Privacy Policy — framia

framia ("we", "us", "our") operates the online betting and gaming platform accessible at https://framia.cam. As an operator serving Members primarily across Indonesia — including major cities such as Jakarta, Surabaya, Bandung, Medan, Bali, Semarang, and Yogyakarta — we are committed to handling your personal information with the utmost care, transparency, and respect.

This Privacy Policy explains in plain language how framia collects, uses, stores, protects, and in limited circumstances shares, your personal data. It also outlines the rights you hold in relation to that data and the practical steps you can take to exercise those rights.

framia's privacy practices are designed to align with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, integrity and confidentiality, and accountability. We do not collect more personal data than is necessary for the legitimate operational and compliance purposes described in this document.

This policy applies to all personal data processed by framia in connection with your use of the platform — whether you are a registered Member, a visitor browsing the site, or a prospective applicant for our services. It covers data collected online via the platform and through any email or other electronic communication you send to us.

2.1 For the purposes of applicable data protection law, the data controller responsible for your personal data is framia, the operator of the platform at https://framia.cam.

2.2 All data protection queries, subject access requests, and formal complaints should be directed to our dedicated privacy contact:

3.1 Registration & Identity Data. When you create a framia Account, we collect the following information directly from you:

3.2 Usage & Behavioural Data. As you interact with the framia platform, we automatically collect data about your activity, including: betting history (sports markets, togel (Indonesia's traditional numbers lottery) draw selections, casino game sessions), session duration and frequency, game preferences, bonus uptake and wagering activity, and customer support interaction records.

3.3 Technical Data. We collect certain technical information about the device and network you use to access framia, including: IP address, device type and operating system, browser type and version, referring URL, and general geolocation data derived from your IP address.

3.4 Communications Data. If you contact framia via email, live chat, or any other channel, we retain records of those communications, including the content of messages, timestamps, and any attachments provided, for the purpose of resolving queries and maintaining service quality records.

framia collects personal data through the following mechanisms:

• Direct collection: Information you provide when completing registration forms, KYC verification submissions, deposit and withdrawal requests, or when contacting customer support;
• Automated collection: Data gathered automatically as you navigate the platform — including cookies, server logs, and session tracking technologies;
• Third-party providers: Identity verification data from KYC service partners, fraud prevention signals from payment processors, and geolocation data from IP intelligence services;
• Payment providers: Transaction confirmation data from your nominated Indonesian bank or e-wallet provider (BCA, BRI, OVO, DANA, GoPay, etc.) to verify deposit and withdrawal activity.

framia does not purchase personal data lists from data brokers or collect personal data from social media platforms without your explicit consent.

framia processes your personal data only where there is a valid legal basis for doing so. The table below summarises our primary processing purposes and the legal basis relied upon in each case:

5.1 Withdrawal of Consent. Where our processing relies on your consent, you have the right to withdraw that consent at any time by contacting us at [email protected]. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal. Note that withdrawing consent for certain categories of processing (such as KYC data collection) may affect your ability to use specific platform features, including withdrawals.

6.1 framia does not sell, rent, or otherwise transfer your personal data to unaffiliated third parties for their own commercial purposes. We may, however, share your data with the following categories of recipients where strictly necessary:

• Payment Service Providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction data necessary to process your deposits and withdrawals;
• KYC & Identity Verification Partners: Specialist third-party identity verification services that process your submitted identity documents to complete the KYC process on our behalf;
• Game Studio Providers: Certified game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive session identifiers and wagering data necessary to operate their game environments within the framia platform;
• Fraud Prevention Services: Third-party fraud detection and security intelligence services that help framia identify suspicious account activity, protect against financial crime, and maintain platform integrity;
• Legal and Regulatory Authorities: Law enforcement agencies, regulatory bodies, and courts where framia is legally compelled to disclose information, or where disclosure is necessary to protect the rights, property, or safety of framia, its Members, or the public;
• Professional Advisers: Lawyers, auditors, accountants, and insurers who provide professional services to framia under strict contractual confidentiality obligations.

6.2 All third-party data processors engaged by framia are required to process personal data only on framia's documented instructions and to implement appropriate technical and organisational security measures. framia conducts due diligence on all data processors before engagement and reviews those relationships periodically.

6.3 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or part of framia's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material changes to this Privacy Policy that arise as a result, with reasonable advance notice.

7.1 framia operates as an internationally licensed platform. As a result, personal data collected from Members in Indonesia may be processed and stored on servers located outside of Indonesia, including in countries where the data protection framework may differ from Indonesian law.

7.2 Where personal data is transferred internationally, framia takes steps to ensure that adequate protections are in place, including:

• Transferring data only to countries recognised as providing an adequate level of data protection, or to recipients in countries that have implemented appropriate safeguards;
• Entering into data processing agreements with international recipients that incorporate standard contractual clauses consistent with internationally recognised data protection standards;
• Applying technical security measures (encryption in transit and at rest) to all cross-border data transfers.

7.3 By registering a framia Account, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Indonesia as described in this clause. If you have questions about the specific safeguards applied to any particular international transfer, please contact us at [email protected].

8.1 framia retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever is longer. The following general retention periods apply:

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised or aggregated data may be retained indefinitely for statistical and analytical purposes, as it no longer constitutes personal data.

8.3 If your account is subject to a fraud investigation, legal dispute, or regulatory inquiry, data associated with that account may be retained beyond the standard periods described above for the duration of the relevant proceedings.

9.1 framia implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your browser and the framia platform is protected by TLS (Transport Layer Security) encryption. Look for the padlock symbol in your browser's address bar when accessing framia;
• Encryption at Rest: Sensitive personal data stored on framia's servers — including financial account details and identity documents — is encrypted at rest using industry-standard algorithms;
• Password Security: Member passwords are never stored in plain text. All passwords are hashed using a strong, salted cryptographic hashing algorithm before storage;
• Access Controls: Access to personal data within framia's systems is restricted on a strict need-to-know basis. Staff with access rights are subject to background checks and mandatory data protection training;
• Network Security: framia's infrastructure is protected by firewalls, intrusion detection systems, and regular security audits conducted by independent third-party specialists;
• Incident Response: framia maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify affected Members as promptly as practicable.

9.2 While framia takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your own Account credentials confidential and for notifying framia immediately if you suspect any unauthorised access to your Account.

10.1 framia uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files placed on your device when you visit our website. They help us recognise your browser, remember your preferences, maintain your login session, and analyse how the platform is used.

10.2 The following categories of cookies are used on the framia platform:

10.3 You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or alert you when a new cookie is set. Please note that disabling strictly necessary cookies will impair your ability to use core platform features. Instructions for managing cookies in popular browsers are available on each browser's official support pages.

10.4 framia does not use cookies to serve third-party advertising on behalf of advertisers unrelated to the framia platform.

As a Member of the framia platform, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request":

11.1 Response Timeframe. framia will acknowledge all valid data rights requests within five (5) business days and will endeavour to respond substantively within thirty (30) calendar days of receipt. Complex requests may require an extension of up to a further thirty (30) days, in which case you will be notified of the delay and the reason for it.

11.2 Identity Verification for Requests. To protect your privacy, framia may request verification of your identity before acting on a data rights request. This is to ensure that we do not disclose or alter personal data in response to fraudulent requests. You will not be charged a fee for making a data rights request unless the request is manifestly unfounded or excessive.

12.1 The framia platform is strictly intended for adults aged 21 and over. framia does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not register an account, access the platform, or submit any personal data to framia.

12.2 If framia becomes aware — through KYC verification, parental notification, or any other means — that personal data has been collected from an individual under the age of 21, that data will be deleted immediately, the associated account will be terminated, and any deposited funds will be returned to the payment source where practicable.

12.3 If you are a parent or guardian and believe that your child may have registered on framia without your knowledge, please contact us immediately at [email protected] with the subject line "Underage Account" and we will investigate and take appropriate action without delay.

13.1 The framia platform integrates third-party services to deliver a complete online betting experience. These include game environments provided by Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. When you access a game within the framia platform, limited session data is shared with the relevant studio to operate the game.

13.2 framia's platform may contain links to or integrations with external services. This Privacy Policy applies solely to data processed by framia. Any personal data you provide directly to a third-party service — whether a game studio environment, a payment provider portal, or any other external site — is governed by that third party's own privacy policy. framia is not responsible for the privacy practices of third-party services.

13.3 framia does not share your personal data with third-party advertisers or ad networks. We do not allow third-party behavioural advertising cookies on the framia platform that are operated by parties unrelated to framia's own services.

14.1 framia reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. Material changes — those that substantively affect your rights or the way your data is processed — will be communicated to Members via email and/or a prominent notice on the platform at least seven (7) days before the changes take effect.

14.2 Minor amendments — such as clarifications of existing language that do not alter the substance of our practices — may be made without prior notice, though the "Last Updated" date at the top of this document will always reflect the date of the most recent change.

14.3 Your continued use of the framia platform following the effective date of any amendment constitutes acknowledgement of the updated Privacy Policy. If you do not accept the amended terms, you should cease using the platform and may request account closure in accordance with the Terms & Conditions.

14.4 The most current version of this Privacy Policy is always accessible at https://framia.cam/privacy-policy. We recommend reviewing this page periodically to stay informed of any changes.

15.1 For any questions, concerns, or requests relating to this Privacy Policy or the way framia handles your personal data, please contact our privacy team through the following channel:

15.2 Complaints. If you are not satisfied with how framia has handled your personal data or responded to a data rights request, you have the right to lodge a complaint with the relevant data protection authority. framia encourages you to contact us first so we have the opportunity to address your concern directly before escalation.

15.3 framia takes all privacy complaints seriously and will acknowledge receipt of any formal complaint within forty-eight (48) hours. We will provide a substantive written response within thirty (30) calendar days, detailing the outcome of our investigation and any remedial steps taken.