Privacy Policy empire29 —
Your Personal Data is Our Responsibility

Empire29 understands that privacy is not merely a legal formality — it is about the real trust you place in us every time you share your personal data with our platform. This Privacy Policy is designed to honestly and transparently explain the data management practices we follow.

This policy applies to all personal data collected, stored, and processed by empire29 in the context of the online gaming entertainment platform services we provide. This includes interactions on the empire29.vu website, Android and iOS mobile apps, and all official empire29 communication channels.

Empire29 acts as the data controller in the context of collecting and using users' personal data. We are responsible for ensuring that the data you entrust to us is managed in accordance with the security and privacy standards we have committed to in this document.

Empire29 only collects data that is strictly necessary to operate the platform's services safely and effectively. The following are the categories of data we collect:

We do not collect sensitive data such as health information, political affiliations, or biometric data beyond what is explicitly required for the identity verification process you have agreed to.

Your personal data is collected through several different methods, all within the context of your interactions with the empire29 platform:

Data You Provide Directly

• When registering an account — name, email, date of birth, and other contact information.
• When completing KYC verification — ID photo and verification selfie.
• When adding a payment method — bank account or digital wallet details.
• When contacting our support team — conversation content and information you share.

Automatically Collected Data

• Server logs recording IP addresses, access times, and platform activity.
• Device data such as phone model, operating system, browser version, and screen resolution.
• Cookies and similar technologies that help the platform function properly.
• Transaction history and gaming activity generated from your use of the service.

Every piece of data we collect has a specific purpose. empire29 does not use your personal data beyond what is stated here:

• Identity and age verification — ensuring that only legitimate users aged 18 and above can access the service.
• Financial transaction processing — validating and securely processing all deposits and withdrawals.
• Account security — detecting unauthorized logins, suspicious activity, and potential fraud before any harm occurs.
• Service communications — sending transaction notifications, security updates, and relevant account information.
• Platform personalization — tailoring the interface and game recommendations based on your preferences and activity history.
• Service improvements — analyzing aggregated usage patterns to improve platform performance and features.
• Legal compliance — fulfilling the reporting and anti-money laundering obligations required by applicable regulations.
• Customer support — providing accurate, context-aware assistance when you contact our team.

We do not use your personal data for third-party advertising, commercial profiling, or any purpose not listed above.

Empire29 does not sell your personal data to anyone, under any circumstances. However, there are limited situations where sharing data with third parties is necessary to operate the platform's services:

Third Parties That May Receive Limited Data Access

• Payment service providers — local banks, DANA, OVO, GoPay, ShopeePay, and Virtual Account providers to process your financial transactions. Only the information necessary to complete the transaction is shared.
• KYC service providers — a third-party identity verification service that helps us securely validate your identity documents. They are bound by strict confidentiality agreements.
• Cloud & infrastructure service providers — the servers and hosting services used by empire29 operate under data agreements that ensure the security and confidentiality of your data.
• Legal authority — if required by a valid court order, anti-money laundering regulations, or an official request from authorized law enforcement.

Empire29 invests significant resources to ensure your personal data is protected to the highest commercially available security standards. This is not an empty claim — here are the concrete implementations we have in place:

• Data encryption in transit: All communication between your device and empire29 servers is encrypted using 256-bit SSL/TLS protocol — the same standard used by leading digital banks in Indonesia.
• Data encryption at rest: Sensitive data stored in the empire29 database is separately encrypted with keys that are rotated regularly, ensuring that data "at rest" remains secure.
• Strict access controls: Only empire29 staff with legitimate operational needs may access user data, and every access is recorded in an immutable audit log.
• 24/7 security monitoring: empire29's cybersecurity team monitors infrastructure in real time to detect and respond to potential threats before they impact users.
• Periodic security testing: The platform undergoes regular security audits and penetration testing to identify and close vulnerabilities before they can be exploited.
• Two-factor authentication (2FA): Available to all users and strongly recommended — an additional security layer that protects your account even if your password is compromised.

While we apply all of the above measures, no security system is 100% perfect. In the event of a data breach that significantly impacts users, empire29 is committed to notifying affected users within a reasonable timeframe.

The empire29 platform uses cookies and similar technologies to ensure the platform functions properly and delivers a personalized experience. Here are the types of cookies we use:

• Essential cookies: Required for the platform to function — including login sessions, language preferences, and form security. Without these cookies, the platform cannot operate normally.
• Functional cookies: Stores your preferences such as display settings, favorite games, and notification choices so you do not need to reconfigure them each time you log in.
• Analytics cookies: Collects anonymous usage data to help us understand how players interact with the platform and which areas need improvement.
• Security cookies: Helps detect and prevent malicious activity such as CSRF attacks and unauthorized login attempts.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may affect your ability to access and use certain features of the empire29 platform.

Your personal data is stored on servers located in the Asia region, meeting certified data security standards. empire29 ensures that all data storage locations comply with the security requirements we have established.

Regarding how long data is retained:

• Active account data — retained for as long as your account remains active on the empire29 platform.
• Financial transaction history — retained for a minimum of 5 years after the transaction occurs, in accordance with applicable legal compliance requirements for financial services.
• KYC Data — retained for the lifetime of your account plus an additional period as required by applicable anti-money laundering regulations.
• Security logs — retained for 12 months for security investigation and audit purposes.
• Data after account closure — some basic data will be retained to fulfill legal obligations and prevent re-registration by users whose accounts were closed due to violations.

Once the applicable retention period has passed, data will be securely deleted or anonymized so it can no longer be linked to your personal identity.

As an empire29 user, you have the following rights regarding your personal data. You may exercise these rights by contacting the empire29 support team via live chat:

Empire29 may update this Privacy Policy from time to time to reflect changes in our privacy practices, regulatory developments, or platform feature updates. Any significant updates will be communicated through:

• Direct in-platform notification when you log in after an update takes effect.
• Email to the address registered on your account if changes materially affect your privacy rights.
• Updated "Last Updated" date at the top of this page.

We recommend reviewing this page periodically. Continuing to use the empire29 platform after the Privacy Policy has been updated constitutes acceptance of those changes. If you disagree with any updates, you may request account closure through our support team.

If you have questions, concerns, or wish to exercise your privacy rights, the empire29 team is ready to help. Here are the best ways to reach us:

For formal requests regarding privacy rights (access, correction, or deletion of data), please include the following: your registered full name, account email, and a clear description of your request. Requests will be processed within 30 business days after your identity has been verified.