sch11 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how sch11 ("we", "us", "our") collects, uses, processes, stores, and protects the personal information of users ("you", "your") of our online betting platform and services. By creating an account and using sch11 services, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.

sch11 operates as an international online gambling platform serving players in Indonesia and other permitted jurisdictions. We are committed to maintaining the highest standards of data protection and privacy in accordance with international data protection regulations, including principles established by the General Data Protection Regulation (GDPR) where applicable, and industry best practices for responsible data handling.

We recognize that when you trust us with your personal information, we have a responsibility to protect it. This Policy outlines our data collection and processing practices transparently so you can make informed decisions about sharing your information with us. If you do not agree with any part of this Privacy Policy, you must not use our services.

2. Personal Data We Collect

2.1 Information You Provide Directly

When you register for a sch11 account, we collect the following personal information that you provide directly:

• Account Registration Data: Full legal name, date of birth, gender, email address, phone number, residential address, username, and password.
• Identity Verification (KYC) Documents: Copies of government-issued identification documents (Indonesian National ID / KTP, passport), proof of address documents (utility bills, bank statements), and selfie photographs for identity verification purposes.
• Payment Information: Bank account details (bank name, account number, account holder name), e-wallet account information, and transaction records. Note that full credit/debit card numbers are never stored on our servers — payment processing is handled by PCI-compliant third-party payment processors.
• Communications: Content of messages you send to customer support, feedback forms, survey responses, and any other communications with sch11.

2.2 Information Collected Automatically

When you use sch11 services, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IP address, device ID).
• Usage Data: Pages visited, time spent on pages, clickstream data, games played, bet history, deposit and withdrawal history, bonuses claimed, and other interaction data.
• Location Data: General location information derived from IP address to verify compliance with geographic restrictions and prevent access from prohibited jurisdictions.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, and similar technologies to maintain your login session, remember preferences, and analyze platform usage (see Section 6 for details).

2.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment processors and financial institutions for transaction verification and fraud prevention.
• Identity verification services that confirm the authenticity of submitted documents.
• Marketing partners (only if you have consented to receive marketing communications).
• Publicly available sources for compliance screening (such as sanctions lists, politically exposed persons databases).

3. How We Use Your Personal Data

sch11 collects and processes your personal information for the following legitimate purposes:

3.1 Account Management and Service Provision

• Create and maintain your player account.
• Process deposits, withdrawals, and other financial transactions.
• Provide access to games, sports betting markets, and other platform features.
• Manage bonuses, promotions, and VIP loyalty program benefits.
• Communicate important account-related information including transaction confirmations, security alerts, and policy updates.

3.2 Legal and Regulatory Compliance

• Verify your identity and age to comply with legal requirements (21+ age restriction in Indonesia).
• Conduct Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by international gambling regulations.
• Screen against sanctions lists, politically exposed persons (PEP) databases, and other compliance watchlists.
• Maintain records as required by gaming license regulations (typically 5-7 years for financial and gaming records).
• Cooperate with law enforcement, regulatory authorities, or legal proceedings when legally required.

3.3 Security and Fraud Prevention

• Detect, prevent, and investigate fraudulent activity, money laundering, bonus abuse, account sharing, and other violations of our Terms & Conditions.
• Monitor account activity for unusual patterns that may indicate unauthorized access or security breaches.
• Protect the integrity of games and ensure fair play for all users.
• Enforce account restrictions including self-exclusion and responsible gaming limits.

3.4 Customer Support

• Respond to your inquiries, complaints, and support requests via live chat, email, and WhatsApp.
• Troubleshoot technical issues and improve service quality.
• Provide personalized assistance based on your account history and preferences.

3.5 Platform Improvement and Analytics

• Analyze usage patterns and player behavior to improve platform performance, user experience, and game offerings.
• Conduct statistical analysis and research on gaming trends and player preferences.
• Test new features, games, and promotional campaigns.
• Optimize website loading times and mobile app performance.

3.6 Marketing and Communications (with Your Consent)

• Send promotional offers, bonus announcements, and special event invitations via email or SMS (only if you have opted in to marketing communications).
• Provide personalized recommendations for games and promotions based on your playing history.
• Invite you to participate in surveys and feedback programs to help us improve our services.

Note: You can opt out of marketing communications at any time by clicking the unsubscribe link in emails, adjusting your account settings, or contacting customer support. Opting out of marketing does not affect transactional communications (account alerts, withdrawal confirmations, security notifications), which are necessary for account operation and cannot be disabled.

4. Data Sharing and Disclosure

sch11 does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your data with trusted third parties in the following circumstances:

4.1 Service Providers and Business Partners

• Payment Processors: Financial institutions, banks, e-wallet providers, and payment gateways that process deposits and withdrawals on our behalf.
• Game Providers: Third-party software providers (Pragmatic Play, Evolution Gaming, PG Soft, etc.) that power casino games and live dealer tables. These providers may collect limited data necessary for game operation.
• Identity Verification Services: Specialized KYC/AML compliance providers that verify the authenticity of identity documents and screen against sanctions lists.
• Cloud Hosting and IT Infrastructure: Secure server hosting providers, database management services, and cybersecurity companies that help protect our systems.
• Customer Support Platforms: Live chat software, email service providers, and helpdesk ticketing systems used to manage customer communications.

All third-party service providers are carefully selected and contractually obligated to maintain strict data confidentiality and use your information only for the specified purposes. They must comply with data protection standards equivalent to those outlined in this Policy.

4.2 Legal and Regulatory Requirements

We may disclose your personal information when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, court orders, subpoenas, or regulatory requests from government authorities.
• Cooperate with law enforcement investigations into criminal activity, fraud, money laundering, or terrorism financing.
• Enforce our Terms & Conditions and protect our legal rights.
• Protect the safety, security, and rights of sch11, our users, or the public.

4.3 Business Transfers

In the event of a merger, acquisition, sale of assets, bankruptcy, or other business restructuring involving sch11, your personal information may be transferred to the acquiring entity or successor organization. We will notify you of any such change in ownership or control of your personal data and provide you with choices regarding the continued use of your information.

5. Data Security Measures

sch11 employs industry-leading security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Encryption

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using 256-bit Secure Socket Layer (SSL) or Transport Layer Security (TLS) protocols — the same encryption standard used by banks and financial institutions.
• Data-at-Rest Encryption: Personal information stored on our servers is encrypted using AES-256 encryption to protect against unauthorized access in the event of a data breach.
• Password Hashing: Your account password is never stored in plain text. We use strong one-way cryptographic hashing (bcrypt or similar) so that even sch11 employees cannot view your password.

5.2 Access Controls and Authentication

• Multi-factor authentication (MFA) options for enhanced account security.
• Strict role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular access audits and employee background checks.
• Mandatory security training for all staff handling sensitive data.

5.3 Infrastructure Security

• Servers hosted in secure, certified data centers with physical security measures including biometric access controls, 24/7 surveillance, and redundant power/cooling systems.
• Network firewalls and intrusion detection/prevention systems (IDS/IPS) to block unauthorized access attempts.
• Regular vulnerability scanning and penetration testing by independent security experts.
• Automated backup systems with geographically distributed redundancy to ensure data availability.

5.4 Monitoring and Incident Response

• 24/7 security monitoring and logging of system access and activity.
• Incident response plan and dedicated security team to address potential breaches.
• Obligation to notify affected users and relevant authorities in the event of a data breach as required by applicable law.

6. Cookies and Tracking Technologies

sch11 uses cookies, web beacons, and similar tracking technologies to enhance your user experience, analyze platform usage, and deliver personalized content. By using our services, you consent to the use of cookies as described in this Policy.

6.1 What Are Cookies?

Cookies are small text files stored on your device by your web browser when you visit a website. Cookies allow the website to recognize your device and remember information about your visit such as login status, preferences, and browsing history.

6.2 Types of Cookies We Use

• Essential Cookies: Necessary for the platform to function properly. These cookies enable core features like account login, session management, and secure transactions. You cannot opt out of essential cookies without disabling your ability to use sch11 services.
• Performance Cookies: Collect information about how you use our platform including which pages you visit, how long you stay, and any errors encountered. This data helps us improve platform performance and user experience. Performance cookies are anonymous and do not identify you personally.
• Functional Cookies: Remember your preferences such as language selection, currency display, and favorite games. These cookies enhance your experience by providing personalized features.
• Analytics Cookies: Used by third-party analytics services (such as Google Analytics) to collect aggregated usage statistics. These cookies help us understand player behavior and make data-driven decisions to improve our services.
• Marketing Cookies: Track your activity across websites to deliver targeted advertising and personalized promotions. You can opt out of marketing cookies through your browser settings or our cookie consent banner.

6.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can configure your browser to block all cookies, accept only certain cookies, or notify you when a cookie is set. However, disabling essential cookies will prevent you from using sch11 services. Disabling other cookies may limit functionality and personalization features.

To learn more about managing cookies in your browser, visit your browser's help documentation. Note that cookie settings are device-specific — if you access sch11 from multiple devices, you must configure cookie preferences on each device separately.

7. Your Privacy Rights

sch11 respects your privacy rights and provides you with control over your personal information. You have the following rights regarding your data:

7.1 Right to Access

You have the right to request a copy of the personal information we hold about you. This includes account details, transaction history, gaming activity, and communications. To request your data, contact customer support with your account information. We will provide your data in a commonly used electronic format within 30 days.

7.2 Right to Rectification

If your personal information is inaccurate, incomplete, or outdated, you have the right to request that we correct or update it. You can update most information directly through your account settings, or contact customer support for assistance.

7.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal data under certain circumstances. However, we may be required to retain certain information for legal, regulatory, or operational reasons including compliance with anti-money laundering regulations, resolution of disputes, enforcement of agreements, and fraud prevention. If we cannot delete your data, we will explain the legal basis for retention.

7.4 Right to Restriction of Processing

You have the right to request that we temporarily suspend processing of your personal data in certain situations, such as when you contest the accuracy of your data or object to processing for legitimate interests. During the restriction period, we will continue to store your data but will not use it except with your consent or for legal claims.

7.5 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 service provider. This right applies to data you have provided to us with your consent or for the performance of our contract with you.

7.6 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes at any time. You can opt out of marketing communications by clicking the unsubscribe link in emails or adjusting your account settings. You also have the right to object to processing based on legitimate interests — we will cease processing unless we can demonstrate compelling legitimate grounds that override your rights.

7.7 Right to Withdraw Consent

Where we process your data based on your consent (such as marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted before withdrawal.

7.8 Exercising Your Rights

To exercise any of these rights, please contact our customer support team at [email protected] with your account details and a description of your request. We will respond within 30 days and may request additional information to verify your identity before processing the request. There is no fee for exercising your privacy rights unless your request is clearly unfounded, repetitive, or excessive.

8. Data Retention

sch11 retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

8.1 Active Accounts

While your account remains active, we retain all personal information, transaction records, and gaming history to provide ongoing services, maintain account integrity, and comply with regulatory requirements.

8.2 Closed Accounts

When you close your account, we will retain certain information as required by law and regulation. Gaming license regulations typically require retention of financial records, transaction history, KYC documents, and gaming activity logs for 5-7 years after account closure. This retention is necessary for audit purposes, tax compliance, anti-money laundering investigations, and resolution of potential disputes.

8.3 Anonymization

After the required retention period expires, we will either delete your personal information or anonymize it so that it can no longer be associated with you personally. Anonymized data may be retained indefinitely for statistical analysis and research purposes.

8.4 Exceptions

We may retain personal information beyond standard retention periods when required by law, ongoing litigation, or regulatory investigations, or when necessary to protect our legal rights.

9. Changes to This Privacy Policy

sch11 reserves the right to modify or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Any changes will be effective immediately upon posting on this page with an updated "Last Updated" date.

If we make material changes that significantly affect your privacy rights or how we process your personal information, we will notify you via email to the address associated with your account or by displaying a prominent notice on the platform. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

Your continued use of sch11 services after changes to this Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the updated terms, you must discontinue use of the platform and contact customer support to close your account.

10. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact sch11's customer support team:

• Email: [email protected]
• Live Chat: Available 24/7 on our website
• WhatsApp: Available 24/7 (number displayed on website)

Our Indonesian-speaking customer service team is available around the clock to address your privacy questions and assist with exercising your data protection rights. We aim to respond to all inquiries within 48 hours.