gul91 Privacy Policy

gul91 ("we", "us", "our") is committed to protecting the privacy and personal data of every member who registers on our platform at gul91.vip. This Privacy Policy sets out a transparent account of the types of personal data we collect from users based primarily in Indonesia, the purposes for which that data is processed, and the technical and organizational measures we apply to keep it secure.

This Privacy Policy applies to all personal data processed in connection with the gul91 platform — including the sportsbook, live casino, online slots, in-play betting markets, card games, and any interaction with our customer support team. It applies whether you access gul91 via a mobile browser, desktop browser, or any other device.

By registering a gul91 account, making a deposit, placing a bet, or otherwise using our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not register an account or use the Services.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" — any information that can directly or indirectly identify a living individual, including name, date of birth, Indonesian mobile number, bank account details, IP address, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "Data Controller" — gul91, as the entity that determines the purposes and means by which Personal Data is processed.
• "Data Subject" / "Member" / "you" — the individual whose Personal Data is being processed; any person who has registered or is using a gul91 account.
• "Third Party" — any natural or legal person other than gul91 and the Data Subject.
• "Services" — all products and features available on the gul91 Platform, including the sportsbook, live casino, online slots, in-play betting, and card games.
• "KYC" — Know Your Customer verification, the process by which gul91 confirms the identity and age of a Member using documentary evidence.

gul91 collects the following categories of personal data from Members and prospective Members:

gul91 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data except where a KYC selfie verification is required for identity confirmation purposes, in which case the image is used solely for that purpose and not retained beyond the verification process.

gul91 collects personal data through the following primary channels:

• Direct interactions: Data you provide when registering an account, completing KYC, making a deposit or withdrawal, contacting our support team, or responding to a promotion.
• Automated technologies: Technical and usage data collected automatically via cookies, server logs, and similar tracking technologies each time you access the gul91 Platform.
• Payment processors: Transaction confirmation data received from Indonesian bank transfer systems and e-wallet providers including OVO, DANA, GoPay, ShopeePay, and LinkAja when you initiate a deposit or request a withdrawal.
• Identity verification partners: Where gul91 uses a third-party KYC verification service to confirm the authenticity of identity documents, that service may return a verified status or risk score to gul91 without sharing the underlying document data beyond what is strictly necessary.
• Publicly available sources: In limited fraud-prevention contexts, gul91 may cross-reference data with publicly available sources to validate the accuracy of information provided during registration or KYC.

gul91 processes your personal data for the following specific purposes:

• Account management: Creating, maintaining, and securing your gul91 account, including password resets, login authentication, and account preference settings.
• Service delivery: Enabling you to place bets on sports events including BRI Liga 1, EPL, and AFF Cup fixtures; play live casino games; spin online slots; and access all other gul91 products.
• Financial processing: Processing deposits and withdrawals in IDR via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, and supported e-wallets, and maintaining an accurate transaction record for each account.
• Identity verification (KYC): Confirming that each Member is at least 21 years of age and that the identity information provided at registration is accurate, in accordance with gul91's anti-fraud and responsible gaming obligations.
• Fraud prevention and security: Detecting, investigating, and preventing unauthorized account access, fraudulent transactions, bonus abuse, money laundering, and other prohibited conduct as defined in the Terms & Conditions.
• Customer support: Responding to queries, resolving complaints, and processing account-related requests submitted via live chat or email to [email protected].
• Responsible gaming: Monitoring account activity to identify patterns consistent with problem gambling; applying deposit limits, cooling-off periods, or self-exclusions as requested by Members or required by gul91's responsible gaming policy.
• Platform improvement: Analyzing aggregated usage data to identify technical issues, improve platform performance, and develop new features that better serve our Indonesian member base.
• Marketing communications: Sending promotional offers, bonus notifications, and seasonal campaign messages (e.g., Idul Fitri promotions, Ramadhan special offers) to Members who have not opted out of marketing communications. You may opt out at any time by contacting support.

gul91 processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing required to provide the Services you have requested under the gul91 Terms & Conditions — including account creation, bet placement, and payment processing.
• Consent: Where you have given explicit consent to a specific processing activity, such as receiving marketing communications or submitting KYC documents for identity verification.
• Legitimate interests: Processing necessary for gul91's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service analytics, provided those interests are not overridden by your rights and interests.
• Legal obligation: Processing required to comply with applicable laws and regulatory obligations, including anti-money-laundering requirements and age verification mandates.

gul91 does not sell or rent your personal data to third parties. We share personal data only in the following limited and controlled circumstances:

• Payment service providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum financial data necessary to process your deposit or withdrawal.
• KYC and identity verification partners: Third-party verification services that assist gul91 in confirming member identities receive identity document data strictly for that verification purpose and are contractually prohibited from using it for any other purpose.
• Technology and infrastructure providers: Hosting providers, content delivery networks, and security software vendors that support the operation of gul91's platform may process technical data on gul91's behalf under strict data processing agreements.
• Game content providers: Where you play games supplied by third-party studios — such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Pocket Games Soft — limited session data may be exchanged with those providers to facilitate gameplay and resolve technical disputes. These providers do not receive your full identity or financial data.
• Legal and regulatory authorities: gul91 may disclose personal data to law enforcement, financial intelligence units, or regulatory bodies where required to do so by applicable law, a valid court order, or in connection with an investigation into fraud, money laundering, or other criminal activity.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of gul91's business, personal data may be transferred to the relevant successor entity, provided that entity agrees to uphold the protections described in this Privacy Policy.

All third parties with whom gul91 shares personal data are required to maintain appropriate technical and organizational security measures and to process that data only for the specific purpose for which it was shared.

gul91 retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, subject to the following retention principles:

• Active account data is retained for the lifetime of the account and for a period of five years following account closure, to meet anti-money-laundering record-keeping requirements and to handle any post-closure disputes or regulatory inquiries.
• KYC documents (identity copies, address proofs) are retained for a minimum of five years following the completion of the KYC process or account closure, whichever is later.
• Transaction records — including deposit and withdrawal history and bet records — are retained for a minimum of five years from the date of the transaction.
• Support communications are retained for three years from the date of the last interaction in the relevant ticket or chat session.
• Technical and usage data (logs, IP records, session data) is retained for a maximum of 24 months unless a longer period is required for ongoing fraud investigation or legal proceedings.
• Marketing preferences and opt-out records are retained indefinitely to ensure gul91 does not re-contact a Member who has opted out.

When data reaches the end of its applicable retention period and there is no ongoing legal or regulatory reason for continued storage, gul91 will securely delete or irreversibly anonymize it.

gul91 applies a layered set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and gul91's servers.
• Encryption at rest for sensitive data fields including financial account numbers and KYC document files.
• Role-based access controls ensuring that gul91 personnel can only access personal data that is strictly necessary for their specific job function.
• Regular internal security audits and penetration testing of platform infrastructure.
• Multi-factor authentication requirements for internal administrative system access.
• Automated anomaly detection systems that flag unusual account activity — including suspicious login patterns or atypical withdrawal requests — for manual review.

While gul91 takes all reasonable precautions to secure your personal data, no internet-based system can guarantee absolute security. You also play an important role in keeping your account secure: use a strong, unique password for your gul91 account, do not share your credentials with anyone, and contact gul91 support immediately if you suspect unauthorized access to your account.

As a gul91 Member, you hold the following rights with respect to your personal data. To exercise any of these rights, contact our support team with the subject line "Data Rights Request — [Your Username]":

gul91 uses cookies and similar technologies to ensure the platform functions correctly, to maintain your session when you are logged in, and to collect anonymized usage analytics. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to operate. These include session cookies that keep you logged in during your visit. They cannot be disabled without preventing core platform functionality.
• Performance and analytics cookies: Collect anonymized information about how Members use gul91 — which pages are visited most, how long sessions last, and where errors occur. This data helps us improve platform performance.
• Functional cookies: Remember your preferences, such as display settings and preferred language, to provide a more personalized experience on return visits.
• Security cookies: Support fraud-detection and anti-bot systems by identifying unusual browsing patterns that may indicate automated or malicious activity.

You can manage cookie preferences through your browser settings. Blocking all cookies may impair the functionality of the gul91 platform, including the ability to remain logged in during a session. gul91 does not use advertising or retargeting cookies from third-party ad networks.

gul91 strictly prohibits the registration or use of its Services by individuals under the age of 21. We do not knowingly collect personal data from anyone under 21 years of age. If gul91 discovers or has reasonable grounds to believe that a Member is under 21, the account will be suspended immediately, all pending transactions will be halted, and any funds deposited may be returned to the source payment method following investigation.

If you are a parent or guardian and believe your child has registered a gul91 account, please contact our support team immediately. We will investigate the matter promptly and take appropriate action, including permanent account closure and data deletion where appropriate.

gul91's primary member base is in Indonesia and the platform is designed to serve Indonesian players. However, some of gul91's technology infrastructure, game content providers, and security service partners operate servers in other jurisdictions. Where your personal data is transferred outside Indonesia, gul91 takes steps to ensure that equivalent data protection standards are maintained, including through contractual data processing agreements with receiving parties.

In particular, game studios such as Pragmatic Play, Evolution Gaming, NetEnt, and Spribe may process limited session data on servers located outside Indonesia. gul91 requires all such partners to implement security and confidentiality obligations consistent with the standards described in this Privacy Policy.

gul91 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform features. When material changes are made, we will notify Members by posting a prominent notice on the gul91 platform and, where feasible, by sending a notification to the mobile number or email address registered to your account.

The "Last updated" date at the top of this page indicates when the current version came into effect. We encourage you to review this Privacy Policy periodically. Your continued use of the gul91 platform after the effective date of any update constitutes acceptance of the revised Policy.

If you have any questions about this Privacy Policy, wish to exercise a data right, or want to raise a concern about how gul91 has handled your personal data, please contact us through the following channels:

• Live Chat: Available directly on the gul91 platform. Indonesian-speaking agents are available 08:00–24:00 WIB; English-speaking agents are available 24/7.
• Email: [email protected] — displayed as plain text only; not a clickable link.
• Formal Data Requests: Submit via live chat with the subject line "Data Rights Request — [Your Username]". gul91 will acknowledge your request within 48 hours and respond fully within 14 calendar days.