sin77 Privacy Policy

1. Introduction

sin77 ("we", "us", "our") operates the online gaming and sportsbook platform accessible at sin77.bet (the "Platform"). We are committed to safeguarding the privacy and personal data of every individual who accesses, registers on, or otherwise interacts with the sin77 Platform (each a "User" or "you").

This Privacy Policy sets out, in full and in plain terms, the categories of personal data we collect, the purposes for which that data is processed, the legal basis on which we rely to process it, the third parties with whom we may share it, the security measures we apply to protect it, and the rights you hold in respect of your personal information.

By registering an Account on sin77 or by continuing to use the Platform after this Privacy Policy has been made available to you, you acknowledge that you have read, understood, and agreed to the data practices described herein. If you do not agree to this Privacy Policy, you must discontinue use of the Platform immediately.

This Privacy Policy should be read alongside our Terms & Conditions, which govern your use of the Platform more broadly. In the event of any conflict between the two documents with respect to the processing of personal data, this Privacy Policy will prevail.

2. Data Controller

For the purposes of applicable data protection law, sin77 is the data controller in respect of personal data collected from Users through the Platform. As data controller, sin77 determines the purposes and means of processing your personal data and bears primary responsibility for ensuring that such processing is carried out lawfully, fairly, and transparently.

sin77 primarily serves players located in Indonesia. If you are resident in Indonesia and have questions or concerns regarding your personal data, you may contact our dedicated Data Protection contact using the details set out in Section 15 of this Policy.

3. Data We Collect

sin77 collects personal data in the following categories:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification document.
• Date of birth — collected to verify that you meet the 21+ age requirement for Platform access.
• Residential address in Indonesia, including city (e.g., Jakarta, Surabaya, Bandung, Bali, Medan) and postal code.
• Email address used to create and access your Account.
• Mobile phone number for account security and transaction verification purposes.

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification, such as your national identity card (KTP) or passport.
• Proof of residential address documents, such as a utility bill or bank statement issued within the past three months.
• Selfie images or video verification submitted as part of liveness-check procedures where applicable.
• Documentation evidencing the source of funds or payment method, where required by our compliance team.

3.3 Financial Data

• Indonesian bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, and any other supported bank.
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja accounts linked to your Profile.
• Transaction history, including deposit amounts, withdrawal amounts, timestamps, and payment method used, all denominated in Indonesian Rupiah (IDR / Rp).

3.4 Gaming & Behavioral Data

• Betting history, game play records, wager amounts, win/loss outcomes, and bonus utilization records.
• Session duration, login timestamps, and in-Platform navigation patterns.
• Responsible gaming tool usage, including deposit limit settings, cool-off activations, and self-exclusion requests.

3.5 Technical & Device Data

• IP address and geolocation data derived from it at the time of login and transaction.
• Device type, operating system, browser type and version, and screen resolution.
• Unique device identifiers and mobile advertising IDs where applicable.

3.6 Communications Data

• Records of live chat transcripts, email correspondence, and support tickets exchanged between you and the sin77 customer support team.
• Responses to surveys, promotional campaigns, or feedback forms you choose to complete voluntarily.

4. How Data Is Collected

sin77 collects personal data through the following channels:

• Directly from you — when you complete the registration form, submit KYC documents, initiate a deposit or withdrawal, contact customer support, or participate in a promotion.
• Automatically through the Platform — via cookies, web beacons, server-side logging, and similar tracking technologies that record your interactions with the Platform (see Section 10 for full details).
• From third-party service providers — including KYC verification bureaus, fraud-detection services, payment processors, and analytics platforms that share data with sin77 pursuant to their own agreements with us.
• From publicly available sources — such as sanctions lists, politically exposed persons (PEP) registers, and adverse media databases consulted as part of our anti-money laundering screening obligations.

5. Purposes of Processing

The table below summarizes the primary purposes for which sin77 processes your personal data:

sin77 will not process your personal data for purposes that are incompatible with those listed above without providing you with prior notice and, where required by applicable law, obtaining your consent.

6. Legal Basis for Processing

sin77 relies on one or more of the following legal bases to process your personal data:

• Contractual necessity: Processing that is required to perform the contract between sin77 and you — principally, providing the gaming and sportsbook services you have signed up to use, processing your deposits and withdrawals, and managing your Account.
• Legal obligation: Processing that sin77 is required to carry out to comply with applicable legal and regulatory obligations, including anti-money laundering (AML) due diligence, KYC verification, and the retention of financial transaction records.
• Legitimate interests: Processing that is necessary for sin77's legitimate business interests, where those interests are not overridden by your rights — including fraud prevention, platform security monitoring, responsible gaming enforcement, and general platform analytics. sin77 has conducted legitimate interest assessments for each such purpose.
• Consent: Where no other legal basis applies, sin77 will request your explicit consent before processing your data — for example, for the sending of direct marketing communications via email or SMS. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing & Third-Party Disclosure

sin77 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may, however, share your personal data with the following categories of recipients where necessary and under strict data processing agreements:

7.1 Service Providers

Third-party vendors who process data on our behalf to support Platform operations, including KYC verification bureaus, payment processors, fraud-detection technology providers, cloud hosting providers, live-game studio operators (such as Evolution Gaming and Pragmatic Play), and customer support platform providers. All service providers are bound by contractual obligations that restrict their use of your data to the specific service being provided.

7.2 Regulatory & Law Enforcement Authorities

Where required by applicable law, court order, or a lawful request from a competent regulatory or law enforcement authority, sin77 will disclose personal data to the relevant body. sin77 will, where legally permissible, notify you of such a disclosure request before complying with it.

7.3 Business Transfers

In the event that sin77 undergoes a merger, acquisition, asset sale, or restructuring, your personal data may be transferred to the acquiring entity as part of that transaction. In such circumstances, sin77 will ensure that the acquiring entity is bound by terms no less protective than those set out in this Privacy Policy, and will notify affected users of the transfer in advance where practicable.

7.4 Responsible Gaming Partners

With your explicit consent, or where required by regulatory obligations, sin77 may share your gaming behavioral data with licensed responsible gaming support organizations for the purpose of facilitating problem gambling intervention and support services.

8. Data Retention

sin77 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention guidelines apply:

• Account & identity data: Retained for the duration of your Account's active status and for a minimum of five (5) years following permanent Account closure, in compliance with AML record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years following the completion of the verification process or Account closure, whichever is later, in accordance with applicable financial regulations.
• Transaction records: Retained for a minimum of five (5) years following the date of the transaction to satisfy financial audit and regulatory reporting obligations.
• Gaming & behavioral data: Retained for the duration of the Account and for up to three (3) years following Account closure for responsible gaming and fraud analytics purposes.
• Communications data: Support correspondence and chat transcripts are retained for up to two (2) years from the date of the interaction for quality assurance and dispute resolution purposes.
• Technical & device data: IP logs and device records are retained for up to twelve (12) months for security and fraud detection purposes, unless a specific investigation requires extended retention.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with sin77's internal data lifecycle management procedures.

9. Data Security

sin77 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption on all data transmitted between your device and sin77's servers.
• Encryption at rest for all stored personal data, including KYC documents and financial records, using AES-256 encryption.
• One-way cryptographic hashing (bcrypt) for all stored Account passwords. Your password is never stored in plain text.
• Role-based access controls (RBAC) ensuring that internal team members can only access personal data on a strict need-to-know basis relevant to their job function.
• Two-factor authentication (2FA) available to Players for Account login, and mandatory for all internal administrative access to production systems.
• Regular penetration testing and independent security audits conducted by qualified third-party security firms.
• Automated anomaly detection systems that monitor Account activity and flag unusual patterns for review by our security team in real time.

Despite these measures, no data transmission over the internet or data storage system is entirely immune to security risks. sin77 will notify affected Users and relevant authorities in the event of a personal data breach that poses a high risk to their rights and freedoms, in accordance with applicable law and within the required notification timeframe.

10. Cookies & Tracking Technologies

sin77 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session state, support fraud prevention, and gather analytics data. The following categories of cookies are in use:

10.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be disabled. They include session authentication tokens, CSRF protection tokens, and load-balancing cookies. No consent is required for these cookies.

10.2 Functional Cookies

These cookies remember your preferences and settings — such as your preferred language, last-used payment method, and responsible gaming limit configurations — to provide a more personalized experience on return visits.

10.3 Analytics Cookies

sin77 uses analytics tools to understand aggregate player behavior on the Platform — including page views, session duration, feature usage rates, and navigation flows. This data is collected in anonymized or pseudonymized form and is used solely to improve Platform performance and user experience.

10.4 Security & Fraud-Detection Cookies

These cookies collect device fingerprint signals to identify and block fraudulent access attempts, duplicate account registrations, and automated bot activity. They are a key component of sin77's account security framework.

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the availability or functionality of some Platform features. Strictly necessary and security cookies cannot be disabled without impacting your ability to use the Platform.

11. Your Rights Over Your Personal Data

Subject to applicable law and certain legal limitations, you hold the following rights in respect of your personal data held by sin77:

• Right of Access: You may request a copy of the personal data sin77 holds about you, along with information about how it is processed.
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected or updated. For minor corrections (such as updating your email address), you may make changes directly from your Account settings panel.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been processed unlawfully. This right is subject to sin77's legal obligation to retain certain data for regulatory and AML compliance periods.
• Right to Restriction of Processing: You may request that sin77 restrict the processing of your personal data in certain circumstances, such as while a dispute over accuracy is resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that your personal data be provided to you in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests at any time. sin77 will cease such processing unless it can demonstrate compelling legitimate grounds that override your rights. You have an unconditional right to object to processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of any prior processing.

To exercise any of the rights listed above, please contact sin77's support team using the details in Section 15. sin77 will respond to all valid data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further sixty (60) days, with notification to you of the extension and the reasons for it.

12. Protection of Minors

The sin77 Platform is strictly intended for adults aged 21 and over. sin77 does not knowingly collect or process personal data of individuals under the age of 21. If you are under 21 years of age, you are not permitted to register an Account or use the Platform in any capacity.

In the event that sin77 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated Account. If you believe that a minor may have registered an Account on the Platform, please notify us immediately at [email protected].

13. International Data Transfers

sin77's primary operations serve players located in Indonesia, and our principal data storage infrastructure is maintained within secure data centers operating under internationally recognized security standards. In delivering certain Platform services — such as live-game streaming from certified studio facilities, third-party KYC verification, and cloud-based security analytics — your personal data may be transferred to, and processed in, jurisdictions outside Indonesia.

Where such international transfers occur, sin77 ensures that an adequate level of data protection is maintained through one or more of the following mechanisms:

• Standard contractual clauses approved by relevant data protection authorities, incorporated into agreements with recipient third parties.
• Transfers to entities certified under internationally recognized data protection frameworks.
• Your explicit consent, where required and where the above mechanisms are not applicable.

You may request further information about the specific safeguards in place for any particular international transfer by contacting us using the details in Section 15.

14. Policy Amendments

sin77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, the services we offer, applicable law, or regulatory requirements. When material changes are made, sin77 will notify registered Users by displaying a prominent notice on the Platform and, where practicable, by sending a notification to the email address associated with your Account.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. Your continued use of the Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed of any updates.

If you do not agree with any material change to this Privacy Policy, you should cease using the Platform and may close your Account in accordance with the Account closure procedure described in our Terms & Conditions.

15. Contact & Data Requests

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the sin77 support and data team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the chat widget within the Platform. Live chat is the fastest way to reach a sin77 agent.
• Email: [email protected] — for formal data rights requests, please include "Data Rights Request" in the subject line along with your registered Account username.
• Response Time: All privacy-related inquiries are acknowledged within 24 hours (WIB, UTC+7). Formal data rights requests are acted upon within 30 days of identity verification.

When submitting a data rights request, please include your full name as registered on your Account, your registered email address, and a clear description of the right you wish to exercise. sin77 will require identity verification before processing any request that involves the disclosure, modification, or deletion of personal data.