Privacy Policy

lenira ("we", "us", "our") operates the online gaming platform accessible at https://lenira.cam (the "Platform"). We are committed to protecting the personal data of every individual who visits, registers on, or interacts with the Platform. This Privacy Policy ("Policy") has been prepared to give you a clear, comprehensive, and honest account of our data practices.

This Policy applies to all personal data processed in connection with your use of the lenira Platform, including data collected during account registration, identity verification, payment processing, customer support interactions, and general site browsing. It should be read in conjunction with our Terms & Conditions, which govern the overall contractual relationship between you and lenira.

By registering a Member account on lenira or by continuing to use the Platform after this Policy has been updated and communicated to you, you acknowledge that you have read and understood its contents. If you do not agree with any aspect of this Policy, you should discontinue use of the Platform and contact us to arrange account closure.

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

lenira collects only the personal data that is necessary for the purposes described in this Policy. The categories of data we may hold about you include:

lenira collects personal data through the following channels:

• Direct Submission: Information you actively provide when completing the registration form, submitting KYC documents, making a deposit or withdrawal request, contacting customer support, or updating your Account profile.
• Automated Technical Collection: Data gathered automatically when you visit or interact with the Platform, including IP addresses, browser fingerprints, session cookies, and device identifiers. This collection occurs regardless of whether you are logged in.
• Payment Processors: Confirmation data returned by our payment partners (local banks and e-wallet providers) upon completion of a financial transaction. lenira does not store full bank account credentials on our own servers; this data is tokenized and held by the payment processor.
• Third-Party Identity Verification Services: Where lenira uses contracted KYC service providers to perform document authentication, those providers may return verification results and risk-scoring data to lenira.
• Analytics Providers: Aggregated behavioral data from analytics tools deployed on the Platform. All such data is anonymized or pseudonymized before it is processed for analytical purposes.
• Fraud Prevention Partners: Risk signals and device reputation data from contracted fraud-detection services used to protect Members and the Platform from unauthorized access and financial crime.

lenira processes your personal data strictly for the purposes listed below. We do not use your data for any purpose that is incompatible with the original reason it was collected without first obtaining your explicit consent.

5.1 Account Administration

To create, maintain, and secure your Member account; to authenticate your identity at login; to process password resets and account updates; and to enforce the one-account-per-person rule that protects the fairness of the Platform.

5.2 Financial Transaction Processing

To receive and credit deposits made via BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, or LinkAja; to process approved withdrawal requests to your registered payment method; and to maintain an accurate transaction ledger for your Account.

5.3 Identity Verification & Regulatory Compliance

To fulfill KYC obligations by verifying that Members are who they claim to be and are at least 21 years of age; to conduct anti-money laundering (AML) screening; and to comply with any lawful request from a competent authority.

5.4 Fraud Prevention & Platform Security

To detect and investigate suspicious account activity, bonus abuse, duplicate registrations, unauthorized access attempts, and any other conduct that threatens the integrity of the Platform or the safety of other Members.

5.5 Customer Support

To respond to your inquiries, resolve disputes, process complaints, and maintain a record of support interactions for quality assurance and training purposes.

5.6 Personalization & Service Improvement

To understand how Members use the Platform so that we can improve game selection, navigation, payment flows, and promotional relevance. This processing uses aggregated and pseudonymized data wherever possible.

5.7 Marketing Communications

To send you promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications at registration or through your Account settings. You may withdraw this consent at any time by updating your notification preferences or contacting support at [email protected].

5.8 Responsible Gaming

To monitor gaming activity for signs of problem gambling behavior, to enforce self-imposed limits and self-exclusion requests, and to ensure that the Platform is not accessed by individuals who have requested an account suspension. Full details are available on our Responsible Gaming page.

Every instance of data processing at lenira is carried out under one of the following recognized legal bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you accepted at registration — including account management, payment processing, and KYC verification.
• Legal Obligation: Processing required to comply with applicable anti-money laundering regulations, age verification requirements, and any lawful order from a regulatory or judicial authority.
• Legitimate Interests: Processing carried out to further lenira's legitimate business interests — including fraud prevention, platform security, abuse detection, and service analytics — provided those interests are not overridden by your fundamental privacy rights.
• Consent: Processing for optional purposes such as marketing communications, where you have given clear, freely provided, and revocable consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

lenira does not sell, rent, or trade your personal data to any third party. We share data only in the following strictly controlled circumstances:

• Payment Service Providers: Local banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive only the minimum data necessary to process your specific transaction.
• KYC & Identity Verification Partners: Contracted document verification services receive identity documents solely for the purpose of authentication. They are prohibited from using this data for any other purpose.
• Fraud Prevention & Security Vendors: Risk-management and fraud-detection services receive technical and behavioral signals necessary to assess transaction risk. No full identity documents are shared with these vendors.
• Game Software Providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive pseudonymized session identifiers to facilitate game round delivery. They do not receive your name, contact details, or financial data.
• Legal & Regulatory Disclosure: Where lenira is required by law, court order, or a lawful request from a competent authority to disclose personal data, we will do so to the minimum extent required and will notify you wherever legally permissible.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of lenira's business, personal data held at that time may be transferred to the acquiring entity, subject to equivalent privacy protections. Members will be notified prior to any such transfer.

lenira uses cookies and similar technologies to deliver a functional, secure, and personalized platform experience. The cookies we deploy fall into the following categories:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing identifiers. They cannot be disabled without breaking core platform functionality.
• Functional Cookies: Store your preferences such as preferred language, last-visited game category, and notification settings so that the Platform behaves consistently across sessions.
• Analytics Cookies: Collect pseudonymized data on how Members navigate and use the Platform. This information helps us identify friction points and improve the user experience. No personal identity information is included in analytics data sets.
• Fraud Detection Cookies: Support our fraud-prevention systems by recording device fingerprint signals that help identify unusual account access patterns.

You can manage cookie preferences through your browser settings. Please note that disabling cookies categorized as "Strictly Necessary" will impair your ability to log in and use the Platform. lenira does not currently respond to browser "Do Not Track" signals, as no uniform standard for their interpretation has been adopted.

lenira retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal obligations. The following general retention periods apply:

• Active Account Data: Retained throughout the period your Account remains open and active on the Platform.
• KYC Documents: Retained for a minimum of five (5) years following account closure to satisfy AML record-keeping obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Support Communications: Retained for two (2) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the duration of your account and for three (3) years after opt-out, as evidence of your consent history.
• Technical & Log Data: Typically retained for ninety (90) days, after which it is anonymized or deleted unless required for an active security investigation.

Once the applicable retention period expires, personal data is securely deleted or irreversibly anonymized in accordance with lenira's internal data lifecycle procedures.

lenira implements a layered security architecture designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Key measures include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your browser and the lenira Platform is encrypted in transit using industry-standard TLS protocols.
• Encrypted Data Storage: Sensitive data fields, including identity numbers and financial account details, are encrypted at rest using AES-256 encryption.
• Access Controls: Staff access to personal data is governed by role-based access control (RBAC). Only personnel with a legitimate operational need may access Member data, and all access is logged and auditable.
• Two-Factor Authentication (2FA): Available for Member accounts. lenira strongly recommends enabling 2FA to add a second layer of protection to your login process.
• Regular Security Audits: lenira conducts periodic internal and third-party security assessments, including penetration testing, to identify and remediate vulnerabilities.
• Incident Response Protocol: In the event of a data breach that poses a risk to Members, lenira will assess the incident promptly and notify affected Members without undue delay, providing details of the nature of the breach, the data affected, and the remediation steps taken.

As a Member of lenira, you hold the following rights with respect to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request" and your registered username.

lenira will respond to all rights requests within thirty (30) days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by up to an additional thirty (30) days, with prior notification to you. Responding to rights requests is free of charge unless requests are manifestly unfounded, repetitive, or excessive.

lenira's Platform and services are strictly intended for individuals who are at least 21 years of age. We do not knowingly collect or process personal data from individuals under the age of 21. Age verification is a mandatory step in our KYC process and is enforced before any real-money wagering activity is permitted.

If lenira becomes aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated Account. Any winnings accumulated during an unverified period will be voided in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor in your care has registered on lenira, please contact us immediately at [email protected] so that we can act promptly.

lenira's Platform serves Members primarily located in Indonesia. Some of our contracted technology partners — including cloud hosting providers, game studios, and fraud-detection services — may operate infrastructure located outside Indonesia. Where personal data is transferred to a jurisdiction that does not provide an equivalent level of data protection, lenira implements appropriate safeguards, which may include:

• Standard contractual clauses or equivalent data-transfer agreements binding the recipient to obligations equivalent to those in this Policy.
• Vendor selection criteria that prioritize partners holding internationally recognized security certifications (ISO 27001 or equivalent).
• Data minimization — ensuring that only the minimum data necessary for the specific service is transferred outside Indonesia.

By using the lenira Platform, you acknowledge that your data may be processed in jurisdictions outside Indonesia and consent to such transfers in accordance with the safeguards described above.

lenira may update this Privacy Policy from time to time to reflect changes in our data practices, new regulatory requirements, or improvements to the Platform. When material changes are made, we will notify registered Members via email and display a prominent notice on the Platform at least seven (7) days before the revised Policy takes effect.

The "Last Updated" date at the top of this page will always reflect the date on which the most recent version came into force. We encourage you to review this Policy periodically so that you remain informed about how lenira handles your personal data.

Continued use of the Platform after an updated Policy takes effect constitutes your acceptance of the revised terms. If you object to any change, you may contact our support team to request account closure and deletion of your data, subject to any legally mandated retention periods.

If you have any questions about this Privacy Policy, wish to exercise one of your data rights, or want to raise a privacy-related complaint, please contact lenira's data support team using the details below. All privacy correspondence is handled by dedicated staff, separate from general customer service.

When submitting a privacy request, please include your registered username, a clear description of your request or complaint, and any relevant reference numbers. lenira will acknowledge receipt within forty-eight (48) hours and provide a substantive response within thirty (30) days.

If you are dissatisfied with lenira's handling of your privacy complaint after receiving our response, you have the right to escalate the matter to an appropriate regulatory or supervisory authority in your jurisdiction.