understand how Members use it. The table below describes the categories of cookies we use:

cina78 does not use third-party advertising or social media tracking cookies. You can manage your cookie preferences through your browser settings; however, disabling strictly necessary or security cookies will impair your ability to use the platform.

9 Data Retention

cina78 retains Personal Data for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable legal and regulatory obligations. The following indicative retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or permanently anonymized. Where deletion is not immediately technically feasible (for example, in backup systems), data is isolated and protected from further active use until it can be securely destroyed.

10 Your Privacy Rights

As a cina78 Member, you have the following rights in relation to your Personal Data. To exercise any of these rights, contact our support team via live chat or at the email address in Clause 15.

11 Data Security

cina78 implements a layered technical and organizational security program to protect your Personal Data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Key security measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your browser and cina78 servers is encrypted using industry-standard TLS protocols. Our SSL certificate is maintained and renewed automatically.
• Encryption at Rest: Sensitive Data — including KYC documents, payment account details, and identity numbers — is encrypted at rest using AES-256 or equivalent standards on cina78's cloud infrastructure.
• Access Controls: Internal access to Personal Data is governed by a strict need-to-know principle. Only authorized cina78 personnel with a legitimate operational requirement may access Member data. All internal access is logged and audited.
• Password Security: Member passwords are stored as salted cryptographic hashes. cina78 staff cannot view or retrieve your plaintext password under any circumstances.
• Intrusion Detection: cina78 operates automated monitoring systems to detect and alert on anomalous access patterns, brute-force attempts, and data exfiltration indicators.
• Vendor Security Reviews: Third-party Processors are subject to security assessment before onboarding and periodic review thereafter to ensure they maintain appropriate standards.
• Incident Response: In the event of a confirmed data breach that poses a risk to Member rights and freedoms, cina78 will notify affected Members without undue delay and take all necessary remediation steps.

12 Children & Minors

cina78 is strictly an adults-only platform. Access to and registration on the cina78 platform is permitted only to individuals who are 21 years of age or older. This minimum age requirement applies to all Members regardless of their city of residence in Indonesia.

cina78 does not knowingly collect, process, or retain Personal Data from any individual under the age of 21. Our KYC verification process is specifically designed to confirm that every Member meets the minimum age requirement before withdrawal privileges are granted.

If cina78 discovers or is notified that a Member account belongs to an individual under 21 years of age, we will:

• Immediately suspend and subsequently close the account;
• Refund any unplayed deposit balance to the payment source where technically possible;
• Permanently delete all Personal Data associated with the underage account within 30 days, subject to any legally mandated retention obligations;
• Take appropriate measures to prevent re-registration by the same individual.

13 Third-Party Links

The cina78 platform may contain references to or information about third-party services — including Indonesian banking institutions (BCA, BRI, BNI, Mandiri), e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), and game content studios (Pragmatic Play, Evolution Gaming, Microgaming, Spribe, and others). These references are provided for informational and contextual purposes only.

cina78 does not operate, control, or take responsibility for the privacy practices of any third-party entity. If you navigate to a third-party website or application from the cina78 platform, you do so at your own discretion and your interaction with that third party is governed by their own privacy policy and terms of service.

cina78 strongly recommends that you review the privacy policy of any third-party service before submitting your Personal Data to them.

14 Amendments to This Policy

cina78 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform features. When we make material changes to this Policy, we will:

• Update the "Last updated" date displayed at the top of this page;
• Post a prominent notice on the cina78 platform homepage for a period of at least 14 days following the change;
• Where the change materially affects how we use your Personal Data, send a notification to your registered email address at least 14 days before the change takes effect;
• Where required by applicable law, obtain your fresh consent before applying the new processing practices to your data.

Your continued use of the cina78 platform after the effective date of any Policy amendment constitutes your acknowledgment of the updated Policy. If you do not agree with any amendment, you should cease using the platform and contact support to discuss your account closure options.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or cina78's handling of your Personal Data, you are encouraged to contact us through any of the following channels:

cina78 commits to acknowledging all privacy-related inquiries within 5 business days (WIB, UTC+7) and to providing a substantive response within 30 calendar days of a valid, verified request. For complex requests, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

cina78 provides Indonesian-speaking support agents available around the clock for Members who prefer to communicate in their native language, even though this platform's primary operational language is English.