Privacy Policy

This Privacy Policy describes how celo11 (referred to in this document as "celo11", "we", "us", or "our") collects, processes, stores, uses, shares, and protects personal information provided by or collected from users ("you", "your", "player") of the celo11 platform, accessible at celo11.cam and any associated mobile applications or services (collectively, the "Platform").

By registering an account on the Platform, accessing our services, or otherwise providing personal information to celo11, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, you must not use the Platform or provide any personal information to celo11.

This Privacy Policy should be read in conjunction with our Terms & Conditions and any other policies or terms referenced on the Platform. In the event of any conflict between this Privacy Policy and other documents, the more specific provision shall prevail to the extent of the inconsistency.

For the purposes of applicable data protection legislation, celo11 is the data controller responsible for the personal information processed through the Platform. This means that celo11 determines the purposes for which, and the manner in which, your personal data is processed.

All enquiries regarding this Privacy Policy, requests to exercise your data protection rights, or complaints concerning our data handling practices should be directed to our Data Protection team at the contact details provided in Section 14 of this document.

celo11 collects several categories of personal information in order to provide, maintain, protect, and improve our services. The information we collect falls into the following categories:

3.1  Information You Provide Directly

When you register for an account or use the Platform, you provide us with the following information:

• Account Registration Data: Full legal name, date of birth, email address, mobile phone number, residential address, and chosen username and password.
• Identity Verification Documents: Government-issued identification (Indonesian national identity card / KTP, passport, or driver's license / SIM), proof of address (utility bills, bank statements), and facial photographs for biometric verification.
• Payment Information: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, or other accepted Indonesian banks), e-wallet account identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history related to deposits and withdrawals.
• Communications: Any information you provide when contacting our customer support team via live chat, email, or other communication channels, including support ticket contents, chat transcripts, and correspondence records.
• Responsible Gaming Settings: Self-imposed deposit limits, loss limits, session time limits, cooling-off periods, and self-exclusion requests.

3.2  Information We Collect Automatically

When you access or use the Platform, we automatically collect certain technical and usage data, including:

• Device Information: Device type, operating system, browser type and version, device identifiers (IMEI, MAC address, device fingerprint), screen resolution, and installed fonts.
• Connection Data: IP address, internet service provider, geographic location (derived from IP address), time zone settings, and network connection type.
• Usage Data: Pages visited, features used, games played, time spent on pages, click patterns, navigation paths, search queries, bet history, gaming session duration, and platform interaction metrics.
• Cookies and Similar Technologies: Data collected through cookies, web beacons, pixel tags, local storage, and other tracking technologies as described in Section 7 below.

3.3  Information from Third Parties

In certain circumstances, celo11 may receive personal information about you from third-party sources, including:

• Payment Processors: Transaction verification data, fraud detection signals, and payment method validation information from our banking and e-wallet partners.
• Identity Verification Providers: Age verification results, identity authentication outcomes, and sanctions screening data from specialised KYC service providers.
• Game Providers: Game session data, RNG results, and gameplay statistics from third-party studios whose games are offered on the Platform (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft, and others).
• Fraud Prevention Services: Risk scores, device reputation data, and behavioural biometrics from fraud detection and prevention partners.

celo11 processes your personal information for the following purposes:

4.1  Account Management & Service Delivery

• To create, maintain, and authenticate your player account.
• To process deposits, withdrawals, and other financial transactions in Indonesian Rupiah (IDR).
• To provide access to casino games, sportsbook markets (including BRI Liga 1, EPL, La Liga, Champions League, and other supported competitions), live dealer experiences, and togel (Indonesia's traditional numbers lottery) markets.
• To calculate, credit, and manage bonuses, promotions, cashback, and loyalty rewards.
• To enforce wagering requirements, bonus terms, and other promotional conditions.
• To provide customer support and respond to your enquiries via live chat, email, or other support channels.

4.2  Legal & Regulatory Compliance

• To verify your identity, age (21+ requirement), and residency status in accordance with Know Your Customer (KYC) and anti-money laundering (AML) regulations.
• To detect, investigate, and prevent fraud, collusion, bonus abuse, and other prohibited activities.
• To comply with legal obligations, court orders, regulatory requests, and law enforcement enquiries.
• To maintain audit trails and transaction records as required by gaming licence conditions and financial regulations.
• To enforce our Terms & Conditions, manage disputes, and protect the rights and safety of celo11, our players, and third parties.

4.3  Platform Improvement & Analytics

• To monitor, analyse, and improve the performance, functionality, and user experience of the Platform.
• To conduct data analytics and statistical research on player behaviour, game popularity, and platform usage patterns (in aggregated, anonymised form where possible).
• To test new features, optimise user interfaces, and develop new products and services tailored to the Indonesian gaming market.
• To diagnose technical issues, fix software bugs, and maintain platform security and stability.

4.4  Marketing & Communications

• To send you promotional offers, bonus notifications, tournament announcements, and other marketing communications where you have consented to receive such communications.
• To personalise content, recommendations, and promotional offers based on your gaming preferences and history.
• To notify you of important account updates, policy changes, security alerts, and service announcements (these are transactional communications sent regardless of marketing consent).

4.5  Responsible Gaming

• To implement and enforce responsible gaming tools including deposit limits, loss limits, session time limits, reality checks, cooling-off periods, and self-exclusion arrangements.
• To monitor player behaviour for signs of problem gambling and to intervene with appropriate support resources where necessary.
• To maintain records of responsible gaming interactions for compliance and player welfare purposes.

celo11 processes your personal data on one or more of the following legal bases, as applicable under data protection law:

• Contractual Necessity: Processing is necessary to perform the contract between you and celo11 (i.e., our Terms & Conditions). This covers account creation, transaction processing, game delivery, and customer support.
• Legal Obligation: Processing is necessary to comply with applicable laws and regulations, including KYC, AML, responsible gaming obligations, and gaming licence conditions.
• Legitimate Interest: Processing is necessary for celo11's legitimate business interests, such as fraud prevention, platform security, service improvement, data analytics, and business operations, provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where required by law, processing is based on your explicit consent, such as for marketing communications, certain cookie uses, and optional data collection. You may withdraw consent at any time through your account settings or by contacting support.

celo11 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may share your personal data with the following categories of recipients in the circumstances described below:

6.1  Service Providers & Business Partners

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) that facilitate deposit and withdrawal transactions.
• Game Content Providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft that deliver gaming content on the Platform and process gameplay data.
• Identity Verification Services: Third-party KYC and AML compliance providers that perform identity checks, age verification, document authentication, and sanctions screening.
• Cloud Hosting & Infrastructure: Data centre operators and cloud service providers that host the Platform's servers and databases.
• Analytics & Marketing Tools: Third-party analytics platforms, customer relationship management (CRM) systems, and marketing automation tools used to analyse platform usage and deliver targeted communications.
• Customer Support Software: Live chat providers and helpdesk platforms used to manage player enquiries and support tickets.

All service providers are contractually bound to process your personal data only as instructed by celo11, to maintain appropriate security measures, and to comply with applicable data protection laws.

6.2  Legal & Regulatory Authorities

celo11 may disclose your personal information to law enforcement agencies, regulatory bodies, courts, government authorities, or other third parties where required or permitted by law, including:

• In response to valid legal process (subpoena, court order, warrant).
• To comply with gaming licence reporting obligations and regulatory investigations.
• To prevent, detect, or prosecute fraud, money laundering, or other criminal activity.
• To protect the rights, property, or safety of celo11, our players, or the public.

6.3  Business Transfers

In the event that celo11 undergoes a merger, acquisition, reorganisation, sale of assets, or similar corporate transaction, your personal information may be transferred to the acquiring or successor entity as part of that transaction. You will be notified of any such change in ownership or control of your personal data.

celo11 uses cookies, web beacons, pixel tags, local storage, and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and deliver personalised content.

7.1  What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They allow the website to recognise your device and remember certain information about your preferences and actions. Cookies can be "session" cookies (deleted when you close your browser) or "persistent" cookies (remain on your device until they expire or are manually deleted).

7.2  Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. They enable core features like account login, secure session management, and access to restricted areas. These cookies cannot be disabled without severely impairing platform functionality.
• Performance & Analytics Cookies: Collect anonymous usage statistics to help us understand how players use the Platform, which pages are most popular, and how we can improve performance. We use tools like Google Analytics for this purpose.
• Functional Cookies: Remember your preferences (language, currency format, game filters) and personalise your experience across sessions.
• Marketing & Advertising Cookies: Track your browsing across websites to build a profile of your interests and deliver targeted advertising. These cookies require your consent and can be disabled through your cookie preferences.

7.3  Managing Cookies

You can control and delete cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or notify you when a cookie is being set. Please note that disabling cookies may impact your ability to use certain features of the Platform. For more information on managing cookies, consult your browser's help documentation.

celo11 retains your personal information for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and maintain business records.

Specific retention periods vary depending on the type of data and the purpose for which it is held:

• Account Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure or inactivity, as required by gaming regulations and financial record-keeping laws.
• Transaction Records: Retained for a minimum of seven (7) years following the transaction date to comply with AML, tax, and financial audit requirements.
• Identity Verification Documents: Retained for the duration of your account plus five (5) years following account closure, unless a longer retention period is required by law or regulatory authority.
• Communications & Support Records: Retained for a minimum of three (3) years to maintain service quality records and resolve disputes.
• Marketing Consent Records: Retained for as long as consent remains valid, plus three (3) years following withdrawal of consent to demonstrate compliance with marketing regulations.
• Responsible Gaming Records: Self-exclusion records are retained permanently to prevent future account registration and to comply with player protection obligations.

After the applicable retention period expires, personal data is securely deleted or anonymised such that it can no longer identify you.

Subject to applicable data protection laws, you have the following rights regarding your personal information:

• Right of Access: You may request a copy of the personal data we hold about you, including details of the processing purposes, data categories, recipients, and retention periods.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. You can update much of your account information directly through your account settings.
• Right to Erasure: You may 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, or where you withdraw consent. Note that we may be required by law to retain certain data even after a deletion request.
• Right to Restriction of Processing: You may request that we limit the processing of your personal data in certain circumstances, such as while we verify the accuracy of data you have contested.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format and transmit it to another data controller where technically feasible.
• Right to Object: You may object to processing of your personal data based on legitimate interests or for direct marketing purposes. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory data protection authority if you believe our processing of your personal data violates applicable law.

To exercise any of these rights, please contact our Data Protection team using the details provided in Section 14. We will respond to your request within 30 days. Verification of your identity may be required before we can action your request.

celo11 takes the security of your personal information seriously and implements industry-standard technical and organisational measures to protect your data from unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL (Secure Sockets Layer) technology.
• Secure Data Storage: Personal data is stored on secure servers located in certified data centres with physical access controls, fire suppression systems, and 24/7 monitoring.
• Access Controls: Access to personal data is restricted to authorised celo11 personnel and service providers on a need-to-know basis, using role-based access controls and multi-factor authentication.
• Password Protection: Player passwords are hashed using strong cryptographic algorithms and are never stored in plain text.
• Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing to identify and remediate potential weaknesses.
• Incident Response: We maintain a documented incident response plan to detect, contain, and respond to data breaches or security incidents promptly.

While we strive to use commercially acceptable means to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you acknowledge that you provide information at your own risk.

The Platform is operated from servers located outside Indonesia, and certain service providers we engage may process your personal data in countries other than Indonesia. This means your personal information may be transferred to, stored in, and processed in jurisdictions that may have different data protection laws than those in Indonesia.

When we transfer your personal data internationally, we take steps to ensure that appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include:

• Standard contractual clauses approved by relevant data protection authorities.
• Verification that the recipient is certified under an approved data protection framework.
• Implementation of technical and organisational security measures equivalent to those we employ for data stored within Indonesia.

By using the Platform and providing your personal information, you acknowledge and consent to such international transfers.

The Platform is intended exclusively for individuals who are at least 21 years of age. celo11 does not knowingly collect, process, or solicit personal information from anyone under the age of 21, and we do not knowingly allow such persons to register accounts or use the Platform.

If we become aware that we have collected personal information from a person under 21 years of age without proper age verification, we will take immediate steps to delete that information and permanently close the associated account. No refunds will be issued for accounts closed due to underage registration.

If you are a parent or guardian and believe that your child has provided personal information to celo11, please contact us immediately at [email protected] so that we can take appropriate action.

celo11 reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this Privacy Policy, we will notify registered players by:

• Posting a prominent notice on the Platform homepage.
• Sending an email notification to the address registered on your account.
• Displaying an in-platform notification upon your next login.

The "Last Updated" date at the top of this document indicates when the Privacy Policy was most recently revised. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

Your continued use of the Platform following the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree to the updated Privacy Policy, you must cease using the Platform and may request account closure in accordance with our account closure procedures.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please contact our Data Protection team using the following details:

• Email: [email protected] (plain text — not a clickable link). For privacy-specific enquiries, please include "DATA PRIVACY REQUEST" in your email subject line.
• Live Chat: Available 24/7 through the on-Platform chat widget. Our support agents can escalate privacy requests to the Data Protection team.
• Response Time: We aim to acknowledge privacy-related enquiries within 2 business days and to provide a substantive response within 30 days.

When submitting a privacy request, please provide sufficient information to allow us to verify your identity and locate your account. This may include your registered email address, account username, and a copy of your government-issued identification.