Privacy Policy

1. Introduction

99sl03 ("we", "us", "our", "the Company", "the Platform") is committed to protecting the personal data and privacy of every individual who uses our services. This Privacy Policy ("Policy") describes how 99sl03 collects, processes, stores, uses, and discloses personal information when you access or use the 99sl03 website, mobile platform, or any associated services (collectively, the "Service").

This Policy applies to all registered members, prospective members who have initiated but not completed registration, and visitors to the Platform. By creating an Account or continuing to use the Service, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy, both of which form part of our complete regulatory framework for member protection.

2. Definitions

For the purposes of this Privacy Policy, the following terms are defined as follows:

• "Personal Data" means any information that identifies or could reasonably identify an individual, including name, email address, phone number, date of birth, national identity number, and financial information.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• "Data Controller" means 99sl03, the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of 99sl03 under a contractual agreement.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the Member's agreement to the processing of their Personal Data.
• "Cookies" means small data files stored on your device by your browser when you visit the Platform.
• "KYC" means Know Your Customer — the identity verification process used to confirm a member's identity and eligibility.

3. Personal Data We Collect

3.1 Registration Data

When you create an Account with 99sl03, we collect the following information:

• Full legal name (as it appears on your government-issued identification)
• Date of birth (to verify you are at least 21 years of age)
• Email address
• Mobile phone number (including Indonesian country code +62)
• Residential address (including city — Jakarta, Surabaya, Bandung, Medan, Bali, or other)
• Username and encrypted password
• Preferred currency (IDR)

3.2 KYC Verification Data

As part of our identity verification process, we may collect:

• Copies of government-issued photo identification (Indonesian National ID / KTP, passport, or driver's license)
• Proof of residential address (utility bill, bank statement, or government correspondence)
• Selfie or facial verification image (used for liveness detection)
• Bank account details or e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Payment method documentation (bank statements from BCA, BRI, BNI, Mandiri, or other supported banks)

3.3 Transaction & Financial Data

We collect and retain records of all financial transactions processed through the Platform, including:

• Deposit amounts, dates, and payment methods used
• Withdrawal requests, amounts, processing times, and destination account details
• Betting history, game session records, and wagering amounts
• Bonus claims, wagering progress, and promotional interactions
• Account balance history

3.4 Technical & Usage Data

When you access the Platform, we automatically collect:

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Pages visited, session duration, and navigation paths
• Referring website or source of visit
• Login timestamps and session identifiers
• Performance data and error logs

3.5 Customer Support Data

When you contact our customer support team via live chat, WhatsApp, or email, we retain records of the interaction including the content of messages, resolution status, and timestamps. This data is used to improve service quality and resolve disputes.

4. How We Collect Your Data

99sl03 collects personal data through the following methods:

• Direct Submission: Information you provide during registration, KYC verification, deposit/withdrawal requests, and customer support interactions.
• Automated Collection: Technical data collected automatically through cookies, session tracking, and server logs when you use the Platform.
• Third-Party Sources: Identity verification data returned by our KYC service providers; fraud detection signals from our payment processing partners.
• Payment Processors: Transaction confirmations and payment status updates from BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja, and other integrated payment providers.

5. How We Use Your Personal Data

99sl03 uses your personal data for the following purposes:

Purpose	Data Used	Legal Basis
Account creation and management	Registration data, KYC data	Contract performance
Identity verification (KYC)	KYC documents, facial data	Legal obligation
Processing deposits and withdrawals	Financial data, payment details	Contract performance
Fraud detection and prevention	Technical data, transaction data	Legitimate interest
Regulatory compliance and AML	All personal data categories	Legal obligation
Customer support	Support interaction data	Contract performance
Responsible gaming monitoring	Betting history, session data	Legitimate interest / legal obligation
Platform performance and analytics	Technical and usage data	Legitimate interest
Promotional communications (opt-in)	Email, phone number	Consent

6. Legal Basis for Processing

99sl03 processes your personal data only where a valid legal basis exists. The primary legal bases we rely upon are:

• Contract Performance: Processing necessary to provide the services you have requested, including Account management, deposits, withdrawals, and game access.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, KYC obligations, and responsible gaming mandates.
• Legitimate Interest: Processing for fraud prevention, platform security, analytics, and improving service quality — where our interests are balanced against your privacy rights.
• Consent: Processing for optional communications and marketing, where you have given explicit and freely withdrawable consent.

7. Data Sharing & Third-Party Disclosure

7.1 Service Providers

We share personal data with carefully selected third-party service providers who process data on our behalf under strict contractual data processing agreements. These providers include:

• KYC and identity verification providers
• Payment processors and gateway operators (for IDR transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, and others)
• Game software providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) — limited to session data required to operate games
• Customer support platform operators
• Fraud detection and cybersecurity services
• Cloud infrastructure providers for secure data hosting

7.2 Legal & Regulatory Disclosure

We may disclose personal data to government authorities, regulators, or law enforcement agencies when required by law, court order, or regulatory directive. We will always seek to notify you of such disclosures unless prohibited by law from doing so.

7.3 No Sale of Personal Data

99sl03 does not sell, rent, lease, or otherwise transfer your personal data to any third party for commercial marketing purposes. Any data shared with third parties is strictly limited to what is necessary to provide the Service and is governed by binding data processing agreements.

8. Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files stored on your device when you visit the Platform. They help us recognize your browser, remember your preferences, maintain your session, and analyze how the Platform is used. We also use similar technologies such as web beacons, pixel tags, and local storage.

8.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. They cannot be disabled.
• Functional Cookies: Remember your language preferences, display settings, and last-visited game categories to improve your experience.
• Analytics Cookies: Collect anonymized data about how members navigate the Platform — pages visited, time spent, and interaction patterns — to help us improve the Service.
• Security Cookies: Used to detect fraudulent login attempts, unusual activity patterns, and suspicious geographic anomalies.

8.3 Managing Cookies

You may control cookie behavior through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies will impair your ability to log in and use the Service. Blocking analytics cookies will not affect your ability to play or transact.

9. Data Retention

99sl03 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our standard retention periods are:

• Account Data: Retained for the duration of your Account plus 5 years after closure, to comply with anti-money laundering and fraud prevention regulations.
• KYC Documentation: Retained for a minimum of 5 years from the date of verification, as required by financial crime compliance obligations.
• Transaction Records: Retained for 5 years from the date of each transaction.
• Customer Support Records: Retained for 2 years from the date of the last interaction.
• Technical / Usage Logs: Retained for 90 days in active logs; anonymized aggregates may be retained indefinitely for analytics purposes.
• Marketing Consent Records: Retained for the duration of your consent plus 2 years as evidence of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be attributed to an identifiable individual.

10. Data Security

99sl03 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, or disclosure. Our security framework includes:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records
• Multi-factor authentication (MFA) for all internal staff accessing member data systems
• Role-based access controls limiting internal data access on a strict need-to-know basis
• Regular third-party penetration testing and vulnerability assessments
• 24/7 intrusion detection and real-time security monitoring
• Segregated network architecture with firewalls protecting member data environments
• Annual security audits conducted by independent cybersecurity firms

Despite these measures, no digital platform can guarantee absolute security. In the event of a data breach that poses a significant risk to your rights or freedoms, we will notify affected members and relevant authorities within the timeframes required by applicable law.

11. Your Privacy Rights

As a member of 99sl03, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our Data Protection team at the address listed in Section 14.

• Right of Access: You may request a copy of the personal data we hold about you and information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restrict Processing: You may request that we limit the processing of your personal data in certain circumstances, such as while a dispute is being resolved.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request a copy of your data in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interest, including profiling for marketing purposes.
• 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 prior to withdrawal.

We will respond to all valid requests within 30 days of receipt. In complex cases, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reason for it.

12. Minors & Age Restrictions

The 99sl03 Service is strictly intended for adults aged 21 years or older. We do not knowingly collect personal data from individuals under the age of 21. If you are under 21, you are not permitted to register an Account or use the Service.

If we become aware that we have collected personal data from a person under the age of 21 without verified parental consent, we will take immediate steps to delete that data and close the associated Account. If you believe a minor has registered on our platform, please contact us immediately at [email protected].

Parents and guardians are encouraged to use parental control tools and monitoring software to prevent minors from accessing gambling platforms. For more information on responsible gaming safeguards, please visit our Responsible Gaming page.

13. Changes to This Privacy Policy

99sl03 reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will notify registered members via email and display a prominent notice on the Platform for at least 14 days before the changes take effect.

The date of the most recent revision is displayed at the top of this Policy. We encourage you to review this Policy periodically. Your continued use of the Service after the effective date of any changes constitutes your acceptance of the revised Policy.

14. Contact Information

If you have any questions, concerns, or requests relating to this Privacy Policy or our data processing practices, please contact us through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 directly on the Platform
• Response Time: We aim to respond to all privacy-related inquiries within 5 business days

For formal data rights requests (access, erasure, portability), please use the subject line "Data Rights Request" and include your registered email address so we can verify your identity before proceeding.