Privacy Policy

1. Definitions

The following definitions apply throughout this Privacy Policy and any supplementary data-processing notices issued by sysaas:

• "Platform" — the sysaas website at https://sysaas.cam, including all subdomains and any mobile interfaces provided by sysaas.
• "We", "Us", "Our" — sysaas, the operator and data controller of this Platform.
• "You", "Member", "User" — any individual who registers an Account on, or otherwise accesses, the Platform.
• "Personal Data" — any information that, alone or in combination with other data, can be used to identify a natural person directly or indirectly. This includes, but is not limited to, name, email address, phone number, national identity number, IP address, and device identifiers.
• "Processing" — any operation or set of operations performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• "Sensitive Personal Data" — a subset of Personal Data requiring a higher degree of protection, including government-issued identity numbers, financial account details, and any data relating to health or criminal records where collected in connection with KYC obligations.
• "Third-Party Processor" — any external organization that processes Personal Data on behalf of sysaas under a data-processing agreement, including payment gateways, game providers, and fraud prevention services.
• "Cookies" — small text files stored on your device by the Platform to enable core functionality, improve performance, and support analytics.

2. Data Controller

sysaas acts as the data controller for all Personal Data collected through the Platform. This means we determine the purposes and means by which your Personal Data is processed. Where we engage Third-Party Processors to handle data on our behalf, we remain responsible for ensuring those processors provide sufficient guarantees of data protection compliance.

For all privacy-related enquiries, correction requests, or complaints, Members may contact our designated Data Protection contact using the details provided in Section 14 of this policy. We aim to acknowledge all privacy-related correspondence within 72 hours and to resolve substantive requests within 30 calendar days.

sysaas processes data primarily to support the operation of a legitimate online gaming platform serving Members across Indonesia, including cities such as Jakarta, Surabaya, Bandung, Medan, Bali, Semarang, and Yogyakarta. The data practices described in this policy are designed to be consistent with internationally recognized data protection principles including purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.

3. Personal Data We Collect

3.1 Data You Provide Directly

sysaas collects the following categories of Personal Data that you provide to us voluntarily during registration, KYC, transactions, or when contacting our support team:

3.2 Data Collected Automatically

When you access the Platform, our systems automatically record certain technical and behavioral data necessary to deliver a functional and secure gaming experience:

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and hardware identifiers.
• Usage Data: Pages visited, features accessed, games played, session start and end times, click patterns, and search queries within the Platform.
• Transaction Logs: Full records of all deposit, withdrawal, bonus, and wagering activity linked to your Account.
• Geolocation Data: Approximate geographic location derived from your IP address, used for fraud prevention and regulatory compliance purposes.
• Cookie and Tracking Data: Information collected via cookies, web beacons, and similar technologies as described in Section 7 of this policy.

4. Legal Basis for Processing

sysaas processes your Personal Data on one or more of the following lawful bases, depending on the specific purpose of processing:

• Contractual Necessity: Processing required to fulfill our obligations to you under the sysaas Terms and Conditions, including account management, transaction processing, and customer support delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, KYC verification requirements, and fraud prevention duties imposed on regulated gaming operators.
• Legitimate Interests: Processing carried out in pursuit of our legitimate business interests, including platform security, fraud detection, product improvement, and responsible gaming monitoring, where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for optional purposes where we have sought and obtained your explicit prior consent, including the delivery of promotional communications and the use of non-essential analytics cookies. You may withdraw consent for such processing at any time without affecting the lawfulness of prior processing.

5. How We Use Your Personal Data

sysaas uses the Personal Data we collect strictly for the following defined purposes. We do not process your data in ways that are incompatible with these stated purposes without providing advance notice and, where required, obtaining your consent.

• Account Administration: Creating, maintaining, and managing your Member Account, including processing login authentication, updating profile information, and handling account closure requests.
• Transaction Processing: Facilitating deposits through BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, LinkAja, and processing withdrawal requests to verified payment accounts.
• Identity Verification (KYC): Verifying your identity and age (minimum 21 years) as required by responsible gaming obligations and anti-money laundering compliance standards.
• Fraud Prevention and Security: Detecting and investigating suspicious account activity, unauthorized access attempts, multi-accounting, bonus abuse, and money laundering activity to protect the integrity of our platform and the safety of our Members.
• Responsible Gaming: Monitoring gaming behavior patterns to identify potential signs of problem gambling and proactively offering or applying appropriate responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: Responding to your enquiries, complaints, and requests via live chat, email, and in-platform messaging.
• Platform Improvement: Analyzing aggregated and anonymized usage data to enhance the functionality, performance, and user experience of the Platform.
• Marketing Communications: Sending promotional emails, bonus notifications, and personalized offers where you have provided consent or where permitted under applicable marketing regulations. You may opt out of marketing communications at any time.
• Legal Compliance: Retaining transaction records, identity documents, and correspondence as required by applicable law, and cooperating with lawful requests from regulatory authorities or law enforcement agencies.

6. Data Sharing & Disclosure

6.1 Third-Party Processors

sysaas shares your Personal Data with carefully selected Third-Party Processors who perform specific functions on our behalf under binding data-processing agreements. These processors are authorized to use your data only as instructed by sysaas and for no other purpose. Categories of processors include:

• Payment Processors: Banking and e-wallet intermediaries (including services connecting to BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja) that process deposit and withdrawal transactions.
• Identity Verification Providers: Third-party KYC and AML screening services that verify identity documents and screen Members against sanctions and politically exposed persons (PEP) databases.
• Game Providers: Licensed studios (including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and Spribe) that deliver game content to the Platform. Game logs containing your Member ID and wagering history may be shared with providers for technical support and audit purposes.
• Fraud Prevention Services: Specialized security vendors that analyze behavioral and technical data patterns to identify fraudulent activity across our platform.
• Customer Support Tools: Providers of live chat, ticketing, and communication platforms used to deliver Member support services.
• Analytics Providers: Services that help us understand aggregated Platform usage patterns to guide product development decisions.

6.2 Legal and Regulatory Disclosure

sysaas may disclose your Personal Data to law enforcement agencies, regulatory bodies, courts, or other public authorities where we are legally required to do so, or where disclosure is necessary to establish, exercise, or defend legal rights. In such cases, we will disclose only the minimum dat a necessary to satisfy the specific legal obligation or request.

6.3 No Sale of Personal Data

sysaas does not sell, rent, lease, or otherwise transfer your Personal Data to any third party for that party's own marketing or commercial purposes. Any sharing of data is strictly limited to the operational purposes described in this policy and is governed by appropriate contractual safeguards.

6.4 Business Transfers

In the event that sysaas undergoes a merger, acquisition, restructuring, or sale of all or a material portion of its assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified via email or a prominent Platform notice prior to any such transfer, and the receiving entity will be required to honor the terms of this Privacy Policy with respect to your data.

7. Cookies & Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the Platform. They allow the Platform to recognize your device across sessions, remember your preferences, and collect usage information that helps us improve the service. In addition to cookies, sysaas may use web beacons, pixel tags, and local storage objects for similar purposes.

7.2 Types of Cookies We Use

7.3 Managing Cookies

You may configure your browser to refuse or delete cookies at any time. Please note that disabling strictly necessary or security cookies will impair core Platform functionality and may prevent you from logging in or completing transactions. Instructions for managing cookies are available in your browser's help documentation. Optional analytics and functional cookies may be disabled without affecting your ability to use the Platform's core features.

8. Data Retention

sysaas retains your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following retention periods reflect our standard practices:

• Account and Identity Data: Retained for the duration of your active Account and for a minimum of 5 years following Account closure, in compliance with anti-money laundering record-keeping obligations.
• Transaction Records: All deposit, withdrawal, and wagering records are retained for a minimum of 5 years from the date of each transaction to satisfy financial compliance and audit requirements.
• KYC Documents: Identity and verification documents are retained for the duration of your Account and for 5 years post-closure, or longer where required by applicable regulatory guidance.
• Customer Support Communications: Chat transcripts, email correspondence, and support ticket records are retained for 3 years from the date of the interaction to support dispute resolution and service quality review.
• Marketing Consent Records: Records of your marketing consent or opt-out are retained for the duration of your Account and for 2 years thereafter, to demonstrate compliance with marketing regulations.
• Technical and Usage Logs: Server logs and session data are typically retained for 12 months from the date of collection, after which they are anonymized or deleted.

Upon expiry of the applicable retention period, your Personal Data will be securely deleted or irreversibly anonymized so that it can no longer be associated with your identity. Where deletion is not immediately possible due to technical constraints, data will be isolated from active processing until secure deletion can be completed.

9. Data Security

sysaas implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, alteration, and unlawful disclosure. Our security framework includes the following controls:

• SSL/TLS Encryption: All data transmitted between your device and the sysaas Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols, protecting your information in transit from interception.
• Encryption at Rest: Sensitive Personal Data, including identity documents and financial account details, is encrypted at rest using AES-256 encryption within our secure database infrastructure.
• Access Controls: Access to Personal Data within sysaas's internal systems is restricted on a strict need-to-know basis. All staff with access to Member data are bound by confidentiality obligations and receive regular data protection training.
• Multi-Factor Authentication: Internal systems handling sensitive Member data require multi-factor authentication for all authorized personnel, reducing the risk of unauthorized access through compromised credentials.
• Penetration Testing and Vulnerability Management: The Platform undergoes regular independent security assessments, including penetration testing and vulnerability scanning, to identify and remediate security weaknesses proactively.
• Incident Response: sysaas maintains a documented data breach response procedure. In the event of a confirmed data breach affecting your Personal Data, we will notify you and relevant authorities within the timeframes required by applicable law.

While sysaas takes all reasonable steps to protect your Personal Data, no digital system can be guaranteed to be completely secure. Members are encouraged to take their own precautions, including using strong unique passwords and logging out after each session, particularly on shared devices.

10. Your Data Rights

As a Member of the sysaas Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please contact our support team using the details in Section 14. We will respond to verified requests within 30 calendar days. In complex cases, we may extend this period by an additional 30 days with prior notice.

• Right of Access: You have the right to request a copy of the Personal Data we hold about you, together with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any Personal Data we hold that is inaccurate or incomplete. Certain data (such as your registered name) may require supporting documentation before it can be amended.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to our legal obligations to retain certain records (see Section 8).
• Right to Restrict Processing: You may request that we limit the processing of your Personal Data in certain circumstances, for example while the accuracy of your data is being contested or while a complaint is under review.
• Right to Data Portability: Where processing is based on your consent or on a contractual relationship, you have the right to receive a structured, commonly used, machine-readable copy of the Personal Data you have provided to us.
• Right to Object: You have the right to object to processing of your Personal Data based on our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your rights.
• Right to Withdraw Consent: Where processing relies on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• Right to Lodge a Complaint: If you believe we have handled your Personal Data unlawfully, you have the right to lodge a complaint with the appropriate data protection authority in your jurisdiction.

11. Minors & Age Restriction

The sysaas Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. If you are under 21 years of age, you are not permitted to register an Account, access the Platform, or provide any Personal Data to sysaas.

Where sysaas discovers or is notified that Personal Data has been collected from an individual who was under 21 years of age at the time of registration, we will take immediate steps to close the relevant Account, delete all associated Personal Data, and refund any deposited funds to the source payment method where this is lawfully possible. Parents or guardians who become aware that a minor has registered on the Platform are encouraged to notify us immediately via the contact details in Section 14.

sysaas employs age verification checks at the point of registration and as part of the KYC process to minimize the risk of underage access. For further information on our age restriction policy, please visit our Responsible Gaming page.

12. International Data Transfers

sysaas's primary operations serve Members based in Indonesia. However, some of our Third-Party Processors — including game providers, KYC vendors, and technical infrastructure providers — may be located in, or process data in, jurisdictions outside Indonesia. Where such international transfers occur, sysaas ensures that appropriate safeguards are in place to maintain a level of data protection equivalent to that described in this Privacy Policy.

Safeguards for international transfers may include standard contractual clauses, binding corporate rules, or transfers to jurisdictions that offer adequate levels of data protection as recognized by relevant data protection authorities. By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in countries outside Indonesia as described in this section.

If you have concerns about how your data is handled during international transfers, please contact us using the details provided in Section 14 and we will provide further information about the specific safeguards applicable to your data.

13. Amendments to This Privacy Policy

sysaas reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the features and services offered on the Platform. When material changes are made, we will notify you by sending a notification to your registered email address and by displaying a prominent notice on the Platform at least 7 calendar days before the revised policy takes effect.

The version number and effective date shown at the top of this document identify the currently applicable version. We encourage you to review this Privacy Policy periodically to remain informed about how sysaas collects, uses, and protects your Personal Data. Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised policy.

If you do not agree with any changes to this Privacy Policy, you should discontinue your use of the Platform and may request Account closure in accordance with the procedure described in our Terms and Conditions.

14. Contact & Data Requests

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or would like to raise a privacy-related concern, please contact the sysaas data protection team through any of the following channels:

• Email: [email protected] — plaintext only, not a clickable link. Include "Privacy Request" in the subject line along with your registered username to expedite handling.
• Live Chat: Available 24/7 via the Platform's live chat widget. For formal data requests, we recommend following up with an email to ensure a documented record is created.
• In-Platform Support Ticket: Submit a formal privacy request through the support ticket system within your Account dashboard for a fully documented resolution trail.

sysaas is committed to addressing all privacy enquiries promptly and transparently. We will acknowledge receipt of your request within 72 hours and provide a substantive response within 30 calendar days, extendable to 60 days for complex requests with prior notification. All communications regarding privacy matters are treated with strict confidentiality by our support and compliance teams.