Privacy Policy

sm306 ("we", "us", "our") operates an online betting and gaming platform accessible at https://sm306.cam (the "Platform"). We are committed to protecting the privacy and security of all personal information provided to us by our users.

This Privacy Policy describes how sm306 collects, uses, stores, discloses, and protects the personal data of individuals who register accounts, place bets, or otherwise interact with our Platform. By accessing or using the sm306 Platform, you acknowledge that you have read, understood, and agree to the collection and use of your personal information as described in this Privacy Policy.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern the contractual relationship between you and sm306. Where any conflict arises between this Privacy Policy and the Terms & Conditions, the Terms & Conditions shall prevail to the extent of the inconsistency.

For the purposes of applicable data protection laws, sm306 acts as the data controller with respect to personal data collected through the Platform. This means sm306 determines the purposes for which, and the manner in which, your personal data is processed.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the handling of your personal data, you may contact our Data Protection Officer by email at:

Email: [email protected]

Subject Line: Data Protection Inquiry

sm306 collects several categories of personal data to enable the operation of the Platform, comply with legal obligations, and provide customer support. The types of data we collect include:

3.1 Account Registration Data

When you create an sm306 account, we collect the following information:

• Full legal name
• Date of birth (to verify you meet the minimum age requirement of 21 years)
• Residential address in Indonesia
• Email address
• Mobile phone number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

To comply with international anti-money laundering and responsible gaming regulations, we collect identity verification documents including:

• Government-issued photo identification (Indonesian national identity card / KTP, passport, or driver's licence)
• Proof of residential address (utility bill, bank statement, or similar document issued within the past three months)
• Photographs or scanned copies of payment methods used for deposits (e.g., bank cards, account ownership certificates for BCA, BRI, BNI, Mandiri, or other supported banks)
• Source-of-funds documentation where required for high-value transactions

3.3 Financial Transaction Data

We collect data related to your financial transactions on the Platform, including:

• Deposit amounts, dates, and payment methods used (bank transfer, e-wallet)
• Withdrawal requests, amounts, dates, and recipient payment details
• Transaction history and account balance information
• Bonus claims and wagering activity

3.4 Betting and Gaming Activity Data

To maintain platform security, investigate disputes, and ensure fair play, we collect:

• Bet placement details (event, market, stake, odds, timestamp)
• Game session data (game type, duration, results, RNG outcomes)
• Win/loss records
• Gameplay patterns and betting behaviour analytics

3.5 Technical and Device Data

When you access the Platform, we automatically collect certain technical information, including:

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Screen resolution and display settings
• Cookies and similar tracking identifiers (see Clause 7 for full details)
• Referral source (how you found the Platform)
• Pages visited, time spent on site, and navigation patterns

3.6 Communications and Support Data

If you contact sm306 customer support, we collect and retain:

• The content of your messages, emails, or live chat transcripts
• Attachments or screenshots you provide
• Records of support tickets and resolution outcomes

sm306 processes your personal data for the following purposes:

4.1 Platform Operation and Service Provision

• To create and maintain your sm306 account
• To process deposits, withdrawals, and internal transfers
• To enable you to place bets and participate in games
• To calculate winnings, settle bets, and update account balances
• To apply bonuses, promotions, and loyalty rewards

4.2 Legal and Regulatory Compliance

• To verify your identity and age (KYC compliance)
• To prevent fraud, money laundering, and other financial crimes
• To detect and prevent underage gambling
• To comply with international gaming regulations and licensing requirements
• To respond to lawful requests from regulatory authorities or law enforcement

4.3 Security and Fraud Prevention

• To detect and prevent account takeovers, duplicate accounts, and collusion
• To identify patterns of suspicious betting behaviour
• To monitor for exploitation of software errors or bonus abuse
• To enforce our Terms & Conditions

4.4 Customer Support

• To respond to your inquiries, questions, and complaints
• To troubleshoot technical issues
• To investigate disputes and resolve account-related problems

4.5 Marketing and Communication (With Your Consent)

• To send promotional emails regarding bonuses, tournaments, and special offers (only where you have opted in)
• To notify you of important platform updates, changes to terms, or service disruptions
• To conduct customer satisfaction surveys (optional participation)

4.6 Platform Improvement and Analytics

• To analyse user behaviour and preferences in aggregate form
• To improve the user interface, performance, and features of the Platform
• To develop new products and services

Under applicable data protection laws, sm306 must have a lawful basis for processing your personal data. We rely on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and sm306 (i.e., the Terms & Conditions), including account creation, transaction processing, and service delivery.
• Legal Obligation: Processing is necessary to comply with legal requirements, including KYC, anti-money laundering, and age verification obligations imposed by international gaming regulations.
• Legitimate Interests: Processing is necessary for sm306's legitimate business interests, including fraud prevention, platform security, data analytics, and product improvement, provided these interests do not override your fundamental rights and freedoms.
• Consent: Where you have given explicit consent for marketing communications, cookies, or other optional data processing activities. You may withdraw consent at any time via your account settings.

sm306 does not sell, rent, or trade your personal data to third parties for their marketing purposes. However, we may share your personal information with the following categories of recipients in limited circumstances:

6.1 Payment Processors

We share necessary financial data with third-party payment processors (including Indonesian banks such as BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, and e-wallet providers such as OVO, DANA, GoPay, ShopeePay, LinkAja) to facilitate deposits and withdrawals. These processors operate under strict confidentiality and data protection obligations.

6.2 Identity Verification Service Providers

We may share identity verification documents with third-party KYC verification services to comply with anti-money laundering and age verification requirements. These providers are contractually bound to use your data solely for verification purposes and to protect it in accordance with applicable data protection standards.

6.3 Technology and Infrastructure Providers

We engage third-party service providers for hosting, data storage, cloud computing, cybersecurity, and technical maintenance. These providers have access to personal data only to the extent necessary to perform their contracted services and are bound by confidentiality obligations.

6.4 Game Providers and Software Licensors

Certain live casino games, slots, and RNG-based games are provided by third-party software studios (such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and others). Limited gameplay data may be shared with these providers for game operation, fairness audits, and technical support. These studios are contractually required to comply with international data protection standards.

6.5 Legal and Regulatory Authorities

sm306 may disclose personal data where required by law, court order, regulatory directive, or to respond to lawful requests from law enforcement agencies investigating fraud, money laundering, or other criminal activity. We will only disclose the minimum data necessary to satisfy the legal obligation.

6.6 Business Transfers

In the event of a merger, acquisition, sale of assets, or other corporate restructuring, personal data held by sm306 may be transferred to the acquiring entity or successor, subject to the same privacy protections set out in this Privacy Policy.

6.7 With Your Consent

We may share your personal data with other third parties where you have provided explicit consent for such disclosure.

The sm306 Platform uses cookies and similar tracking technologies to enhance user experience, maintain security, and analyse platform performance. A cookie is a small text file stored on your device that allows the Platform to recognise your browser and remember certain information across sessions.

7.1 Types of Cookies We Use

• Essential Cookies: These cookies are strictly necessary for the operation of the Platform, including maintaining your logged-in session, processing transactions, and ensuring security. You cannot opt out of essential cookies without disabling access to core Platform features.
• Performance and Analytics Cookies: These cookies collect aggregated, anonymised data about how users interact with the Platform, including pages visited, time spent, and navigation patterns. This data helps us improve the Platform's performance and user experience.
• Functional Cookies: These cookies remember your preferences (such as language settings, display preferences, or previously-visited sections) to provide a more personalised experience.
• Advertising and Marketing Cookies: Where you have opted in, these cookies may be used to deliver targeted promotional content and measure the effectiveness of marketing campaigns.

7.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can set your browser to block or delete cookies, or to notify you when a cookie is being set. However, disabling essential cookies will prevent you from accessing certain features of the Platform, including logging in and placing bets.

To learn more about cookies and how to manage them, visit www.allaboutcookies.org (external resource).

sm306 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

• Active Accounts: Personal data associated with active accounts is retained for the duration of your relationship with sm306 and for as long as your account remains open.
• Closed Accounts: Following account closure (whether voluntary or involuntary), sm306 will retain certain personal data for a minimum of seven (7) years to comply with international anti-money laundering, tax, and accounting regulations. After this retention period, personal data will be securely deleted or anonymised.
• Transaction Records: Financial transaction data, bet history, and account activity logs are retained for regulatory compliance and audit purposes for a minimum of seven years from the date of the transaction.
• Communications: Customer support records and communications may be retained for up to three years for quality assurance and dispute resolution purposes.

If you wish to request early deletion of your data (subject to legal retention requirements), please contact us at [email protected].

sm306 takes the security of your personal data seriously and implements a range of technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction.

9.1 Technical Security Measures

• 256-bit SSL/TLS Encryption: All data transmitted between your device and sm306 servers is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Secure Data Storage: Personal data is stored on secure, access-controlled servers located in jurisdictions with robust data protection laws. Access is restricted to authorised personnel only.
• Firewalls and Intrusion Detection: The Platform is protected by enterprise-grade firewalls and intrusion detection systems that monitor for suspicious activity and potential security breaches.
• Regular Security Audits: sm306 conducts regular internal and third-party security audits to identify and address vulnerabilities.
• Password Hashing: User passwords are stored using strong cryptographic hashing algorithms and are never stored in plain text.

9.2 Organisational Security Measures

• Access to personal data is granted on a need-to-know basis and is limited to employees, contractors, and service providers who require access to perform their duties.
• All personnel with access to personal data are bound by strict confidentiality obligations.
• sm306 maintains an incident response plan to detect, investigate, and respond to data breaches in accordance with applicable breach notification requirements.

9.3 Your Responsibilities

While sm306 implements robust security measures, you also have a responsibility to protect your account. Please ensure that you:

• Use a strong, unique password and do not share it with anyone.
• Enable two-factor authentication (2FA) where available.
• Log out of your account when using shared or public devices.
• Notify sm306 immediately if you suspect unauthorised access to your account.

sm306 cannot be held liable for losses resulting from unauthorised account access caused by your failure to keep your credentials secure.

Under applicable data protection laws, you have certain rights regarding your personal data. sm306 respects these rights and will respond to legitimate requests in accordance with legal requirements.

10.1 Right to Access

You have the right to request a copy of the personal data sm306 holds about you. You may submit a data access request by emailing [email protected] with the subject line "Data Access Request". We will respond within 30 days.

10.2 Right to Rectification

If you believe any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You may update most personal information directly through your account settings, or by contacting customer support.

10.3 Right to Erasure ("Right to Be Forgotten")

You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. However, this right is subject to legal retention requirements (e.g., anti-money laundering, tax, and regulatory obligations that require sm306 to retain data for up to seven years). Where deletion is not possible due to legal obligations, we will restrict processing of your data instead.

10.4 Right to Restriction of Processing

You have the right to request that sm306 restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing based on legitimate interests.

10.5 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 (where technically feasible).

10.6 Right to Object

You have the right to object to processing of your personal data where sm306 relies on legitimate interests as the legal basis for processing. If you object, sm306 will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

10.7 Right to Withdraw Consent

Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal. You may withdraw marketing consent via the unsubscribe link in any promotional email or through your account settings.

10.8 Right to Lodge a Complaint

If you believe sm306 has not complied with applicable data protection laws, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

To exercise any of these rights, please contact us at [email protected] with a clear description of your request. We may require proof of identity before processing your request to ensure data security.

sm306 operates internationally and may transfer, store, and process your personal data in jurisdictions outside Indonesia. These jurisdictions may not have data protection laws equivalent to those in Indonesia or your country of residence.

Where personal data is transferred internationally, sm306 ensures that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws. These safeguards may include:

• Standard contractual clauses approved by international data protection authorities
• Adequacy decisions recognising the recipient jurisdiction as providing an adequate level of data protection
• Binding corporate rules or other enforceable data protection frameworks

By using the sm306 Platform, you acknowledge and consent to the international transfer of your personal data as described in this Privacy Policy.

The sm306 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21.

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. Any deposits made by an underage individual will be returned in accordance with our Terms & Conditions, subject to verification of the source of funds.

If you believe sm306 has collected data from a minor, please contact us immediately at [email protected].

sm306 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. When material changes are made, we will notify you by:

• Sending an email notification to the registered email address on your account
• Displaying a prominent notice on the Platform homepage
• Updating the "Effective Date" at the top of this Privacy Policy

Continued use of the Platform following notification of changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes, you must cease using the Platform and may request closure of your account.

We recommend that you review this Privacy Policy periodically to stay informed about how we protect your personal data.

If you have any questions, concerns, or complaints regarding this Privacy Policy or sm306's data handling practices, please contact our Data Protection Officer:

Email: [email protected]

Subject Line: Privacy Policy Inquiry

Response Time: We aim to respond to all privacy-related inquiries within 30 days under normal circumstances.

For general customer support inquiries unrelated to privacy or data protection, please use the same email address with the subject line "Customer Support".