99sll Privacy Policy

1. Introduction and Scope

99sll operates an online betting and gaming platform accessible at https://99sll.cam and associated mobile applications (collectively, the "Platform"). This Privacy Policy applies to all personal data collected through the Platform, including during account registration, deposits and withdrawals, gameplay, customer support interactions, and marketing communications.

This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy. By using the 99sll Platform, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein.

99sll respects your right to privacy and is committed to protecting your personal data in accordance with applicable data protection laws and international best practices. We collect only the information necessary to provide our services, maintain account security, comply with legal obligations, and improve the user experience.

2. Data Controller and Contact Information

99sll is the data controller responsible for your personal information collected through the Platform. Our registered business address and data protection contact details are as follows:

• Company Name: 99sll Gaming Platform
• Service Contact Email: support@99sll.cam
• Data Protection Officer Email: privacy@99sll.cam
• Mailing Address: 99sll Data Protection Office, International Gaming District, Online Services Division

If you have any questions, concerns, or requests regarding the processing of your personal data, you may contact our Data Protection Officer at privacy@99sll.cam. We will respond to all privacy inquiries within 10 business days.

3. Information We Collect

99sll collects several categories of personal information to operate the Platform, process transactions, verify your identity, comply with legal requirements, and provide customer support. The information we collect includes:

3.1 Account Registration Information

When you register for a 99sll account, we collect the following mandatory information:

• Full legal name (as it appears on your government-issued identification document)
• Date of birth (to verify you are at least 21 years of age)
• Residential address (street address, city, province, postal code)
• Email address (used for account notifications and communications)
• Mobile phone number (used for two-factor authentication and account security)
• Username and password (chosen by you during registration)
• Preferred currency (Indonesian Rupiah / IDR)

3.2 Identity Verification Documents (KYC)

To comply with anti-money laundering (AML) regulations and prevent fraud, 99sll requires all Players to complete a Know Your Customer (KYC) verification process. During KYC verification, we collect:

• Government-issued photo identification document (Indonesian National Identity Card / KTP, passport, or driver's license), including document number, issue date, expiration date, and photograph
• Proof of residence document (utility bill, bank statement, or government-issued document dated within the last 3 months)
• Selfie photograph holding your identification document (if requested for enhanced verification)

3.3 Financial and Transaction Information

To process deposits and withdrawals, we collect:

• Bank account details (bank name, account holder name, account number) for Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, and Bank Permata
• E-wallet account information (account holder name, phone number or account ID) for OVO, DANA, GoPay, ShopeePay, and LinkAja
• Transaction history (deposits, withdrawals, wagers, winnings, bonuses claimed)
• Payment method preferences

Note: 99sll does not store full credit or debit card numbers, CVV codes, or card PINs. Payment card transactions (where applicable) are processed through PCI-DSS compliant third-party payment processors who handle card data securely on our behalf.

3.4 Gameplay and Platform Usage Data

When you use the 99sll Platform, we automatically collect:

• Game activity logs (games played, bets placed, outcomes, timestamps)
• Login and session data (login times, session duration, IP addresses)
• Device and browser information (device type, operating system, browser type and version, screen resolution, language settings)
• Clickstream data (pages visited, features used, navigation paths within the Platform)
• Geolocation data (approximate location based on IP address to verify you are accessing the Platform from an eligible jurisdiction)

3.5 Communications and Customer Support Records

When you contact 99sll Customer Support or communicate with us, we collect:

• Chat transcripts (live chat and in-app messaging conversations)
• Email correspondence
• WhatsApp messages (if you contact us via WhatsApp)
• Phone call recordings (where permitted by law and with your consent)
• Support ticket history and resolution notes

3.6 Marketing Preferences and Consent Records

We record your marketing communication preferences, including:

• Consent to receive promotional emails, SMS messages, and push notifications
• Marketing opt-out preferences
• Participation in surveys and promotional campaigns

4. How We Use Your Personal Data

99sll uses your personal information for the following purposes:

4.1 Account Management and Service Delivery

• Creating and maintaining your 99sll account
• Verifying your identity and eligibility to use the Platform (age verification, residence verification)
• Processing deposits, withdrawals, and other financial transactions
• Delivering the betting and gaming services you request (placing bets, playing games, tracking results)
• Managing your VIP tier status and calculating loyalty rewards
• Providing customer support and responding to inquiries

4.2 Legal and Regulatory Compliance

• Complying with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Preventing fraud, collusion, money laundering, and other illegal activities
• Detecting and preventing underage gambling
• Maintaining records required by gaming regulators and financial authorities
• Responding to legal requests, court orders, and regulatory inquiries

4.3 Platform Security and Fraud Prevention

• Monitoring account activity for suspicious behavior and unauthorized access
• Enforcing our Terms & Conditions and detecting prohibited activities (multiple accounts, bonus abuse, collusion)
• Implementing two-factor authentication and other security measures
• Conducting security audits and vulnerability assessments

4.4 Service Improvement and Analytics

• Analyzing Platform usage patterns to improve user experience and identify popular features
• Testing new features, games, and betting markets
• Optimizing Platform performance, load times, and mobile responsiveness
• Conducting aggregated statistical analysis and market research (using anonymized data)

4.5 Marketing and Promotional Communications

• Sending promotional offers, bonus announcements, and VIP rewards (only if you have opted in to marketing communications)
• Personalizing promotions based on your gaming preferences and activity (e.g., offering football betting bonuses to users who frequently bet on BRI Liga 1)
• Inviting you to participate in tournaments, competitions, and special events

Note: You can opt out of marketing communications at any time by clicking the "Unsubscribe" link in promotional emails, adjusting your notification preferences in your account settings, or contacting Customer Support. Opting out of marketing communications does not affect transactional messages (deposit confirmations, withdrawal notifications, security alerts), which are necessary for account operation.

5. Legal Basis for Processing

99sll processes your personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions) and deliver the betting and gaming services you request. This includes account registration, transaction processing, and customer support.
• Legal Obligation: Processing is required to comply with legal and regulatory obligations, including KYC/AML requirements, age verification, responsible gaming regulations, and tax reporting.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, service improvement, and operational analytics, provided these interests do not override your fundamental rights and freedoms.
• Consent: Where required by law, we obtain your explicit consent before processing your data for marketing purposes, placing cookies on your device, or collecting optional information.

6. Sharing Your Personal Data

99sll does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality obligations:

6.1 Payment Processors

We share necessary financial information with third-party payment service providers (banks, e-wallet operators, payment gateways) to process your deposits and withdrawals. These providers are contractually obligated to use your data only for transaction processing and to maintain appropriate security measures.

6.2 Identity Verification Services

We may use third-party KYC verification services to validate the authenticity of your identification documents and detect fraudulent submissions. These services have access only to the documents and information necessary for verification purposes.

6.3 Game Providers and Software Partners

When you play casino games, slots, or live dealer games on 99sll, we share your username and gameplay data with the respective game providers (e.g., Evolution Gaming, Pragmatic Play, NetEnt, Microgaming) to deliver the game experience. These providers do not have access to your financial or identity documents.

6.4 Customer Support Tools

We use third-party customer support platforms (live chat software, ticketing systems) to manage support inquiries. Support agents have access to your account information and communication history only to the extent necessary to resolve your inquiry.

6.5 Legal and Regulatory Authorities

We may disclose your personal data to law enforcement agencies, regulatory authorities, tax authorities, or other government bodies when required by law, court order, or regulatory request. We will only disclose the minimum information necessary to fulfill the legal obligation.

6.6 Affiliates and Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy. We will notify you via email and provide an opportunity to opt out if the new entity intends to use your data in a manner materially different from this Privacy Policy.

7. Data Retention Period

99sll retains your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods are as follows:

• Active Accounts: Personal data is retained for the duration of your account's active status plus seven (7) years after account closure to comply with financial record-keeping and AML regulations.
• Transaction Records: Deposit, withdrawal, and gameplay transaction records are retained for a minimum of seven (7) years as required by financial regulations and tax authorities.
• Identity Documents: KYC documents (identification cards, proof of residence, selfie photographs) are retained for seven (7) years after the account relationship ends.
• Customer Support Records: Chat transcripts, emails, and support tickets are retained for three (3) years for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Records of your marketing preferences and consent are retained until you withdraw consent, plus an additional three (3) years to demonstrate compliance with data protection laws.

After the applicable retention period expires, we securely delete or anonymize your personal data. Anonymized data (data that can no longer identify you as an individual) may be retained indefinitely for statistical analysis and research purposes.

8. Security Measures

99sll implements comprehensive technical, administrative, and physical security measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction. Our security controls include:

• Encryption: All data transmitted between your device and 99sll servers is encrypted using 256-bit SSL/TLS encryption. Sensitive data at rest (e.g., identification documents, financial records) is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized personnel on a need-to-know basis. All staff members with data access are bound by confidentiality agreements and receive regular data protection training.
• Two-Factor Authentication: We offer optional two-factor authentication (2FA) for all accounts, adding an extra layer of security beyond username and password.
• Intrusion Detection and Prevention: Our servers are protected by firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) that monitor for suspicious activity 24/7.
• Regular Security Audits: We conduct annual third-party security audits and penetration testing to identify and remediate vulnerabilities.
• Secure Data Centers: Personal data is stored in Tier III or Tier IV data centers with physical security controls including biometric access, CCTV surveillance, and 24/7 on-site security personnel.
• Incident Response Plan: We maintain a comprehensive data breach response plan and will notify affected users within 72 hours of discovering any breach that poses a risk to their rights and freedoms.

While we implement industry-leading security measures, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and should not share your password with anyone.

9. Your Privacy Rights

Under applicable data protection laws, you have the following rights regarding your personal data:

9.1 Right of Access

You have the right to request a copy of the personal data we hold about you. To exercise this right, log in to your 99sll account and navigate to Account Settings > Privacy > Download My Data, or contact our Data Protection Officer at privacy@99sll.cam. We will provide your data in a structured, commonly used, and machine-readable format (e.g., JSON or CSV) within 30 days of your request.

9.2 Right of Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You can update most information directly in your account settings (email address, phone number, residential address). For changes to your legal name or date of birth, contact Customer Support with supporting documentation.

9.3 Right of Erasure ("Right to Be Forgotten")

You may request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or you withdraw consent. However, we may be required to retain certain data to comply with legal obligations (e.g., financial record-keeping requirements, AML regulations) or to establish, exercise, or defend legal claims. Account closure requests can be submitted via Customer Support.

9.4 Right to Restrict Processing

You have the right to request restriction of processing in certain situations, such as when you contest the accuracy of your data or object to processing based on legitimate interests. During the restriction period, we will store your data but not actively process it (except with your consent or for legal claims).

9.5 Right to Data Portability

You have the right to receive your personal data in a portable format and, where technically feasible, request that we transmit your data directly to another service provider. This right applies to data you provided to us based on consent or contract, and that we process by automated means.

9.6 Right to Object

You may object to processing of your personal data based on legitimate interests or for direct marketing purposes. If you object to direct marketing, we will cease processing your data for those purposes immediately. For objections based on legitimate interests, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

9.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw marketing consent by clicking "Unsubscribe" in promotional emails or adjusting your preferences in Account Settings > Notifications.

9.8 Right to Lodge a Complaint

If you believe that 99sll has violated your privacy rights or applicable data protection laws, you have the right to lodge a complaint with a supervisory authority in your jurisdiction. For Indonesian residents, the relevant authority is the Ministry of Communication and Informatics of the Republic of Indonesia. You may also contact our Data Protection Officer at privacy@99sll.cam to resolve the issue directly.

10. Cookies and Tracking Technologies

99sll uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. A cookie is a small text file stored on your device when you visit a website. We use the following types of cookies:

10.1 Essential Cookies

These cookies are necessary for the Platform to function and cannot be disabled. They enable core functionality such as user authentication, session management, and secure access to member-only areas. Essential cookies do not collect personal information beyond what is necessary for these functions.

10.2 Performance and Analytics Cookies

We use analytics cookies to collect aggregated data on how users interact with the Platform (pages visited, time spent, navigation paths, error messages). This information helps us identify areas for improvement and optimize Platform performance. We may use third-party analytics services such as Google Analytics for this purpose. Analytics data is anonymized and does not identify you personally.

10.3 Functionality Cookies

These cookies remember your preferences and settings (language preference, theme selection, favorite games) to provide a more personalized experience. Functionality cookies enhance convenience but are not essential for basic Platform operation.

10.4 Marketing and Advertising Cookies

With your consent, we use marketing cookies to deliver relevant promotional content and track the effectiveness of advertising campaigns. These cookies may track your activity across different websites to build a profile of your interests. You can opt out of marketing cookies through your browser settings or our cookie consent banner.

10.5 Managing Your Cookie Preferences

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, although doing so may affect Platform functionality (e.g., you may need to log in more frequently or re-enter preferences). To adjust cookie settings, refer to your browser's help documentation:

• Google Chrome: Settings > Privacy and Security > Cookies and other site data
• Mozilla Firefox: Options > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Manage Website Data
• Microsoft Edge: Settings > Cookies and site permissions > Cookies and site data

For more information about cookies and how to control them, visit www.allaboutcookies.org or www.youronlinechoices.com.

11. Changes to This Privacy Policy

99sll reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. When we make material changes, we will notify you via email to your registered email address and display a prominent notice on the Platform homepage for at least 30 days.

The "Last Updated" date at the top of this document indicates when the current version of the Privacy Policy became effective. Your continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us:

• Data Protection Officer Email: privacy@99sll.cam
• General Customer Support Email: support@99sll.cam
• Live Chat: Available 24/7 via the 99sll Platform (click the chat icon in the bottom-right corner)
• WhatsApp: +62 811 9900 9955 (available 08:00–22:00 WIB daily)
• Mailing Address: 99sll Data Protection Office, International Gaming District, Online Services Division

We will respond to all privacy inquiries within 10 business days. For urgent security matters (e.g., suspected account breach, unauthorized access), please contact Customer Support immediately via live chat or email.

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Document History:
Version 2.4 published January 15, 2026. Previous version 2.3 dated October 5, 2025. Material changes in this version: expanded cookie policy section to include detailed opt-out instructions; clarified data retention periods for KYC documents; updated list of payment methods to reflect new e-wallet integrations (Bank Permata, BSI).

By continuing to use the 99sll Platform after January 15, 2026, you acknowledge that you have read and understood this updated Privacy Policy. Thank you for trusting 99sll with your personal information — your privacy and security are our highest priorities.