1. Introduction
pulito ("we", "us", "our", "the Platform") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you use our online betting services accessible via https://pulito.cam, including sports betting, live casino, togel (Indonesia's traditional numbers lottery), slot games, and all related features.
This Privacy Policy applies to all Users who register an account on pulito, whether you access our services via desktop, mobile browser, or any other device. By creating an account or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.
This Privacy Policy should be read in conjunction with our Terms and Conditions and Responsible Gaming Policy, which together govern your relationship with pulito.
pulito collects several categories of personal information to provide you with a secure, personalized, and compliant gaming experience. The types of information we collect include:
2.1 Information You Provide Directly
- Account Registration Data: When you create a pulito account, we collect your full legal name, date of birth, gender, email address, mobile phone number, residential address in Indonesia, and chosen username and password.
- Identity Verification Documents: To comply with Know Your Customer (KYC) and anti-money laundering regulations, we collect copies of government-issued identification documents such as your Indonesian National Identity Card (KTP), passport, or driver's license, as well as proof of address documents (utility bills, bank statements) and proof of payment method ownership.
- Payment Information: We collect your bank account details (bank name, account number, account holder name) for Indonesian banks such as BCA, BRI, BNI, Mandiri, CIMB Niaga, and OCBC NISP, as well as e-wallet account information for OVO, GoPay, DANA, and ShopeePay. Payment card details, if provided, are tokenized and processed by our secure payment processors; pulito does not store full card numbers.
- Communication Data: When you contact our customer support team via Live Chat, email, WhatsApp, or in-app messaging, we collect the content of your communications, including any attachments you send.
- Preferences and Settings: We collect information about your communication preferences, notification settings, language preferences, and responsible gaming limits you set (deposit limits, time-outs, self-exclusion requests).
2.2 Information We Collect Automatically
- Account Activity Data: We automatically log your betting history, deposit and withdrawal transactions, game play data, bonus claims and usage, win/loss records, and session duration.
- Device and Technical Information: When you access pulito, we collect your IP address, device type and model, operating system and version, browser type and version, screen resolution, language settings, and unique device identifiers.
- Location Data: We collect your geographic location based on your IP address to verify that you are accessing our services from within Indonesian territory, as required by our operating license and legal obligations.
- Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing behavior, preferences, and interactions with our Platform. See Section 6 (Cookies & Tracking) for more details.
2.3 Information from Third-Party Sources
- Payment Processors: We receive transaction confirmation data from our payment partners (banks and e-wallet providers) to verify deposits and process withdrawals.
- Identity Verification Services: We may use third-party identity verification services to authenticate your documents and detect fraudulent activity.
- Game Providers: Our casino game providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, etc.) share gameplay data and RTP (Return to Player) statistics with us to ensure fair play and regulatory compliance.
3. How We Use Your Data
pulito uses your personal information for the following purposes:
3.1 Service Provision and Account Management
- To create, maintain, and manage your pulito account.
- To process your deposits, withdrawals, and betting transactions.
- To verify your identity, age (21+ requirement), and residency in Indonesia.
- To provide customer support and respond to your inquiries.
- To enforce our Terms and Conditions and detect violations such as multi-accounting, bonus abuse, and fraudulent activity.
3.2 Legal and Regulatory Compliance
- To comply with Know Your Customer (KYC) and anti-money laundering (AML) regulations.
- To fulfill our obligations under our gaming license and applicable Indonesian and international laws.
- To respond to lawful requests from government authorities, law enforcement agencies, or court orders.
- To enforce responsible gaming policies, including age verification, self-exclusion management, and problem gambling detection.
3.3 Marketing and Communications
- To send you promotional offers, bonus notifications, and marketing communications related to pulito's services (with your consent, where required by law).
- To personalize your experience on the Platform based on your preferences and betting history.
- To conduct market research and analyze user behavior to improve our services.
3.4 Security and Fraud Prevention
- To detect, prevent, and investigate fraudulent activity, money laundering, collusion, cheating, and other prohibited conduct.
- To protect the security and integrity of our Platform, including monitoring for unauthorized access attempts and distributed denial-of-service (DDoS) attacks.
- To maintain audit logs and transaction records as required by our gaming license.
3.5 Analytics and Improvement
- To analyze usage patterns, game preferences, and user behavior to optimize our Platform and develop new features.
- To conduct A/B testing and performance monitoring to improve user experience.
- To generate aggregated, anonymized statistics for internal business purposes and regulatory reporting.
4. Data Sharing and Disclosure
pulito does not sell your personal information to third parties. However, we may share your data with the following categories of recipients for the purposes described below:
4.1 Service Providers and Business Partners
- Payment Processors: We share payment information with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet providers (OVO, GoPay, DANA, ShopeePay) to process your deposits and withdrawals.
- Game Providers: Your gameplay data is shared with our licensed game providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Playtech, etc.) to deliver casino games and sports betting services.
- Identity Verification Services: We share identity documents with third-party KYC verification providers to authenticate your identity and comply with regulatory requirements.
- Customer Support Tools: We use third-party customer support platforms (Live Chat software, ticketing systems) that may have access to your communications with our support team.
- Analytics and Marketing Services: We share anonymized or pseudonymized data with analytics providers (Google Analytics, etc.) and marketing platforms to measure campaign effectiveness and improve our services.
4.2 Legal and Regulatory Authorities
We may disclose your personal information to government authorities, law enforcement agencies, regulators, or courts when:
- Required by law, regulation, legal process, or governmental request.
- Necessary to enforce our Terms and Conditions or protect our legal rights.
- Necessary to prevent, detect, or investigate fraud, money laundering, or other illegal activity.
- Required to comply with our gaming license obligations and regulatory audits.
4.3 Business Transfers
In the event of a merger, acquisition, sale of assets, or other corporate transaction involving pulito, your personal information may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.
4.4 With Your Consent
We may share your information with third parties for purposes not described in this Privacy Policy if we obtain your explicit consent to do so.
5. Data Security
pulito takes data security seriously and implements industry-standard technical and organizational measures to protect your personal information from unauthorized access, loss, misuse, alteration, or disclosure.
5.1 Technical Safeguards
- 256-bit SSL Encryption: All data transmitted between your device and our servers is encrypted using 256-bit Secure Sockets Layer (SSL) encryption, the same standard used by banks and financial institutions.
- Secure Data Storage: Personal information is stored on secure servers located in certified data centers with physical access controls, fire suppression systems, and 24/7 monitoring.
- Firewall Protection: Our Platform is protected by enterprise-grade firewalls and intrusion detection systems to prevent unauthorized access.
- Two-Factor Authentication (2FA): We offer optional two-factor authentication to add an extra layer of security to your account login.
- Password Hashing: User passwords are hashed using industry-standard cryptographic algorithms and are never stored in plain text.
5.2 Organizational Safeguards
- Access Controls: Access to personal information is restricted to authorized employees and contractors on a need-to-know basis, and all access is logged and audited.
- Employee Training: All pulito staff with access to personal information receive regular training on data protection and privacy best practices.
- Third-Party Audits: We undergo regular security audits by independent third-party firms to validate our security controls and compliance with industry standards.
- Incident Response Plan: We maintain a documented incident response plan to detect, contain, and remediate security breaches, and we will notify affected users in accordance with applicable law if a breach occurs.
5.3 Limitations
While we implement robust security measures, no system is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and should notify us immediately at [email protected] if you suspect unauthorized access to your account.
6. Cookies and Tracking Technologies
pulito uses cookies and similar technologies to enhance your experience, analyze usage, and deliver personalized content and advertising.
6.1 What Are Cookies?
Cookies are small text files placed on your device by a website when you visit. They allow the website to recognize your device and remember your preferences, login status, and browsing behavior.
6.2 Types of Cookies We Use
- Essential Cookies: Required for the Platform to function properly. These cookies enable core features such as account login, transaction processing, and security.
- Performance Cookies: Collect anonymized information about how you use pulito, such as which pages you visit and how long you stay. We use this data to improve our Platform's performance.
- Functionality Cookies: Remember your preferences (language, currency, display settings) so you don't have to re-enter them each time you visit.
- Advertising Cookies: Track your activity across websites to deliver personalized advertising and measure the effectiveness of our marketing campaigns.
6.3 Managing Cookies
Most browsers allow you to control cookies through your browser settings. You can choose to block or delete cookies, but this may affect your ability to use certain features of pulito. Essential cookies cannot be disabled without losing access to the Platform.
7. Your Privacy Rights
As a pulito user, you have certain rights regarding your personal information:
7.1 Access and Portability
You have the right to request a copy of the personal information we hold about you. We will provide this information in a structured, commonly used, and machine-readable format within 30 days of your request.
7.2 Correction
You have the right to request correction of inaccurate or incomplete personal information. You can update most of your account information directly through your pulito account dashboard, or contact [email protected] for assistance.
7.3 Deletion
You have the right to request deletion of your personal information, subject to certain exceptions (e.g., we may be required to retain certain data for legal or regulatory compliance purposes). Account deletion requests can be submitted via email to [email protected].
7.4 Objection and Restriction
You have the right to object to or request restriction of certain processing activities, including marketing communications. You can opt out of promotional emails by clicking the "unsubscribe" link in any marketing email, or by contacting customer support.
7.5 Withdrawal of Consent
Where we rely on your consent to process personal information, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.
7.6 Exercising Your Rights
To exercise any of the above rights, please contact us at [email protected] with your account details and a description of your request. We will respond within 30 days. We may request additional information to verify your identity before fulfilling your request.
8. Data Retention
pulito retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
- Active Accounts: While your account remains active, we retain all personal information necessary to provide our services.
- Closed Accounts: After account closure, we retain certain data for 7 years to comply with financial record-keeping requirements, anti-money laundering regulations, and our gaming license obligations. This includes transaction history, identity verification documents, and betting records.
- Marketing Data: If you opt out of marketing communications, we retain your email address on a suppression list to ensure we do not contact you again.
- Anonymized Data: We may retain anonymized or aggregated data indefinitely for statistical analysis and business intelligence purposes.
9. International Data Transfers
pulito operates from servers located outside Indonesia and may transfer your personal information to service providers in other countries for the purposes described in this Privacy Policy. When we transfer data internationally, we ensure that appropriate safeguards are in place, such as standard contractual clauses or participation in recognized data protection frameworks, to protect your information in accordance with this Privacy Policy.
10. Changes to This Privacy Policy
pulito reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological developments. We will notify you of material changes by posting a notice on the Platform or sending an email to your registered email address at least 14 days before the changes take effect. Your continued use of pulito after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.
The "Last Updated" date at the top of this page indicates when this Privacy Policy was last revised. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.
If you have any questions, concerns, or complaints regarding this Privacy Policy or how pulito handles your personal information, please contact us:
- Email: [email protected]
- Subject Line: Privacy Inquiry
- Live Chat: Available 24/7 via the pulito website
- WhatsApp: +62 812 3456 7890
- Support Hours: 24/7, Western Indonesia Time (WIB, UTC+7)
We aim to respond to all privacy-related inquiries within 30 days. For urgent account security concerns, please contact us immediately via Live Chat.
12. Children's Privacy
pulito's services are strictly for individuals aged 21 and older. We do not knowingly collect personal information from anyone under the age of 21. If we become aware that we have collected information from a person under 21, we will delete that information immediately and permanently close the associated account. If you believe a minor has registered on pulito, please contact us at [email protected] immediately.
Acknowledgment: By using pulito, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.