Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by 99ls through our website located at https://99ls.cam, mobile-optimized platforms, and any related services, applications, or communications. This policy covers data collected from Indonesian residents who register accounts, make deposits, place wagers, or otherwise interact with the 99ls platform.

99ls operates as an online gaming platform offering sports betting, live casino games, slot machines, table games, and lottery draws to players in Indonesia. As part of our services, we necessarily collect and process personal information to facilitate account creation, payment processing, identity verification, customer support, regulatory compliance, and platform security.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the 99ls platform. Where conflicts arise between this policy and our Terms & Conditions, the Terms & Conditions shall prevail except where specific privacy rights are expressly granted herein.

2. Data Controller and Contact Information

99ls acts as the data controller for all personal information collected through our platform. As data controller, we determine the purposes and means of processing your personal data and are responsible for ensuring compliance with applicable data protection regulations.

For questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact our Data Protection Team:

• Email: [email protected] (subject line: Privacy Inquiry)
• Customer Service: Available 24 hours per day, 7 days per week (WIB timezone)
• Response Time: We aim to respond to all privacy-related inquiries within 72 hours

3. Information We Collect

3.1 Information You Provide Directly

When you register an account with 99ls, we collect personal information that you voluntarily provide, including:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (KTP - Indonesian National Identity Card number)
• Contact Information: Email address, telephone number, residential address, and postal code
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account identifiers, payment card information (for supported payment methods), and transaction history
• Account Credentials: Username, password (stored in encrypted/hashed format), security questions and answers, and authentication tokens
• Verification Documents: Copies of identity documents, proof of address documents (utility bills, bank statements), selfie photographs for identity verification, and payment method verification documents
• Communication Content: Messages sent through customer support channels, live chat transcripts, email correspondence, and feedback submissions

3.2 Information Collected Automatically

When you access the 99ls platform, we automatically collect certain technical information through cookies, log files, and similar tracking technologies:

• Device Information: IP address, device type and model, operating system and version, browser type and version, screen resolution, and device identifiers
• Usage Data: Pages viewed, features accessed, time spent on pages, clickstream data, referral sources, search queries, and navigation patterns
• Gaming Activity: Bets placed, games played, wager amounts, win/loss history, session duration, and gaming preferences
• Location Data: Approximate geographic location derived from IP address (country, region, city level)
• Performance Data: Platform load times, error messages, crash reports, and technical diagnostics

3.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Identity Verification Services: Age verification, identity authentication, and fraud prevention data from specialized verification providers
• Payment Processors: Transaction confirmation, payment status updates, and financial fraud screening results from banks and payment service providers
• Marketing Partners: Referral source information and campaign performance data (where you have consented to such data sharing with those partners)
• Public Databases: Information from publicly available sources for compliance and verification purposes where legally permitted

4. How We Use Your Information

99ls processes your personal information for the following legitimate purposes:

4.1 Account Management and Service Delivery

• Creating and maintaining your player account
• Processing registration requests and account verification (KYC compliance)
• Authenticating your identity when you log in
• Providing customer support and responding to inquiries
• Communicating important service updates, platform changes, and policy modifications
• Enabling platform features and personalizing user experience

4.2 Transaction Processing

• Processing deposits, withdrawals, and other financial transactions
• Verifying payment method ownership and preventing payment fraud
• Maintaining accurate transaction records and account balances
• Generating financial reports for tax and accounting purposes
• Handling bonus credits, promotional awards, and loyalty rewards

4.3 Legal and Regulatory Compliance

• Verifying player age and eligibility (21+ requirement enforcement)
• Conducting Anti-Money Laundering (AML) screening and monitoring
• Detecting and preventing fraud, collusion, and other prohibited activities
• Cooperating with regulatory authorities and law enforcement when legally required
• Maintaining records as required by gaming regulations and financial reporting standards
• Enforcing our Terms & Conditions and protecting platform integrity

4.4 Security and Fraud Prevention

• Monitoring for suspicious account activity and unusual betting patterns
• Preventing unauthorized access, account takeover, and identity theft
• Detecting bot activity, automated betting systems, and platform manipulation
• Investigating disputes, chargebacks, and reported violations
• Implementing responsible gaming measures and self-exclusion enforcement

4.5 Marketing and Communications (with consent)

• Sending promotional offers, bonus announcements, and special event notifications
• Delivering personalized content based on gaming preferences and activity
• Conducting customer satisfaction surveys and feedback requests
• Providing information about new games, features, and platform improvements

You may opt out of marketing communications at any time through account settings or by contacting customer support. Opting out of marketing does not affect essential service communications (transaction confirmations, security alerts, policy updates).

4.6 Platform Improvement and Analytics

• Analyzing platform usage patterns to improve user experience and interface design
• Testing new features, games, and functionalities
• Conducting statistical analysis of gaming trends and player behavior
• Optimizing platform performance, load times, and technical reliability
• Developing new products and services tailored to Indonesian market preferences

5. Legal Basis for Processing

99ls processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing required to fulfill our Terms & Conditions and deliver services you have requested
• Legal Obligation: Processing required to comply with applicable laws, regulations, and regulatory requirements (KYC, AML, age verification)
• Legitimate Interests: Processing necessary for fraud prevention, platform security, business analytics, and service improvement, balanced against your privacy rights
• Consent: Processing based on your explicit consent, such as marketing communications and optional data collection (consent may be withdrawn at any time)

6. How We Share Your Information

99ls does not sell your personal information to third parties. We share your data only in the following limited circumstances:

6.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment Processors: Banks, e-wallet providers, and payment gateways (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay) to process deposits and withdrawals
• Identity Verification Services: KYC/AML compliance providers for age and identity verification
• Game Providers: Software providers (Pragmatic Play, Evolution Gaming, Microgaming, etc.) whose games you play
• Customer Support Tools: Live chat platforms and support ticket management systems
• Analytics Providers: Web analytics services for platform usage analysis and performance monitoring
• Cloud Infrastructure: Hosting and data storage providers for secure server infrastructure

All service providers are contractually bound to process your data only as instructed by 99ls and to implement appropriate security measures. They are prohibited from using your data for their own purposes.

6.2 Legal and Regulatory Authorities

We may disclose your information to government authorities, regulators, or law enforcement agencies when:

• Required by law, court order, subpoena, or other legal process
• Necessary to cooperate with regulatory investigations or audits
• Required to prevent, detect, or prosecute criminal activity or fraud
• Necessary to protect the rights, property, or safety of 99ls, our players, or the public

6.3 Business Transfers

In the event of a merger, acquisition, corporate reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. You will be notified via email and/or prominent notice on our website of any such change in ownership or control of your personal information.

7. Data Security Measures

99ls implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

• Encryption: All sensitive data transmitted between your device and our servers uses SSL/TLS encryption protocols
• Secure Storage: Personal information stored on our servers is encrypted at rest using industry-standard encryption algorithms
• Password Protection: User passwords are hashed using cryptographic hashing algorithms; 99ls staff cannot view plaintext passwords
• Access Controls: Strict role-based access controls limit employee access to personal data on a need-to-know basis
• Network Security: Firewalls, intrusion detection systems, and regular security audits protect against external threats
• Secure Development: Code review, vulnerability scanning, and security testing throughout development lifecycle
• Incident Response: Documented procedures for detecting, responding to, and recovering from data breaches

While we implement robust security measures, no method of transmission over the internet or electronic storage is 100% secure. You acknowledge that you provide information at your own risk. We recommend using strong, unique passwords and enabling two-factor authentication where available.

8. Data Retention

99ls retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Active Accounts: While your account remains active, we retain all account data to provide continuous service
• Closed Accounts: After account closure, we retain certain information for up to 7 years to comply with legal obligations (tax records, AML compliance, dispute resolution)
• Marketing Data: If you opt out of marketing communications, we retain minimal data necessary to honor your opt-out preference
• Transaction Records: Financial transaction records are retained for at least 5 years as required by financial regulations
• Security Logs: Technical logs and security-related data may be retained for up to 2 years for fraud prevention and investigation purposes

Upon expiration of applicable retention periods, we will securely delete or anonymize your personal information in accordance with data protection best practices.

9. Your Privacy Rights

You have the following rights regarding your personal information held by 99ls:

9.1 Right of Access

You have the right to request confirmation of what personal information we hold about you and to obtain a copy of that information. You may submit an access request by contacting our customer support team.

9.2 Right to Rectification

If any personal information we hold about you is inaccurate or incomplete, you have the right to request correction. You can update most account information directly through your account settings or by contacting customer support.

9.3 Right to Erasure

You may request deletion of your personal information, subject to legal exceptions. We may need to retain certain data to comply with legal obligations (financial records, AML requirements) or to resolve disputes. After your account closure and expiration of legal retention periods, your data will be permanently deleted.

9.4 Right to Restrict Processing

You may request that we restrict processing of your personal information in certain circumstances, such as when you contest the accuracy of data or object to processing based on legitimate interests.

9.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.

9.6 Right to Object

You may object to processing of your personal information for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our demonstration of compelling legitimate grounds.

9.7 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 conducted prior to withdrawal.

To exercise any of these rights, please contact our customer support team at [email protected]. We will respond to your request within 30 days and may require identity verification to protect against fraudulent requests.

10. Cookies and Tracking Technologies

99ls uses cookies and similar tracking technologies to enhance platform functionality, analyze usage patterns, and deliver personalized experiences. Cookies are small text files stored on your device that allow us to recognize your browser and capture certain information.

Types of Cookies We Use:

• Essential Cookies: Required for platform operation, including authentication, session management, and security features (these cannot be disabled)
• Functional Cookies: Remember your preferences, settings, and language choices to provide enhanced user experience
• Analytics Cookies: Collect aggregated usage statistics to help us understand how players interact with the platform and identify areas for improvement
• Marketing Cookies: Track effectiveness of promotional campaigns and deliver personalized content (used only with your consent)

You can control cookie preferences through your browser settings. However, disabling certain cookies may limit platform functionality and prevent access to some features. For more information about cookies and how to manage them, visit your browser's help documentation.

11. International Data Transfers

While 99ls primarily serves Indonesian players and stores data within secure facilities, some service providers and business partners may be located outside Indonesia. In such cases, your personal information may be transferred to, stored in, and processed in countries with different data protection laws than Indonesia.

We ensure that all international data transfers are protected by appropriate safeguards, including standard contractual clauses, adequacy decisions, or other legally approved transfer mechanisms. We require all recipients to implement security measures and handle your data in accordance with this Privacy Policy and applicable data protection regulations.

12. Children's Privacy

The 99ls platform is strictly intended for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected information from someone under the minimum age requirement, we will take immediate steps to delete that information and close the associated account.

If you believe that we have collected information from a minor, please contact our customer support team immediately at [email protected].

13. Changes to This Privacy Policy

99ls reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, services, legal requirements, or for other operational, legal, or regulatory reasons. When we make material changes, we will notify you by:

• Posting the updated policy on this page with a new "Last Updated" date
• Sending email notification to your registered email address
• Displaying a prominent notice on the platform homepage

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Continued use of the 99ls platform after policy changes become effective constitutes your acceptance of the revised policy.

14. Contact Information and Complaints

For questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact us:

• Email: [email protected] (subject: Privacy Inquiry)
• Customer Service: 24/7 via live chat, email, or WhatsApp

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.