Privacy Policy

1 Introduction

mpo121 ("we", "us", "the Company", or "mpo121") operates the online betting and gaming platform accessible at https://mpo121.cam, serving players primarily located in Indonesia. We are committed to protecting the privacy and personal data of every individual who interacts with our platform, whether as a registered member or a visitor browsing our public pages.

This Privacy Policy describes our practices with respect to the collection, use, storage, disclosure, and protection of personal information in connection with the operation of the mpo121 platform. It has been drafted in accordance with internationally recognised data protection principles and reflects our commitment to transparent, responsible data stewardship.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern the overall contractual relationship between mpo121 and its registered members. Where this Privacy Policy conflicts with the Terms & Conditions on a privacy-specific matter, this Privacy Policy shall take precedence.

2 Definitions

The following terms carry the meanings assigned below throughout this Privacy Policy:

• "Personal Data" — any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, or online identifier.
• "Processing" — any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, dissemination, restriction, erasure, or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data; in this context, mpo121.
• "Data Processor" — a third party that processes Personal Data on behalf of mpo121 under a written data processing agreement.
• "User" / "you" — any individual who accesses the mpo121 platform, registers an account, or otherwise interacts with our services.
• "Cookies" — small text files placed on your device by a website to store information about your preferences, session state, or browsing behaviour.
• "KYC" — Know Your Customer; the identity and address verification process required of all members prior to withdrawal processing or full account activation.
• "Sensitive Personal Data" — a subset of Personal Data requiring heightened protection, including government identification numbers, financial account details, and biometric data collected during identity verification.

3 Data We Collect

mpo121 collects the following categories of Personal Data, depending on your level of engagement with the platform:

3.1 Registration Data

• Full legal name as it appears on your government-issued identity document.
• Date of birth (to verify you are aged 21 or over).
• Email address (used for account communications and optional marketing).
• Indonesian mobile phone number (used for two-factor authentication and account verification).
• Chosen username and encrypted password.
• Residential address in Indonesia.

3.2 Identity Verification (KYC) Data

• Scanned copy or photograph of your Indonesian national identity card (KTP — Kartu Tanda Penduduk) or valid passport.
• Proof of residential address (utility bill, bank statement, or official government correspondence).
• Selfie photograph holding your identity document for liveness verification.
• In some cases, source-of-funds documentation where required by our compliance procedures.

3.3 Financial and Transaction Data

• Bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, and BSI accounts used for deposits and withdrawals.
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja registered phone numbers or account IDs).
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment methods used.
• Betting and gaming history including stakes, game selections, odds accepted, and settlement outcomes.
• Bonus claims and wagering activity records.

3.4 Technical and Usage Data

• IP address and approximate geographic location derived therefrom.
• Device type, operating system, browser type and version.
• Pages visited, features used, and session duration data collected via cookies and analytics tools.
• Login timestamps and session logs.
• Customer support interaction records including chat transcripts and email correspondence.

3.5 Marketing Preferences Data

• Your preferences regarding promotional communications, collected at registration and adjustable at any time in account settings.
• Responses to any surveys or promotional campaigns you voluntarily participate in.

4 How We Collect Data

mpo121 collects Personal Data through the following channels:

• Directly from you — when you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact customer support, or participate in a promotion.
• Automatically via the platform — through cookies, web beacons, server logs, and analytics tools as you browse and interact with the mpo121 website.
• From third-party payment processors — when you initiate a transaction via a local Indonesian bank or e-wallet, our payment processing partners transmit confirmation data to us to record the transaction on your account.
• From identity verification partners — when you submit KYC documents, our authorised verification partners may process your data and return a verification result to us.
• From fraud prevention and compliance services — we may receive flagging signals from third-party anti-fraud and sanctions-screening services regarding accounts or transactions that require investigation.

5 Purposes of Processing

We process your Personal Data only for clearly defined, legitimate purposes. The table below summarises the primary purposes and the categories of data used for each:

mpo121 will not use your Personal Data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another valid legal basis for the new processing activity.

6 Legal Basis for Processing

mpo121 relies on the following legal bases to process your Personal Data:

• Contractual necessity — processing required to fulfil our obligations under the Terms & Conditions, including account administration, transaction processing, and bet settlement.
• Legal obligation — processing required to comply with applicable anti-money laundering (AML) regulations, international sanctions obligations, and identity verification requirements.
• Legitimate interests — processing necessary for fraud detection, platform security, and the prevention of cheating or account abuse, provided these interests are not overridden by your fundamental rights.
• Consent — processing for optional marketing communications, for which you have provided a clear, affirmative opt-in. You may withdraw consent at any time via your account settings or by contacting [email protected].

7 Data Sharing & Disclosure

mpo121 does not sell your Personal Data to third parties. We may share your data only in the following circumstances and only to the minimum extent necessary for the stated purpose:

7.1 Service Providers and Data Processors

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

• Payment processors — Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to facilitate deposits and withdrawals.
• KYC and identity verification providers — to validate government-issued identity documents and conduct liveness checks.
• Game software providers — Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and other studios receive session tokens and game-round data necessary to operate their games within our platform.
• Cloud infrastructure providers — hosting and data storage partners who operate the servers on which mpo121's platform runs.
• Customer support platforms — live chat and helpdesk software providers that facilitate support interactions.
• Analytics providers — platforms that help us understand platform usage patterns using aggregated or pseudonymised data.

7.2 Legal and Regulatory Disclosure

mpo121 may disclose your Personal Data to regulatory authorities, law enforcement agencies, courts, or other government bodies where required to do so by applicable law, court order, or binding regulatory direction. We will, where legally permitted, notify you of such a disclosure request before complying.

7.3 Business Transfers

In the event of a merger, acquisition, asset sale, or restructuring of mpo121 or its parent entities, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will notify registered members by email prior to any such transfer taking effect and will ensure the acquiring entity honours this Privacy Policy or provides equivalent protections.

8 International Data Transfers

As an internationally operated platform serving users in Indonesia, some of your Personal Data may be transferred to and stored on servers located outside of Indonesia. These transfers may occur when our cloud infrastructure providers, KYC partners, or game software studios operate data centres in other jurisdictions.

Wherever such transfers occur, mpo121 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Privacy Policy. Safeguards we rely upon include:

• Standard contractual clauses incorporated into agreements with our service providers.
• Transfers only to jurisdictions or organisations that maintain internationally recognised data protection standards.
• Technical measures including end-to-end encryption for data in transit and encryption at rest for stored data.

9 Data Retention

mpo121 retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Anonymised or aggregated data derived from your usage may be retained indefinitely for statistical and analytical purposes.

10 Security Measures

mpo121 implements a layered security architecture to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. Our key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption at rest for all stored Personal Data and financial information using industry-standard AES-256 encryption.
• Two-factor authentication (2FA) available to all registered members and mandatory for withdrawal requests above specified thresholds.
• Role-based access controls ensuring that mpo121 staff can only access Personal Data to the extent required by their job function.
• Regular penetration testing and independent security audits conducted by certified third-party security firms.
• Automated intrusion detection systems monitoring for suspicious login activity, unusual transaction patterns, and potential data exfiltration attempts.
• Incident response procedures enabling us to detect, contain, and notify affected users of any data breach within a timeframe consistent with applicable data protection obligations.

11 Cookies & Tracking Technologies

mpo121 uses cookies and similar tracking technologies to operate and improve the platform. The categories of cookies we use are described below:

11.1 Strictly Necessary Cookies

These cookies are essential for the platform to function. They enable core features such as secure login sessions, account authentication, and bet placement. Without these cookies, the platform cannot operate. No consent is required for strictly necessary cookies.

11.2 Performance and Analytics Cookies

These cookies collect information about how users interact with the platform — which pages are visited most frequently, where users encounter errors, and how sessions flow from page to page. This data is used in aggregate form to improve platform performance and user experience. We use industry-standard analytics tools for this purpose.

11.3 Functionality Cookies

These cookies remember your preferences, such as your preferred language setting, display options, and the last game you played. Disabling these cookies may reduce the convenience of your experience but will not prevent you from using core platform features.

11.4 Targeting and Marketing Cookies

With your consent, we may use targeting cookies to deliver promotional content that is relevant to your interests and gaming history. You may withdraw consent for targeting cookies at any time through your account settings. Note that withdrawing consent for marketing cookies does not affect cookies required for platform operation.

12 Your Data Rights

As a user of the mpo121 platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request".

We will acknowledge all data rights requests within 5 business days and provide a substantive response within 30 calendar days. In complex cases we may extend this period by a further 30 days, in which case we will notify you promptly with an explanation.

13 Minors

The mpo121 platform is strictly intended for adults aged 21 years and over. We do not knowingly collect Personal Data from individuals under the age of 21. If you are under 21, you must not use the mpo121 platform or provide us with any Personal Data.

If we become aware that we have inadvertently collected Personal Data from a person under 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the platform, please notify us immediately at [email protected].

Parents and guardians are encouraged to make use of parental control software to prevent minors from accessing online gambling platforms. mpo121 fully supports initiatives to keep gambling away from young people and enforces rigorous age-verification checks as part of our KYC process.

14 Third-Party Links & Services

The mpo121 platform may contain references to or integrations with third-party services, including game studios, payment processors, and analytics providers. mpo121 is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party service you interact with in connection with your use of the mpo121 platform.

Game content delivered by studios such as Pragmatic Play, Evolution Gaming, Microgaming, and NetEnt is governed by those studios' own privacy and data practices in addition to the data processing agreements we hold with them. Our agreements require these studios to process only the minimum data necessary to operate their games and to maintain appropriate security standards.

15 Policy Amendments

mpo121 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will notify registered members by email to their registered address and update the "Last Updated" date at the top of this page. Where a change relates to a new processing activity for which your consent is required, we will seek that consent before proceeding.

We recommend that you review this Privacy Policy periodically to remain informed of how we protect your data. Continued use of the mpo121 platform after the effective date of any amendment constitutes your acceptance of the updated policy. If you disagree with any changes, you may close your account as described in our Terms & Conditions.

16 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or wish to raise a privacy-related complaint, please contact us through the following channels:

• Email: [email protected] — for formal privacy requests, use the subject line "Privacy Enquiry" or "Data Rights Request".
• Live Chat: Available 24/7 on the mpo121 platform for general privacy questions.
• WhatsApp: Contact our Indonesian-speaking support team for assistance in your preferred language.

We take all privacy complaints seriously. Upon receipt of a formal complaint, we will acknowledge it within 24 hours and provide a substantive resolution within 14 business days. If you are not satisfied with our response, you have the right to escalate your complaint to a relevant data protection authority or seek independent dispute resolution.