Privacy Policy — ht51

The following defined terms are used throughout this Privacy Policy:

• "ht51", "we", "us", or "our" refers to the ht51 Platform and its operating entity, accessible at https://ht51.cam.
• "Personal Data" means any information relating to an identified or identifiable natural person — a "data subject" — including but not limited to a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this context, ht51.
• "Data Processor" means any third party that processes Personal Data on behalf of ht51 under a written data-processing agreement.
• "Player" or "You" means any individual who accesses or uses the ht51 Platform.
• "KYC" means Know Your Customer — the identity, age, and source-of-funds verification process conducted in compliance with applicable anti-money laundering regulations.
• "Cookie" means a small text file placed on your device by the ht51 Platform for the purposes described in Section 8.

This Privacy Policy applies to all Personal Data collected and processed by ht51 in connection with the operation of the Platform, including data collected through the website at https://ht51.cam, through direct communications with our support team, and through third-party service providers acting as Data Processors on our behalf.

ht51 acts as the Data Controller with respect to Personal Data provided by Players and visitors. As Data Controller, ht51 is responsible for determining the purposes for which and the means by which Personal Data is processed.

This Policy is intended to serve Players and visitors who are primarily based in Indonesia. Where Indonesian data protection law (as supplemented by Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions and related ministerial regulations) applies, ht51 endeavours to meet or exceed those obligations.

ht51 collects the following categories of Personal Data, depending on your level of interaction with the Platform:

ht51 collects Personal Data through the following channels:

• Direct Submission: Data you actively provide when creating an account, completing KYC, submitting a deposit or withdrawal request, contacting customer support, or responding to a promotional campaign.
• Automated Collection: Technical and usage data collected automatically via cookies, web beacons, server logs, and similar tracking technologies each time you visit or interact with the Platform. See Section 8 for full details.
• Third-Party Sources: Identity verification data returned by our KYC service providers; fraud-risk scores provided by anti-fraud intelligence partners; device fingerprint data from our security layer; and, where applicable, publicly available information used to verify the accuracy of the data you have provided.
• Payment Processors: Transaction confirmation data (reference numbers, timestamps, amounts, payment method type) returned by our partner payment gateways following a deposit or withdrawal instruction.
• Game Providers: Aggregated game-session data (game title, wager amount, outcome, session duration) relayed from third-party studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, PG Soft, and Spribe under their respective data-sharing agreements with ht51.

ht51 processes your Personal Data only where a lawful basis exists. The table below sets out our primary processing purposes and the corresponding legal basis for each:

Where we rely on legitimate interests as a legal basis, we have conducted and documented a legitimate interests assessment (LIA) to confirm that our interests do not override your fundamental rights and freedoms. You may request a summary of any relevant LIA by contacting us as described in Section 14.

ht51 does not sell your Personal Data. We may share your data with the following categories of third parties, strictly on a need-to-know basis and subject to contractual data protection obligations:

• KYC & Identity Verification Providers: We share identity documents and biometric selfie data with our designated KYC service provider solely to verify age and identity. These providers are prohibited from using your data for any purpose beyond verification.
• Payment Processing Partners: Transaction instructions (amount, recipient account details, payment method) are shared with the relevant payment gateway or bank (e.g., the BCA virtual account system, OVO API) to execute deposits and withdrawals. We do not share your full bank account credentials beyond what is required to initiate or confirm the specific transaction.
• Game Studios: Your username and session token are shared with game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, PG Soft, Spribe) to enable gameplay. These studios receive no additional Personal Data beyond what is technically necessary to render the game.
• Fraud Prevention & Security Services: Technical identifiers (IP address, device fingerprint, session metadata) may be shared with anti-fraud intelligence platforms to detect and prevent prohibited conduct including multi-accounting, bonus abuse, and money laundering.
• Customer Support Infrastructure: Live chat and email support is facilitated through a third-party helpdesk platform. Support agents access only the account data necessary to resolve your specific enquiry.
• Legal & Regulatory Authorities: Where required by applicable law, court order, or lawful regulatory demand, ht51 may disclose Personal Data to the relevant authority. We will notify you of any such disclosure to the extent permitted by law.
• Business Successors: In the event of a merger, acquisition, or sale of all or part of ht51's business, your Personal Data may be transferred to the successor entity. You will be notified prior to any such transfer and given the opportunity to close your account if you do not consent to the new data controller's terms.

ht51 operates as an internationally hosted platform. Your Personal Data may be transferred to and processed in countries outside Indonesia, including countries where data protection laws may differ from those applicable in Indonesia.

Where such transfers occur, ht51 ensures that appropriate safeguards are in place, which may include:

• Standard contractual clauses (SCCs) incorporated into agreements with Data Processors located in third countries.
• Transfer only to jurisdictions that maintain an adequacy determination from a recognized international data protection authority.
• Binding corporate rules where data is transferred within a group of companies subject to a common data governance framework.

You may request information about the specific safeguards applicable to any international transfer involving your Personal Data by contacting us at the address set out in Section 14.

ht51 uses cookies and similar tracking technologies to operate the Platform, recognize returning users, maintain session state, and gather analytical data to improve our services. The following categories of cookies are used:

Strictly necessary cookies cannot be disabled as they are required for the Platform to function. Functional, analytics, and marketing cookies may be controlled through your browser settings. Note that disabling functional cookies may affect your user experience on the Platform.

ht51 retains Personal Data for no longer than is necessary for the purpose for which it was collected, or as required by applicable law. The following retention schedule applies:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized so that it can no longer be linked to an individual. Anonymized data may be retained indefinitely for aggregate statistical and business intelligence purposes.

As a data subject, you hold the following rights with respect to your Personal Data held by ht51. To exercise any of these rights, contact us as described in Section 14. We will respond to all requests within 30 calendar days of receipt.

The ht51 Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect Personal Data from individuals under the age of 21. Our registration process includes an age declaration step and mandatory KYC verification to enforce this requirement.

If ht51 becomes aware that Personal Data has been collected from a person under 21 years of age, we will take immediate steps to delete that data, close the associated account, and — where applicable — return any deposited funds in accordance with our Terms and Conditions.

If you are a parent or guardian and believe that a minor in your care has provided Personal Data to ht51, please contact us immediately at [email protected] and we will investigate and act on your report within 48 hours.

ht51 implements a multi-layered security architecture to protect your Personal Data against unauthorized access, accidental loss, destruction, or disclosure. Our key security measures include:

• TLS 1.3 Encryption in Transit: All data transmitted between your browser or app and ht51's servers is encrypted using TLS 1.3. Connections over older, insecure protocols are rejected.
• AES-256 Encryption at Rest: Sensitive Personal Data stored in our databases — including KYC documents and financial identifiers — is encrypted at rest using AES-256.
• Access Controls: Internal access to Personal Data is granted on a strict need-to-know basis, governed by role-based access control (RBAC) policies. All internal access events are logged and audited.
• Multi-Factor Authentication (MFA): All ht51 staff with access to production systems are required to authenticate using MFA. We strongly recommend that Players also enable any available MFA options on their accounts.
• Penetration Testing: The Platform undergoes periodic security assessments and penetration tests conducted by qualified independent security professionals.
• Incident Response: In the event of a Personal Data breach that is likely to result in a risk to your rights and freedoms, ht51 will notify affected Players without undue delay and will take immediate steps to contain and remediate the breach.

ht51 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, operational requirements, or applicable law. When material changes are made, we will:

• Update the "Last updated" date at the top of this page.
• Send a notification to all registered Players via the email address on file.
• Display a prominent notice on the Platform for a minimum of 14 days following the effective date of the change.

Your continued use of the Platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with a material amendment, you may close your account and request deletion of your Personal Data as described in Section 10, subject to mandatory retention obligations under applicable law.

For all privacy-related enquiries, data subject requests, or concerns about how ht51 handles your Personal Data, please contact our Data Protection Officer (DPO) team using the details below:

• Email: [email protected] — use the subject line "Privacy Enquiry — [Your Username]" for faster routing.
• Response Time: We acknowledge all privacy enquiries within 48 hours and aim to provide a substantive response within 30 calendar days of receipt.
• Support Hours: 08:00–22:00 WIB, seven days a week, including Indonesian public holidays (subject to Nyepi service pause).
• Live Chat: Available 24/7 on the Platform for general queries; formal data subject requests must be submitted in writing via email as described above.

All formal data subject requests must be submitted in writing via email to [email protected]. Requests submitted via live chat will be acknowledged but are not treated as formal written requests for the purposes of our statutory response timelines.