Privacy Policy — viv77

viv77 ("we", "us", "our", "the Platform") operates the online gaming website accessible at https://viv77.app. This Privacy Policy applies to all personal data collected, stored, processed, or otherwise handled by viv77 in connection with the operation of the Platform and the delivery of our Services to registered players located in Indonesia.

This policy covers data collected through all channels through which you interact with viv77, including but not limited to:

• The viv77 website at https://viv77.app and any mobile-optimised version thereof;
• Account registration and KYC verification workflows;
• Deposit, withdrawal, and payment processing interactions;
• Customer support correspondence submitted via email to [email protected];
• Automated data collected through cookies and Platform analytics tools.

This policy does not apply to third-party websites, payment processors, or game studios whose services may be accessible via links or integrations within the Platform. Those third parties operate their own privacy policies, and viv77 is not responsible for their data practices.

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

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, date of birth, address, email address, phone number, bank account details, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means viv77, the entity that determines the purposes and means of processing your Personal Data.
• "Data Subject" / "you" / "your" means any natural person whose Personal Data is processed by viv77, primarily registered Players.
• "KYC" means Know Your Customer — the identity verification process used to confirm a Player's age, identity, and residential status.
• "Services" means all gaming products and account-related features available on the viv77 Platform, including sportsbook betting, live casino, slot gacor (high-payout slot) games, togel (Indonesia's traditional numbers lottery), Domino QQ, and Bingo Online.
• "Third-Party Processor" means any external organisation engaged by viv77 to carry out specific data-processing tasks on our behalf, such as payment gateway providers and fraud detection services.

viv77 collects Personal Data through two primary means: information you provide directly, and information collected automatically when you use the Platform.

3.1 Information You Provide Directly

• Registration data: Full legal name, date of birth, Indonesian residential address, email address, and mobile phone number submitted during account creation.
• Identity verification documents: Copies of your Indonesian National Identity Card (KTP), passport, or driver's licence (SIM) submitted as part of the KYC process.
• Payment information: Bank account numbers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI), and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja) provided for deposits and withdrawals.
• Support correspondence: Any information you include in emails or messages sent to the viv77 support team.
• Responsible gaming preferences: Deposit limits, session time alerts, cool-off periods, and self-exclusion requests you configure within your account.

3.2 Information Collected Automatically

• Technical data: IP address, browser type and version, operating system, device type, screen resolution, and referring URL collected when you visit the Platform.
• Session data: Pages visited, time spent on each page, click patterns, and navigation paths recorded to improve Platform performance and detect suspicious behaviour.
• Transaction logs: A full audit trail of every deposit, withdrawal, bet placement, game round, and account setting change associated with your account.
• Cookie data: Session tokens and preference identifiers stored in your browser as described in Section 8 of this policy.

viv77 uses the Personal Data we collect for the following purposes:

viv77 does not use your Personal Data for automated decision-making that produces legal or similarly significant effects on you, except where explicitly required for fraud prevention or AML compliance. In such cases, you may request human review of any automated decision by contacting [email protected].

viv77 processes your Personal Data only where a valid legal basis exists. The primary legal bases we rely on are:

• Contract performance: Processing is necessary to open and maintain your account, accept and settle bets, process payments, and provide customer support — all of which are obligations viv77 owes you under the Terms & Conditions.
• Legal obligation: Processing is required to comply with applicable anti-money laundering standards, age verification obligations, and any lawful request from a competent authority.
• Legitimate interests: Processing is necessary to pursue viv77's legitimate business interests — including fraud prevention, Platform security, performance analytics, and responsible gaming monitoring — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we rely on consent (for example, to send you optional promotional communications), we will obtain your express agreement beforehand and you may withdraw that consent at any time without affecting the lawfulness of prior processing.

viv77 does not sell, rent, or trade your Personal Data. We share your data only in the following limited circumstances:

6.1 Third-Party Processors

We engage vetted third-party service providers to process data on our behalf under strict contractual obligations. These include:

• Payment processors and banking partners: To facilitate deposits and withdrawals via BCA, BRI, BNI, Mandiri, and supported e-wallets.
• Identity verification providers: To assist with KYC document checks and age verification.
• Fraud detection and cybersecurity firms: To identify and prevent suspicious account activity, bonus abuse, and money laundering.
• Game content providers: Studios such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Pocket Games Soft, and Spribe receive only the data necessary to operate their game sessions (typically an anonymised player identifier and session token).
• Analytics providers: To measure Platform performance and user experience using aggregated, non-identifiable data.

All Third-Party Processors are contractually prohibited from using your data for any purpose other than the specific service they provide to viv77.

6.2 Legal Disclosure

viv77 may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts where we are legally required to do so, or where disclosure is necessary to protect the rights, property, or safety of viv77, its players, or the public. We will notify you of any such disclosure to the extent permitted by law.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of viv77's business assets, your Personal Data may be transferred to the successor entity. You will be notified in advance of any such transfer, and the successor entity will be bound by this Privacy Policy or a materially equivalent one.

All financial transactions on viv77 are conducted in Indonesian Rupiah (IDR). viv77 collects and stores the minimum payment information necessary to process transactions and comply with anti-money laundering obligations.

• Bank account numbers and registered account names for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, and BSI (Bank Syariah Indonesia) are encrypted at rest using AES-256 encryption.
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja are stored in tokenised form and used solely for processing withdrawals and verifying deposit origins.
• viv77 does not store full card numbers (PAN), CVV codes, or card expiry dates. Card-based transactions, if any, are routed through PCI-DSS-compliant payment processors who handle this data directly.
• Payment data is never shared with third parties for marketing purposes under any circumstances.

viv77 uses a limited set of cookies and similar tracking technologies to operate the Platform effectively. We do not use advertising cookies, retargeting pixels, or social media tracking scripts.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Note that disabling essential session cookies will prevent you from logging in to the Platform. Analytics and preference cookies may be disabled without affecting core functionality.

viv77 retains your 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 periods apply as a general guide:

• Account and registration data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, to satisfy anti-money laundering record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Transaction logs: Retained for a minimum of five (5) years from the date of each transaction.
• Support correspondence: Retained for three (3) years from the date of the most recent interaction in the relevant support thread.
• Cookie and session data: Retained in accordance with the cookie durations set out in Section 8.
• Analytics data: Retained in aggregated, non-identifiable form indefinitely for Platform improvement purposes.

At the end of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents reconstruction of the original information.

viv77 implements a layered security architecture designed to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Our key security measures include:

• Transport security: All data in transit is protected by TLS 1.2 or higher (256-bit SSL encryption), ensuring that information exchanged between your device and our servers cannot be intercepted.
• Data at rest encryption: Sensitive stored data — including KYC documents and payment details — is encrypted using AES-256 symmetric encryption.
• Access controls: Personal Data is accessible only to viv77 personnel and authorised processors who have a legitimate operational need. Access is governed by role-based permissions and multi-factor authentication.
• Penetration testing: The Platform undergoes periodic security assessments conducted by independent cybersecurity specialists to identify and remediate vulnerabilities.
• Incident response: viv77 maintains a documented data breach response procedure. In the event of a breach that poses a risk to your rights and freedoms, we will notify affected players without undue delay.

While viv77 takes all reasonable precautions, no system is entirely immune to risk. You are responsible for maintaining the security of your own login credentials and for notifying us immediately at [email protected] if you suspect unauthorised access to your account.

As a Data Subject, you hold the following rights with respect to your Personal Data held by viv77. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request" and your registered account email. We will respond within 30 days of receiving a valid request.

The viv77 Platform is strictly restricted to individuals aged 21 years or older. We do not knowingly collect Personal Data from individuals under the age of 21. Age verification is conducted as part of the KYC process, and accounts where the Player is found to be under 21 are closed immediately, with all associated data deleted or anonymised to the extent permitted by AML obligations.

If you are a parent or guardian and believe that a minor has registered an account or provided Personal Data to viv77 without your knowledge, please contact us immediately at [email protected]. We will investigate and take prompt remedial action, including account closure and data deletion where legally permissible.

viv77 is designed primarily to serve players based in Indonesia. However, some of our Third-Party Processors — including game studios such as Evolution Gaming, Pragmatic Play, and Microgaming, as well as certain technology infrastructure providers — may be located outside Indonesia and may process your data in their respective jurisdictions.

Where Personal Data is transferred internationally, viv77 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Privacy Policy. These safeguards may include:

• Contractual clauses that bind the receiving party to process your data only in accordance with viv77's instructions and this Privacy Policy;
• Transfers to organisations certified under internationally recognised data protection frameworks;
• Transfers to jurisdictions that maintain an adequate level of data protection as assessed by independent regulators.

You may request details of the specific safeguards in place for any given international transfer by contacting [email protected].

viv77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, operational requirements, or applicable law. When we make material changes, we will:

• Update the "Last Updated" date displayed at the top of this page;
• Post a prominent notice on the Platform for a minimum of 14 days following the change taking effect; and
• Where the change materially affects your rights, send a notification to the email address registered to your account.

Your continued use of the Platform after the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. If you disagree with a material change, you may request account closure and withdrawal of your Real Money Balance before the change takes effect by contacting [email protected].

If you have any questions, concerns, or complaints about this Privacy Policy or viv77's handling of your Personal Data, please contact our Data Protection team through the following channel:

• Email: [email protected] — use the subject line "Privacy Enquiry" or "Data Rights Request" for fastest routing.
• Response time: We aim to acknowledge all privacy-related enquiries within 2 business days and provide a substantive response within 30 calendar days.
• Support hours: 24 hours a day, 7 days a week, including Indonesian public holidays, with Indonesian-speaking support agents available (WIB, UTC+7).

If you are not satisfied with viv77's response to a privacy complaint, you may escalate the matter through viv77's formal dispute resolution process as described in our Terms & Conditions. We are committed to resolving all privacy-related concerns fairly and transparently.