1 Introduction
tuna88 (the "Company", "we", "us", or "our") is committed to protecting the privacy and personal data of all individuals who access our Platform. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, and what rights you have regarding your data.
This Privacy Policy applies to all users of the tuna88 website at https://tuna88.cam, including visitors, registered account holders, and any person who interacts with our customer support channels, promotional campaigns, or marketing communications.
By creating an account or using our services, you acknowledge that you have read, understood, and agreed to the collection, use, and disclosure of your personal data as described in this Privacy Policy. If you do not agree with any part of this policy, you must immediately cease using the Platform and contact us to request account closure.
2 Data Controller
For the purposes of applicable data protection laws, tuna88 is the data controller responsible for your personal data. The Company determines the purposes for which and the means by which your personal data is processed.
Our designated contact for all data protection and privacy inquiries is:
Email:
Subject Line: "Privacy Inquiry" or "Data Protection Request"
All requests related to data subject rights (access, rectification, erasure, restriction, portability, objection) should be submitted in writing via email to ensure proper audit trail and timely response in accordance with statutory deadlines.
3 Personal Data We Collect
tuna88 collects the following categories of personal data from users:
3.1 Identity Data
- Full legal name as it appears on your government-issued identification document
- Date of birth (to verify age eligibility — users must be 21 or older)
- Nationality and country of residence
- Copy of government-issued photo ID (Indonesian KTP, passport, or equivalent) uploaded during KYC verification
- Selfie photograph holding your ID document next to your face
3.2 Contact Data
- Email address (used for account communications, password resets, promotional offers, and transactional notifications)
- Mobile phone number (used for two-factor authentication, SMS alerts, and customer support contact)
- Residential address (as stated on proof-of-address documentation or registered bank account statement)
3.3 Financial Data
- Bank account details (bank name, account number, account holder name) for deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, or Bank Permata
- E-wallet registration details (OVO, DANA, GoPay, ShopeePay, LinkAja phone number or account ID)
- Transaction history including deposit amounts, withdrawal amounts, timestamps, payment methods, and transaction reference numbers
- Bonus claim history and associated wagering progress
3.4 Technical Data
- IP address and geolocation data (used to verify access from permitted jurisdictions and prevent fraud)
- Device information (device type, operating system, browser type and version, screen resolution)
- Login timestamps, session duration, and logout events
- Cookies and similar tracking technologies (see section 11 below for full details)
3.5 Behavioral Data
- Betting history (sports bets, live casino wagers, slot spins, togel entries, sabung ayam bets, and all other game-play activity)
- Game preferences and most-played titles
- Deposit and withdrawal patterns
- Responsible gaming tool usage (deposit limits set, session time limits, self-exclusion requests)
3.6 Communication Data
- Live chat transcripts with customer support agents
- Email correspondence sent to or received from [email protected]
- Feedback, survey responses, and promotional preference selections
4 How We Collect Your Data
Personal data is collected through the following channels:
- Direct provision by you: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, or participate in promotions.
- Automated technologies: Cookies, pixel tags, and analytics scripts collect technical and behavioral data as you navigate the Platform. See section 11 for more detail.
- Third-party sources: Payment processors (e.g., bank APIs, e-wallet providers) transmit transaction confirmation data to us. Game providers (e.g., Pragmatic Play, Evolution Gaming, Microgaming) transmit game-play outcome data and bet settlement results.
- Public sources: In rare cases, where enhanced due diligence is required under anti-money-laundering regulations, we may verify your identity against publicly available databases or official government registries.
5 Purposes for Which We Use Your Data
tuna88 processes your personal data for the following purposes:
| Purpose | Description |
|---|---|
| Account Management | Creating, maintaining, and administering user accounts; processing login credentials; enabling password resets. |
| KYC & AML Compliance | Verifying identity and age to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under international financial crime prevention standards. |
| Payment Processing | Processing deposits, withdrawals, and refunds via Indonesian banks (BCA, BRI, BNI, Mandiri, etc.) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja). |
| Game Delivery | Enabling access to sports betting, live casino, slots, togel, sabung ayam, and other gaming products; recording bet placement and settlement outcomes. |
| Fraud Prevention | Monitoring for suspicious activity, duplicate accounts, bonus abuse, arbitrage betting, collusion, and other prohibited conduct. |
| Responsible Gaming | Implementing deposit limits, session timers, loss limits, self-exclusion, and other player-protection tools; monitoring for signs of problem gambling. |
| Customer Support | Responding to inquiries, resolving disputes, providing technical assistance, and maintaining support ticket history. |
| Marketing Communications | Sending promotional emails, SMS messages, and in-app notifications about bonuses, tournaments, new game releases, and seasonal campaigns (only with your consent, which can be withdrawn at any time). |
| Platform Improvement | Analyzing usage patterns, user preferences, and technical performance to enhance user experience, optimize site speed, and develop new features. |
| Legal Obligations | Complying with court orders, regulatory requests, tax reporting obligations, and law enforcement investigations. |
6 Legal Basis for Processing
Under applicable data protection laws, tuna88 processes your personal data on the following legal grounds:
- Contractual Necessity: Processing is necessary to perform our obligations under the Terms and Conditions you accepted when registering an account (e.g., providing gaming services, processing payments, settling bets).
- Legal Obligation: Processing is required to comply with laws and regulations to which the Company is subject, including KYC, AML, counter-terrorism financing (CTF), and responsible gaming obligations.
- Legitimate Interests: Processing is necessary for the Company's legitimate business interests, provided these interests are not overridden by your fundamental rights and freedoms. Examples include fraud prevention, platform security, internal analytics, and improvement of services.
- Consent: For marketing communications and non-essential cookies, we rely on your freely given, specific, informed, and unambiguous consent, which you may withdraw at any time via Account Settings or by contacting support.
7 Data Sharing and Third-Party Recipients
tuna88 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. However, we may share your data with the following categories of recipients in order to deliver our services:
7.1 Payment Service Providers
Your financial data (bank account details, e-wallet IDs, transaction amounts) is transmitted to authorized payment processors and banking partners to facilitate deposits and withdrawals. These providers are contractually obligated to process data only in accordance with our instructions and to maintain appropriate security safeguards.
7.2 Game Suppliers
Your username, bet history, and game-play data are shared with third-party game providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Pocket Games Soft, Spribe, S128, SV388) to enable real-time gaming and ensure fair play. Game providers process data as independent controllers under their own privacy policies.
7.3 KYC and Verification Services
Identity documents and personal data submitted during KYC verification may be transmitted to specialist third-party identity verification services that cross-check your details against official registries, sanctions lists, and fraud databases.
7.4 Analytics and Marketing Partners
We use analytics platforms (e.g., Google Analytics) and marketing automation tools to measure site performance, user engagement, and campaign effectiveness. These tools process pseudonymized or aggregated data and are configured to respect user privacy in accordance with applicable law.
7.5 Legal and Regulatory Authorities
We may disclose your personal data to law enforcement agencies, regulators, courts, or other public authorities when required by law, in response to a valid legal request, or to protect the rights, property, or safety of tuna88, our users, or the public.
8 Data Retention Periods
tuna88 retains your personal data for the following periods:
- Active Accounts: Personal data is retained for the entire duration that your account remains active, plus the additional periods specified below following account closure.
- Closed Accounts — Financial Records: Transaction history, deposit and withdrawal records, and KYC documents are retained for a minimum of five (5) years following account closure to satisfy AML record-keeping obligations imposed by international financial crime prevention standards.
- Closed Accounts — Marketing Data: If you have consented to receive marketing communications, your contact details and marketing preferences are retained until you withdraw consent or request deletion, subject to a maximum retention period of two (2) years after your last interaction with a marketing message.
- Responsible Gaming Records: Self-exclusion requests and records of problem gambling interventions are retained for a minimum of five (5) years to prevent premature re-activation of excluded accounts and to protect vulnerable users.
- Legal Claims: Where personal data is relevant to an ongoing dispute, investigation, or legal claim, retention may be extended beyond standard periods until the matter is fully resolved.
At the end of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be attributed to an identifiable individual.
9 Security Measures
tuna88 employs industry-standard technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or damage. These measures include:
- Encryption: All data transmitted between your device and our servers is encrypted using TLS (Transport Layer Security) 1.2 or higher. Sensitive data stored in our databases is encrypted at rest using AES-256 encryption.
- Access Controls: Access to personal data is restricted to authorized personnel on a need-to-know basis and is governed by role-based access controls (RBAC) with multi-factor authentication (MFA) requirements.
- Firewalls and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) that monitor for and block malicious activity in real time.
- Regular Audits: We conduct annual security audits and penetration testing performed by independent third-party cybersecurity firms to identify and remediate vulnerabilities.
- Employee Training: All employees with access to personal data receive mandatory data protection and security awareness training upon hiring and on an annual basis thereafter.
- Incident Response: We maintain a documented data breach response plan and will notify affected users and relevant authorities within 72 hours of becoming aware of any breach that poses a risk to your rights and freedoms.
While we implement robust security measures, no method of electronic transmission or storage is 100% secure. Users are responsible for maintaining the confidentiality of their login credentials and must immediately report any suspected unauthorized access to .
10 Your Data Protection Rights
Under applicable data protection laws, you have the following rights regarding your personal data:
10.1 Right of Access
You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format within 30 calendar days of your request.
10.2 Right to Rectification
You have the right to request correction of any inaccurate or incomplete personal data. You can update your email address, phone number, and bank account details directly via Account Settings. For changes to your legal name, date of birth, or residential address, contact support with supporting documentation.
10.3 Right to Erasure (Right to be Forgotten)
You have the right to request deletion of your personal data where there is no compelling legal reason for its continued processing. Note that we are required by law to retain financial records and KYC documents for five years following account closure, during which time erasure requests cannot be fully honored.
10.4 Right to Restriction
You have the right to request that we restrict processing of your personal data in certain circumstances, for example, if you contest the accuracy of the data or the lawfulness of the processing.
10.5 Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance from tuna88.
10.6 Right to Object
You have the right to object to processing of your personal data where we rely on legitimate interests as the legal basis. You also have an absolute right to object to processing for direct marketing purposes at any time.
10.7 Right to Withdraw Consent
Where processing is based on your consent (e.g., marketing emails), you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, please email with the subject line "Data Subject Request" and specify which right you wish to exercise. We will respond within 30 calendar days.
11 Cookies and Tracking Technologies
tuna88 uses cookies and similar tracking technologies to enhance user experience, analyze site usage, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize your browser across multiple visits.
11.1 Types of Cookies We Use
- Essential Cookies: Required for the Platform to function. These include session cookies that maintain your login state, CSRF tokens that prevent cross-site request forgery attacks, and load-balancing cookies. You cannot opt out of essential cookies.
- Performance Cookies: Collect anonymous data about how visitors use the Platform, which pages are most popular, and where users encounter errors. This data is aggregated and used to improve site performance.
- Functional Cookies: Remember your preferences such as language settings, currency display, and preferred game categories. These cookies enhance usability but are not strictly necessary.
- Marketing Cookies: Track your activity across the Platform and other websites to deliver targeted advertisements and measure campaign effectiveness. These require your explicit consent.
11.2 Managing Cookie Preferences
You can control cookie settings via your browser preferences. Most browsers allow you to block all cookies, accept only first-party cookies, or receive notifications when a cookie is set. Note that blocking essential cookies will prevent you from logging in or placing bets on the Platform.
To manage marketing cookie preferences specifically, visit Account Settings > Privacy > Cookie Preferences or click the "Cookie Settings" link in the footer of any page.
12 International Data Transfers
tuna88 operates under an international offshore gaming license. Your personal data may be transferred to, stored at, and processed in countries outside of Indonesia where our servers, service providers, and business partners are located. These countries may have data protection laws that differ from Indonesian law.
Where personal data is transferred to a country that does not provide an adequate level of data protection, we implement appropriate safeguards such as:
- Standard Contractual Clauses (SCCs) approved by relevant data protection authorities
- Binding Corporate Rules (BCRs) where transfers occur within a multinational corporate group
- Certification under recognized international data protection frameworks
By using the Platform, you acknowledge and consent to the international transfer of your personal data as described in this section.
13 Minors and Age Verification
tuna88 is an adult-only platform. Use of our services is strictly prohibited for persons under the age of 21 years. We do not knowingly collect personal data from individuals under 21.
All users are required to complete age verification during KYC by submitting a government-issued photo ID that clearly displays their date of birth. Accounts found to belong to minors will be immediately suspended, all funds forfeited, and the matter reported to relevant authorities if required by law.
If you believe that a minor has registered an account on tuna88, please report it immediately to with the subject line "Underage Account Report". We will investigate and take appropriate action within 24 hours.
14 Amendments to This Privacy Policy
tuna88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. Material changes will be communicated to registered users via email notification and a prominent banner on the Platform at least 14 days before the updated policy takes effect.
The "Last Updated" date at the top of this page indicates the date of the most recent revision. Continued use of the Platform after the effective date of an updated Privacy Policy constitutes acceptance of the revised terms.
We recommend that you review this Privacy Policy periodically to stay informed about how we protect your data.
15 Contact Us and Complaints
If you have any questions, concerns, or complaints regarding this Privacy Policy or our data processing practices, please contact us:
Email:
Subject Line: "Privacy Inquiry" or "Data Protection Complaint"
We will acknowledge receipt of your inquiry within 2 business days and provide a substantive response within 30 calendar days.
If you are not satisfied with our response to a data protection complaint, you have the right to lodge a complaint with the supervisory authority in the jurisdiction where you reside or where the alleged infringement occurred. Please note that tuna88 operates under an international offshore gaming license and may not be subject to Indonesian domestic data protection regulations.