Privacy Policy — sm605

This Privacy Policy ("Policy") is issued by sm605 ("we", "us", "our", "the Platform", "sm605"), the operator of the online betting and gaming platform accessible at sm605.cam. It governs the manner in which sm605 collects, uses, stores, transfers, and protects personal data relating to individuals who visit, register on, or otherwise interact with the Platform.

sm605 is primarily used by English-preference players based in Indonesia. We are committed to handling your personal data with rigour, transparency, and respect for your privacy. This Policy has been drafted in plain, accessible English so that you can understand exactly what happens to your data at every stage of your relationship with sm605.

By accessing the Platform, creating an Account, making a deposit, placing a bet, or contacting our support team, you confirm that you have read this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately.

sm605 collects the minimum amount of personal data necessary to deliver a safe, legal, and high-quality gaming service. The categories of personal data we collect are described below.

• Full legal name — as it appears on your government-issued identification document.
• Date of birth — used to verify that you meet the minimum age requirement of 21 years.
• Email address — the primary channel for Account communications, security alerts, and support correspondence.
• Nationality and country of residence — used for eligibility verification and regulatory compliance.
• Username and encrypted password — created by you at registration. sm605 never stores passwords in plain text.

• Government-issued photo ID — Indonesian National Identity Card (KTP), passport, or driver's licence.
• Proof of address — a recent bank statement or utility bill issued to you within the last 90 days, confirming your residential address.
• Payment method verification — a bank book, screenshot, or statement confirming ownership of the BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, or other linked account used for deposits and withdrawals.

• Bank account numbers and e-wallet identifiers associated with your Account (stored in tokenised form where technically feasible).
• Deposit and withdrawal amounts, timestamps, and reference numbers.
• Bonus claim history, wagering activity, and game session records.
• Balance history and transaction ledger for your Account.

• IP address and approximate geolocation derived from it.
• Browser type, version, and language setting.
• Device type, operating system, and screen resolution.
• Session start/end timestamps, page views, and navigation paths within the Platform.
• Error logs and crash reports relevant to Platform stability.

• Content of live chat and email correspondence with our support team.
• Feedback and survey responses submitted voluntarily.
• Records of any responsible gaming self-assessments completed on the Platform.

sm605 processes personal data strictly for the purposes set out in this section. We do not use your data for any purpose that is incompatible with those stated below without first seeking your explicit consent.

sm605 does not use personal data to build profiles for sale to third-party advertisers, nor do we use your data to serve targeted advertising on external platforms.

Where international data protection standards apply, sm605 relies on one or more of the following legal bases when processing your personal data:

• Contractual necessity — processing required to open and maintain your Account, process transactions, and deliver the services you have requested under our Terms & Conditions.
• Legal obligation — processing required to comply with applicable anti-money laundering regulations, fraud prevention obligations, and lawful requests from competent authorities.
• Legitimate interests — processing for fraud detection, Platform security, responsible gaming monitoring, and internal analytics, where those interests are not overridden by your privacy rights.
• Consent — processing for optional promotional communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

sm605 acknowledges that Indonesia's personal data protection landscape is evolving, including under Law No. 27 of 2022 on Personal Data Protection (UU PDP). We are committed to applying data protection standards consistent with internationally recognised best practices, and we will update this Policy as applicable legal requirements develop.

sm605 does not sell, rent, or trade your personal data to third parties for marketing or commercial purposes. We share personal data only in the limited circumstances described below, and only to the extent strictly necessary for each purpose.

We engage carefully selected third-party service providers who process personal data on our behalf under binding data processing agreements. These include:

• Payment processors and banking partners — BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja, to facilitate deposits and withdrawals in IDR.
• Identity verification providers — third-party KYC platforms used to authenticate government-issued documents and confirm age eligibility.
• Game content providers — studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive session-level data necessary to deliver and audit game outcomes, but do not receive your full identity profile.
• Cloud infrastructure providers — server and storage infrastructure partners bound by strict confidentiality and security obligations.
• Customer support platforms — live chat and email management tools used to handle support interactions.

sm605 may disclose personal data to competent authorities, law enforcement agencies, or regulatory bodies where required or permitted by applicable law — for example, in connection with anti-money laundering investigations, court orders, or lawful regulatory inquiries. We will notify you of any such disclosure where we are legally permitted to do so.

In the event of a merger, acquisition, restructuring, or sale of all or part of sm605's business, personal data held by sm605 may be transferred to a successor entity as part of that transaction. In such circumstances, sm605 will take reasonable steps to ensure that the successor entity is bound by privacy obligations no less protective than those set out in this Policy, and will notify affected Members in advance where practical.

sm605 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, and in accordance with applicable legal retention obligations. The table below summarises our standard retention periods by data category:

When data is no longer required and no legal retention obligation applies, sm605 will either securely delete it or anonymise it so that it can no longer be associated with any identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

sm605 applies a layered, defence-in-depth approach to personal data security. Our technical and organisational security measures include, but are not limited to, the following:

• 256-bit SSL/TLS encryption on all data transmitted between your browser and the Platform, ensuring that your login credentials, financial information, and personal data are never transmitted in plain text.
• Encrypted password storage using an industry-standard one-way hashing algorithm. sm605 staff cannot view your password; if you lose it, a reset flow is used rather than retrieval.
• Two-factor authentication (2FA) available to all Members and strongly recommended. When enabled, access to your Account requires both your password and a one-time code sent to your registered device.
• Role-based access control ensuring that only authorised sm605 personnel with a demonstrable business need can access any given category of personal data.
• Regular security audits and penetration testing conducted by independent third-party security professionals to identify and remediate vulnerabilities before they can be exploited.
• Fraud detection systems that monitor transaction patterns, login behaviour, and device fingerprints in real time to detect and respond to suspicious activity.
• Data breach response procedures — in the event of a personal data breach that poses a risk to your rights, sm605 will notify affected Members without undue delay, describing the nature of the breach, the data affected, and the steps being taken to mitigate harm.

While sm605 takes every reasonable precaution to protect your data, no internet-based service can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account password and for logging out of shared or public devices after each session. If you suspect that your Account credentials have been compromised, contact our support team immediately at the address in Section 13.

Subject to applicable law and certain conditions inherent in the nature of a regulated gaming platform, you have the following rights with respect to your personal data held by sm605:

• Right of access — you may request a copy of the personal data sm605 holds about you, together with information about how it is being used and with whom it has been shared.
• Right to rectification — if any personal data we hold about you is inaccurate or incomplete, you may request that we correct or update it. For core identity data, an updated KYC document may be required.
• Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under anti-money laundering and financial record-keeping requirements.
• Right to restrict processing — in certain circumstances (for example, where you contest the accuracy of the data or have objected to processing pending verification of our legitimate grounds), you may request that we temporarily suspend processing of your data.
• Right to data portability — where processing is based on your consent or on a contract with you and is carried out by automated means, you may request that we provide your data in a structured, commonly used, machine-readable format.
• Right to object — you have the right to object to processing carried out on the basis of legitimate interests, including profiling. We will cease that processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent — where processing is based on consent (e.g., marketing emails), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please submit a written request to the support email address in Section 13, including your Account ID and a brief description of the right you wish to exercise. sm605 will respond within 30 calendar days of receiving a valid request. Where a request is complex or high in volume, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reason for it within the initial 30-day window.

sm605 will not charge a fee for exercising your rights unless a request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

sm605 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, maintain your login session, and analyse how the Platform is used. The table below summarises the categories of cookies we deploy:

You can control cookies through your browser settings at any time. Note that disabling strictly necessary cookies will impair or prevent access to the Platform. Disabling functional cookies may result in a degraded user experience. Disabling analytics cookies will not affect your ability to play or transact.

sm605 does not use fingerprinting techniques or any other tracking method designed to circumvent browser-level cookie controls.

The sm605 Platform integrates with third-party services in order to deliver its full range of betting, casino, and payment functionality. Each of these third parties operates under its own privacy policy and data processing terms, which govern their independent use of any data received. sm605 has entered into data processing agreements with all third-party service providers who process personal data on our behalf, requiring them to maintain appropriate security standards and to use the data solely for the purposes specified by sm605.

Relevant third-party categories include:

• Game studios — Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft deliver game content through embedded interfaces. These studios receive game-session identifiers and bet amounts necessary to run and audit outcomes; they do not receive your full personal profile.
• Local payment gateways — integration partners that facilitate real-time bank transfer confirmations from BCA, BRI, BNI, Mandiri, CIMB Niaga, and BSI, as well as e-wallet confirmations from OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Analytics providers — if you have consented to analytics cookies, aggregated and anonymised usage data may be processed by a server-side analytics tool operated by sm605 or a contracted analytics provider. No individually identifiable data is shared with analytics providers.

sm605 does not embed social media plugins, third-party comment systems, or external advertising networks on the Platform. The only third-party scripts that may load on the Platform are those directly related to game delivery, payment processing, and — with your consent — analytics.

sm605 implements a mandatory KYC age-verification process prior to approving withdrawal requests, and we reserve the right to request age verification at any point during a Member's use of the Platform. If sm605 becomes aware that personal data has been collected from an individual under the age of 21, we will promptly delete that data, close the associated Account, and refund any real-money deposits net of any withdrawals already processed, to the extent possible.

If you believe that a minor in your household may have created an Account on sm605, please contact us immediately at the email address in Section 13. For guidance on preventing underage access to gambling sites, please visit our Responsible Gaming page.

sm605 may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, industry practice, or the services we offer. When changes are made, the revised Policy will be published on this page with an updated "Last Reviewed" date. Where a change is material — meaning it substantively affects your rights or the way we process your personal data — sm605 will notify registered Members by email at least fourteen (14) days before the change takes effect.

Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the updated Policy. If you do not agree with any revised terms, you must stop using the Platform before the effective date of the change. Prior versions of this Policy are available on request by emailing our support team.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way sm605 handles your personal data, please contact our support team. Our Indonesian-speaking agents are available 24 hours a day, 7 days a week.

For questions specifically about responsible gaming tools, self-exclusion, or deposit limits, please visit our Responsible Gaming page. For contractual terms governing your use of the Platform, refer to our Terms & Conditions.