At hmd29, we take the privacy and security of your personal data seriously. This Privacy Policy explains what information we collect when you use the hmd29 platform, how we use and protect that data, with whom we share it, and what rights you hold as a data subject. By registering an account or using our services, you agree to the practices described herein.
These six principles summarise hmd29's approach to handling your personal information. The complete legal text for each area is detailed in the numbered clauses below.
All data transmitted between your browser and the hmd29 platform is protected by industry-standard TLS 1.3 encryption. Sensitive account and payment data is encrypted at rest using AES-256.
hmd29 will never sell, rent, or trade your personal data to third-party marketers. Your information is used solely to operate your account, process transactions, and improve your experience on our platform.
As a registered hmd29 member, you hold meaningful rights over your personal data — including the right to access, correct, restrict processing, and request deletion of information we hold about you.
We share your data only with strictly necessary service providers — payment processors such as BCA, BRI, OVO, and DANA; KYC verification partners; fraud detection systems; and licensed game studios — all under binding data protection agreements.
hmd29 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods are specified per data category in Clause 7.
In the unlikely event of a data breach that poses a risk to your rights and freedoms, hmd29 will notify affected members within 72 hours of becoming aware of the incident, in accordance with our international licensing obligations.
hmd29 ("we", "us", "our") operates the online sports betting, live casino, and slot gaming platform accessible at hmd29.bet (the "Platform"). hmd29 is licensed and regulated under an international gaming authority and provides its services primarily to adult residents of Indonesia aged 21 and over.
For the purposes of data protection law, hmd29 acts as the data controller in respect of personal data collected directly from members through the Platform. Where hmd29 engages third-party service providers to process data on its behalf, those providers act as data processors subject to binding contractual obligations that reflect the standards set out in this Privacy Policy.
This Privacy Policy applies to all personal data collected, processed, stored, and transmitted by hmd29 in connection with your use of the Platform — including the website at hmd29.bet, any progressive web app version of the Platform, and all communications sent to you by hmd29 via email or in-platform messaging.
This Policy should be read in conjunction with the hmd29 Terms & Conditions, which governs the overall contractual relationship between you and hmd29. In the event of any conflict between the Terms & Conditions and this Privacy Policy on a data protection matter, this Privacy Policy shall prevail.
This Policy does not apply to third-party websites that may be linked to or referenced from the Platform, including the websites of game studio partners, payment providers, or regulatory bodies. We encourage you to review the privacy policies of any third-party service you access independently.
hmd29 collects personal data through several channels: information you provide directly during registration or account management; data generated automatically through your use of the Platform; and, in limited circumstances, information received from trusted third-party verification partners. The categories of data we collect are set out in the table below.
| Category | Examples of Data Collected | Source |
|---|---|---|
| Identity Data | Full legal name, date of birth, Indonesian National Identity Card (KTP) number, passport number, nationality | Provided by you at registration and during KYC verification |
| Contact Data | Email address, Indonesian mobile telephone number, residential address (including city, province, and postal code) | Provided by you at registration or during account updates |
| Financial Data | Bank account name and number (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Danamon), e-wallet account identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history, deposit and withdrawal records | Provided by you at cashier; generated by Platform transaction processing |
| Technical Data | IP address, browser type and version, device type, operating system, screen resolution, session timestamps, referring URL | Collected automatically via server logs and analytics tools |
| Usage Data | Pages visited, games played (including slots, live baccarat, Sakong, sportsbook), bet amounts, game session durations, bonus activity, search queries | Generated automatically through your interaction with the Platform |
| KYC & Verification Data | Scanned copies of KTP or passport, proof-of-address documents, selfie photographs with identity documents | Provided by you during identity verification; may be supplemented by third-party KYC partner data |
| Communications Data | Content of support tickets, live chat transcripts, emails, and in-platform messages sent to or received from hmd29 | Generated by your communications with our support team |
| Marketing Preferences | Email marketing opt-in/opt-out status, promotional preference selections, notification settings | Provided by you during registration or via account settings |
hmd29 uses the personal data described in Clause 3 for the following purposes. We only process data where a valid legal basis exists, as set out in Clause 5.
hmd29 processes your personal data under one or more of the following legal bases, depending on the specific processing activity:
hmd29 does not sell your personal data to any third party. We share data only in the circumstances set out below, and only to the extent strictly necessary for the stated purpose.
hmd29 retains personal data only for as long as is necessary to fulfil the purposes described in this Policy, to comply with our legal and regulatory obligations, and to resolve any ongoing disputes or enforce our agreements. The following retention periods apply to the principal data categories we hold:
| Data Category | Retention Period | Basis |
|---|---|---|
| Identity & Contact Data | 5 years from account closure | AML regulatory obligation; licensing requirement |
| Financial & Transaction Data | 7 years from the date of each transaction | Financial record-keeping; AML compliance; dispute resolution |
| KYC Documents | 5 years from account closure | International licensing obligation; AML compliance |
| Technical & Usage Data | 13 months from collection | Legitimate interest (Platform improvement, fraud detection) |
| Support Communications | 3 years from the date of last interaction | Legitimate interest (quality assurance; dispute resolution) |
| Marketing Preferences | Until consent is withdrawn, plus 1 year | Consent; legitimate interest (suppression list management) |
On expiry of the applicable retention period, hmd29 will securely delete or irreversibly anonymise the relevant personal data. Anonymised, aggregated data (which cannot identify any individual) may be retained indefinitely for statistical and analytical purposes.
hmd29 uses cookies and similar tracking technologies on the Platform to ensure core functionality, improve usability, and — where you have provided consent — to analyse user behaviour and deliver relevant content. The categories of cookies we use are as follows:
You can manage your cookie preferences by adjusting your browser settings at any time. Note that disabling strictly necessary cookies will impair your ability to use the Platform. For full instructions on managing cookies in your specific browser, please refer to your browser's help documentation.
hmd29 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, and disclosure. Our security framework includes the following controls:
As a member of hmd29, you hold the following rights with respect to the personal data we hold about you. To exercise any of these rights, please submit a written request to [email protected]. hmd29 will respond within 30 calendar days of receiving a valid request.
hmd29 is an adults-only platform. Access to and use of our services is strictly limited to individuals who are at least 21 years of age. We do not knowingly collect personal data from anyone under the age of 21.
If hmd29 becomes aware that personal data has been collected from an individual under 21 — whether through a false age declaration at registration or any other means — we will immediately suspend the relevant account, delete all associated personal data, void any bets placed or winnings accrued, and reverse any deposits to the originating payment account where technically possible.
If you are a parent or guardian and believe that a person under 21 in your care has registered an account with hmd29, please contact us immediately at [email protected]. We will investigate and take appropriate action within 24 hours of receiving your report.
hmd29's primary data processing infrastructure is hosted in data centres that maintain ISO 27001 information security certification. Certain service providers — including some KYC verification partners and game studios — may process data outside Indonesia. In such cases, hmd29 ensures that appropriate transfer safeguards are in place, including:
By accepting this Privacy Policy, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Indonesia where data protection laws may differ from those in your country of residence. hmd29 takes all reasonable steps to ensure that such transfers are conducted securely and subject to appropriate contractual protections.
hmd29 will only send you promotional and marketing communications — including emails about bonuses, new game releases, seasonal promotions, and platform updates — where you have given your explicit consent to receive such communications during the registration process or subsequently via your account settings.
You may withdraw your consent to receive marketing communications at any time by:
Please note that withdrawal of consent to marketing communications does not affect the delivery of transactional and account-related messages — such as deposit confirmations, withdrawal notifications, security alerts, and mandatory policy update notices — which are sent on the basis of contractual necessity and cannot be opted out of while your account remains active.
hmd29 will process any unsubscribe or opt-out request within 5 business days (WIB). If you continue to receive marketing emails after this period, please contact support so we can investigate and rectify the issue promptly.
hmd29 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws and regulations, Platform features, or industry standards. All amendments will be published on this page at hmd29.bet/privacy-policy with a revised "Last Updated" date shown at the top of the page.
Where a proposed amendment is material — meaning it significantly changes the way we collect, use, or share your personal data, or reduces your rights as a data subject — hmd29 will notify you in advance via email to the address registered on your account, providing at least 14 calendar days' notice before the change takes effect. Your continued use of the Platform after the effective date of any amendment constitutes acceptance of the revised Policy.
We encourage you to review this Privacy Policy periodically to stay informed about how hmd29 protects your information. The version number and date shown at the top of this document identify the currently operative version.
If you have any questions, concerns, or requests relating to this Privacy Policy or hmd29's data processing practices, please contact our Data Protection team using the details below. We aim to respond to all privacy-related inquiries within 5 business days.
If you are dissatisfied with our response to a privacy complaint, you have the right to escalate your complaint to the relevant supervisory authority or to seek resolution through the dispute mechanism provided under our international gaming licence. hmd29 is committed to resolving all data protection concerns in good faith and in a timely manner.
Where your complaint relates specifically to responsible gaming matters — including the operation of deposit limits, self-exclusion tools, or session time-out features — please also refer to our dedicated Responsible Gaming page, which contains additional guidance and escalation pathways specific to that area.
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