Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how sl77, the operator of the online betting platform accessible at https://sl77.cam ("Platform"), collects, processes, stores and protects the personal data of its users. sl77 operates in compliance with applicable international data protection principles and is committed to handling your personal information with transparency and care.

This Policy applies to all personal data collected through the Platform, including data submitted during registration, account use, payment transactions, customer support interactions and any other engagement with our services. It applies to all users of the Platform who are residents of Indonesia or who access the Platform while located in Indonesian territory.

By registering an account on sl77 or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform and contact us to request account closure.

This Policy should be read in conjunction with our Terms and Conditions and our Responsible Gaming Policy, both of which form part of the overall legal framework governing your use of sl77.

2. Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, address, email, phone number, financial information and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means sl77, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of sl77 under our instruction and pursuant to a data processing agreement.
• "User", "You" or "Your" refers to any individual who creates an account or uses the Platform.
• "Cookies" means small text files placed on your device by the Platform to enable certain functionality and to collect usage data.

3. Data We Collect

sl77 collects Personal Data across three broad categories: data you provide directly, data generated automatically through your use of the Platform, and data received from third parties.

3.1 Data You Provide Directly

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, nationality, gender, KTP (Indonesian National Identity Card) number	Account creation, KYC verification, age restriction compliance (21+)
Contact Data	Email address, Indonesian mobile phone number, city and province of residence (e.g., Jakarta, Surabaya, Bandung, Bali)	Account communication, two-factor authentication, support correspondence
Verification Documents	Photographs of government-issued ID, selfie with ID, proof of address (utility bill, bank statement)	KYC compliance, anti-money-laundering obligations, fraud prevention
Financial Data	Bank account name and number (BCA, BRI, BNI, Mandiri), e-wallet account reference (OVO, DANA, GoPay), transaction history	Payment processing, withdrawal verification, fraud detection
Correspondence Data	Support chat transcripts, email messages, feedback submissions	Customer service delivery, quality assurance, dispute resolution

3.2 Automatically Collected Data

• Technical Data: IP address, browser type and version, operating system, device type, screen resolution and unique device identifiers.
• Usage Data: Pages visited, features used, bet placement timestamps, session duration, game history and navigation paths through the Platform.
• Location Data: General geographic location derived from IP address (city and country level). We do not collect precise GPS location data.
• Cookie Data: Session tokens, preference settings, authentication state and analytics identifiers. See Section 8 for full cookie details.

3.3 Data from Third Parties

• Payment Providers: Transaction confirmation references and fraud-screening scores from local bank payment gateways and e-wallet providers.
• Identity Verification Services: Confirmation results from third-party KYC and document verification platforms.
• Fraud Prevention Services: Risk scores and device fingerprint assessments from anti-fraud technology partners.

4. How We Collect Your Data

sl77 collects your Personal Data through the following channels:

• Registration Form: When you create an account on the Platform, you submit identity, contact and preference data directly.
• KYC Submission: When you complete identity verification, you upload document images and selfies through our secure verification portal.
• Deposit and Withdrawal Forms: When you submit payment transactions, financial data is captured and passed to our payment processing partners.
• Platform Activity: As you navigate the Platform, place wagers and use game features, usage and technical data are collected automatically via server logs and analytics tools.
• Customer Support: When you contact our support team via live chat or email, the content of those communications is recorded.
• Cookies and Tracking Technologies: When you visit the Platform, cookies and similar technologies collect technical and usage data from your browser or device.

5. Legal Basis for Processing

sl77 processes your Personal Data on the following legal grounds:

• Contractual Necessity: Processing is necessary to deliver the services set out in our Terms and Conditions — including account management, bet settlement and payment processing.
• Legal Obligation: Processing is required to comply with applicable anti-money-laundering (AML) regulations, Know Your Customer (KYC) requirements and financial reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security monitoring, platform improvement and responsible gaming enforcement — provided those interests are not overridden by your rights.
• Consent: Where we send marketing communications or set non-essential cookies, we rely on your consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

sl77 uses your Personal Data for the following specific purposes:

• Creating, verifying and managing your account, including enforcing the 21+ age restriction applicable to all users.
• Processing deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay and other payment methods available on the Platform.
• Verifying your identity in accordance with our KYC obligations and detecting, investigating and preventing fraud, money laundering and other financial crimes.
• Settling bets and wagers, resolving disputes, and providing accurate transaction history within your account.
• Delivering customer support, responding to your queries and resolving complaints.
• Sending essential service communications, such as account security alerts, policy update notices and transaction confirmations. These communications are not optional as they relate directly to the operation of your account.
• Sending promotional communications, bonus offers and personalized content — but only where you have consented to receive such communications or where we have a legitimate interest in doing so.
• Enforcing our responsible gaming controls, including monitoring for patterns of play that may indicate problem gambling and applying account restrictions where appropriate.
• Improving Platform performance, fixing technical issues and conducting internal analytics to enhance the user experience.

7. Sharing Your Personal Data

sl77 does not sell your Personal Data. We share data only in the following circumstances and only to the extent strictly necessary:

7.1 Service Providers and Data Processors

We engage carefully selected third-party Data Processors who provide services essential to operating the Platform. These include:

• Payment Processors: Local bank gateways (for BCA, BRI, BNI, Mandiri transfers) and e-wallet providers (OVO, DANA, GoPay) receive the payment reference data necessary to complete transactions.
• KYC and Identity Verification Providers: Third-party verification platforms receive copies of identity documents and process them according to our instruction and applicable data protection standards.
• Cloud Infrastructure Providers: Our Platform is hosted on secure, internationally recognized cloud infrastructure. Data stored on these se rvers is subject to contractual data protection obligations equivalent to those described in this Policy.
• Fraud Prevention Services: Anti-fraud and risk-scoring providers receive limited technical data (IP address, device fingerprint) to assess transaction risk in real time.
• Customer Support Platforms: Our live chat and ticketing infrastructure providers process support correspondence data on our behalf.

All Data Processors are bound by written data processing agreements that prohibit them from using your data for any purpose beyond the specific service they provide to sl77.

7.2 Legal and Regulatory Disclosure

sl77 may disclose your Personal Data to competent authorities, regulators or law enforcement agencies where we are required to do so by law, court order or binding regulatory directive. We will notify you of any such disclosure where we are legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of sl77's business, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and ensure that the receiving entity is bound by privacy obligations no less protective than those in this Policy before any transfer takes place.

8. Cookies and Tracking Technologies

sl77 uses cookies and similar tracking technologies to operate the Platform, enhance your experience and analyze usage patterns. The following categories of cookies are in use:

Cookie Type	Purpose	Can You Opt Out?
Strictly Necessary	Maintain your login session, remember your account preferences, enable secure payment flows and support core Platform functionality.	No — these are essential to the Platform's operation.
Performance & Analytics	Collect aggregated, anonymized data on page views, session duration, feature usage and error rates to help us improve the Platform.	Yes — via your browser cookie settings.
Functional	Remember your display language preference, odds format and other personalization settings across sessions.	Yes — disabling these may affect your experience.
Security	Detect and prevent fraudulent login attempts, bot activity and other security threats by analyzing session behavior patterns.	No — these are necessary for account and Platform security.

You can manage cookie preferences through your browser settings at any time. Please note that disabling strictly necessary or security cookies may prevent you from accessing certain features of the Platform or from logging in to your account.

sl77 does not use advertising cookies or place third-party tracking pixels that report your behavior to external advertising networks.

9. Data Retention

sl77 retains your Personal Data for no longer than is necessary for the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in accordance with anti-money-laundering record-keeping requirements.
• Transaction and Financial Data: Retained for a minimum of five (5) years from the date of each transaction, consistent with financial compliance obligations.
• KYC Documentation: Retained for a minimum of five (5) years after the completion of the business relationship, or longer if required by a regulatory authority.
• Support Correspondence: Retained for three (3) years from the date of the interaction, to support dispute resolution and quality assurance purposes.
• Technical and Usage Data: Typically retained for thirteen (13) months on a rolling basis, then aggregated or deleted.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance with consent-based processing obligations.

When Personal Data is no longer required, sl77 will securely delete or anonymize it so that it can no longer be associated with you as an individual.

10. Data Security

sl77 implements a comprehensive range of technical and organizational security measures to protect your Personal Data against unauthorized access, loss, destruction or alteration. These measures include:

• 256-bit SSL/TLS Encryption: All data in transit between your device and our servers is encrypted using industry-standard TLS protocols.
• Encryption at Rest: Sensitive Personal Data stored on our servers, including identity documents and financial records, is encrypted at the storage layer.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. Staff members who handle your data are bound by confidentiality obligations and receive regular data protection training.
• Two-Factor Authentication (2FA): Your account is protected by optional 2FA. We strongly recommend enabling this feature for maximum security.
• Regular Security Audits: Our infrastructure undergoes periodic penetration testing and vulnerability assessments by qualified independent security professionals.
• Incident Response Plan: sl77 maintains a documented data breach response plan. In the event of a confirmed breach that poses a risk to your rights, we will notify affected users without undue delay.

11. Your Data Protection Rights

As a user of the sl77 Platform, you have the following rights with respect to your Personal Data. To exercise any of these rights, please contact us using the details in Section 15.

• Right of Access: You may request a copy of the Personal Data sl77 holds about you, along with information about how it is being processed.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.
• Right to Erasure: You may request that sl77 delete your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations (see Section 9).
• Right to Restriction of Processing: You may request that we temporarily restrict the processing of your Personal Data while a dispute about its accuracy or the lawfulness of its use is being resolved.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, you may request that we provide your Personal Data in a structured, commonly used machine-readable format.
• Right to Object: You may object at any time to the processing of your Personal Data where that processing is based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights.
• 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 that occurred before the withdrawal.

sl77 will respond to all verified data rights requests within 30 calendar days of receipt. We may request additional information to verify your identity before processing a request. In complex cases, we may extend the response period by a further 30 days, in which case we will notify you of the extension and the reason for it.

12. Children's Privacy and the 21+ Restriction

The sl77 Platform is strictly intended for adults aged 21 years and over. We do not knowingly collect or process Personal Data from any person under the age of 21. Registration is prohibited for minors, and all accounts are subject to age verification as part of our KYC process.

If sl77 becomes aware that Personal Data has been collected from a person 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. If you believe that we may have inadvertently collected data from a minor, please contact us immediately at [email protected].

Parents and guardians who are concerned about underage access to online gambling platforms are encouraged to use parental control software and to visit our Responsible Gaming page for further guidance and resources.

13. International Data Transfers

sl77 operates internationally and may transfer your Personal Data to servers or service providers located outside Indonesia. Where such transfers occur, sl77 ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to the protections described in this Policy. These safeguards may include:

• Contractual clauses in data processing agreements with international service providers that impose data protection obligations consistent with applicable standards.
• Transfers only to jurisdictions that provide an adequate level of data protection as recognized by applicable data protection authorities.
• Technical security measures (encryption, access controls) applied to all data regardless of the jurisdiction in which it is stored or processed.

By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in jurisdictions outside Indonesia. We will always handle such transfers in a manner consistent with this Policy and with due regard for your privacy rights.

14. Updates to This Privacy Policy

sl77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations or the services we offer. All updates will be published on this page with a revised "Last Updated" date prominently displayed at the top of the Policy.

Where changes are material — for example, where we introduce a new purpose for processing your data or a new category of data sharing — we will notify you directly via the email address registered to your account prior to the changes taking effect. Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how sl77 protects your Personal Data.

15. Contact Information

If you have any questions, concerns or requests relating to this Privacy Policy or to the way sl77 processes your Personal Data, please contact our privacy team using the details below:

• Email: [email protected]
• Subject Line: "Privacy Policy Inquiry" or "Data Rights Request"
• Response Time: We aim to acknowledge all privacy inquiries within 2 business days and to provide a full response within 30 calendar days.
• Support Hours: Our customer support team is available 24/7 (WIB, UTC+7).

We are committed to working with you to resolve any privacy-related concerns promptly and fairly. If you remain dissatisfied with our response, you may escalate the matter to the relevant data protection authority in your jurisdiction.