thr77 Privacy Policy

thr77 ("we", "us", "our") operates the online betting and gaming platform accessible at thr77.bio (the "Platform"). We are committed to protecting the privacy and personal data of every individual who visits, registers with, or uses our Services. This Privacy Policy has been prepared in accordance with internationally recognised data protection principles and is intended to give you a clear, honest account of our data practices.

This Privacy Policy applies to all personal data collected by thr77 through the Platform, including data collected during account registration, identity verification (KYC), financial transactions, gameplay, customer support interactions, and marketing communications. It should be read alongside our Terms & Conditions, which govern your use of the Platform as a whole.

By registering an account on thr77 or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any aspect of this Policy, you should not register an account or continue to use the Platform.

For the purposes of this Privacy Policy, thr77 acts as the data controller in respect of personal data collected from Members and visitors to the Platform. As data controller, thr77 is responsible for determining the purposes and means by which your personal data is processed.

All enquiries relating to the processing of your personal data, including requests to exercise your rights under applicable data protection law, should be directed to our Data Privacy team at [email protected]. We aim to respond to all substantive privacy enquiries within ten (10) business days.

thr77 collects personal data across several categories, depending on how you interact with the Platform. The categories of personal data we collect include, but are not limited to, the following:

We do not intentionally collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless specifically required for responsible gaming assessments or legal compliance purposes and with your explicit consent.

thr77 collects personal data through the following primary channels:

• Direct interactions: Data you provide when completing the account registration form, submitting KYC documents, making a deposit or withdrawal request, contacting customer support, or responding to a promotional survey.
• Automated technologies: Technical and usage data collected automatically as you navigate the Platform, through cookies, web beacons, server logs, and similar tracking technologies. See Section 9 (Cookies & Tracking) for full details.
• Third-party sources: We may receive data about you from identity verification service providers, fraud detection agencies, payment processors (including Indonesian banks and e-wallet operators such as OVO, DANA, GoPay, and ShopeePay), and publicly available sources, where we have a legitimate interest or legal obligation to do so.
• Referral partners: If you arrive at the thr77 Platform via an affiliate or referral partner, we may receive limited data from that partner relating to the referral, such as a campaign identifier or click reference.

thr77 only processes your personal data where we have a valid lawful basis to do so. The table below sets out the primary purposes for which we use your data and the corresponding lawful basis for each:

Where we rely on legitimate interests as our lawful basis, we have assessed that our interests are not overridden by your fundamental rights and freedoms, taking into account the nature of the data and the reasonable expectations of Members on a platform of this type.

Where we rely on consent as our lawful basis — most notably for marketing communications — you have the right to withdraw that consent at any time without detriment to your Account status. To opt out of marketing communications, update your preferences from within your Account dashboard or contact us at [email protected].

thr77 does not sell your personal data to third parties. We do not share your data with external organisations for their independent marketing purposes. We may, however, disclose your personal data to the following categories of recipients where strictly necessary for the purposes described in Section 5:

• Identity verification and KYC providers: Third-party services that assist thr77 in verifying the authenticity of identity documents, detecting document fraud, and confirming the accuracy of Member-provided information.
• Payment processors and financial institutions: Indonesian banks (including BCA, BRI, BNI, Bank Mandiri, CIMB Niaga, OCBC NISP, BSI, and Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) to whom data must be transmitted to process deposit and withdrawal requests.
• Game and technology providers: Licensed game studios and platform software providers, such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft, who may process limited usage data in connection with game delivery and integrity monitoring.
• Fraud detection and security services: Specialist providers that help thr77 identify suspicious activity, detect account takeovers, and prevent financial crime.
• Customer support platforms: Third-party helpdesk and live-chat software providers who process support communications on our behalf under strict data processing agreements.
• Analytics and performance monitoring tools: Service providers that help thr77 understand how Members use the Platform, identify technical issues, and improve overall service quality. Such providers access only aggregated or pseudonymised data where possible.
• Legal and regulatory authorities: Law enforcement agencies, regulatory bodies, courts, or other public authorities where thr77 is required to disclose data by applicable law, lawful court order, or in connection with the investigation of suspected criminal activity including money laundering and fraud.
• Successors in business: In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of thr77's assets, your personal data may be transferred to the relevant successor entity, subject to equivalent privacy protections.

thr77 operates as an internationally regulated online platform, and some of our service providers and technology partners are located outside of Indonesia. As a result, your personal data may be transferred to and processed in countries other than Indonesia, including countries whose data protection laws may differ from those applicable in your jurisdiction.

Where such international transfers occur, thr77 takes all reasonable steps to ensure that your personal data receives an equivalent level of protection as it would in Indonesia. Safeguards we employ include:

• Entering into contractual data transfer clauses with recipients that impose data protection obligations equivalent to internationally recognised standards.
• Transferring data only to recipients in jurisdictions that maintain adequate data protection frameworks as recognised by internationally accepted standards.
• Applying technical safeguards including encryption in transit and at rest, access controls, and pseudonymisation where feasible.

If you have questions about the specific safeguards applied to any particular international data transfer, please contact us at [email protected].

thr77 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required to comply with applicable legal and regulatory obligations. Our standard retention periods are as follows:

At the end of the applicable retention period, thr77 will securely delete, destroy, or irreversibly anonymise your personal data. Where data must be retained beyond the standard period to comply with a specific legal obligation or to defend against a legal claim, we will retain only the minimum data necessary for that specific purpose and will isolate it from active processing systems.

thr77 uses cookies and similar tracking technologies to operate and improve the Platform, to maintain your session state after login, and to understand how Members interact with our Services. The categories of cookies we use are as follows:

• Strictly necessary cookies: Required for the Platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. They cannot be disabled without breaking core Platform functionality.
• Functional cookies: Used to remember your preferences (such as language settings, preferred payment method, and display options) so that we can provide a more personalised experience on your return.
• Analytics cookies: Used to collect aggregated, pseudonymised information about how visitors use the Platform — such as which pages are most frequently visited and where technical errors occur — enabling us to improve performance and usability.
• Marketing and retargeting cookies: Used, where you have consented, to deliver promotional content relevant to your interests both on and off the thr77 Platform, and to measure the effectiveness of marketing campaigns.

Most web browsers allow you to control cookies through their settings. You can instruct your browser to refuse all cookies or to alert you when cookies are being sent. However, disabling strictly necessary cookies will impair your ability to use the Platform. For full information on managing cookies, please refer to your browser's help documentation.

As a data subject, you have a number of rights in respect of the personal data thr77 holds about you. These rights are described below. To exercise any of these rights, please contact us at [email protected] with sufficient information to verify your identity and to specify the right you wish to exercise.

• Right of access: You have the right to request a copy of the personal data thr77 holds about you, along with information about how it is used and with whom it has been shared.
• Right to rectification: You have the right to request correction of any personal data we hold about you that is inaccurate, incomplete, or out of date.
• Right to erasure: In certain circumstances, you have the right to request deletion of your personal data. This right is subject to thr77's legal obligations — for example, we may be required to retain transaction and KYC records for regulatory purposes.
• Right to restriction of processing: You may request that thr77 restrict the processing of your personal data in certain circumstances, for example while the accuracy of the data is contested or while an objection to processing is being assessed.
• Right to data portability: Where processing is based on your consent or on performance of a contract, you may request that we provide your personal data in a structured, commonly used, and machine-readable format.
• Right to object: You have the right to object to processing of your personal data carried out on the basis of thr77's legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

thr77 will respond to all valid rights requests within thirty (30) days of receipt. In complex or high-volume circumstances, we may extend this period by a further two months, in which case we will notify you of the extension and the reasons for it. We will not charge a fee for exercising your rights unless requests are manifestly unfounded or excessive.

thr77 takes the security of your personal data seriously. We have implemented a range of technical and organisational security measures designed to protect your data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption in transit: All data transmitted between your device and the thr77 Platform is encrypted using 256-bit Transport Layer Security (TLS/SSL). The Platform enforces HTTPS across all pages.
• Encryption at rest: Sensitive personal data, including identity document images and financial data, is encrypted when stored on thr77 servers.
• Access controls: Access to personal data within thr77 is restricted on a strict need-to-know basis. Internal systems enforce role-based access controls, and all data access events are logged and audited.
• Two-factor authentication (2FA): Members may enable 2FA on their Accounts for enhanced login security. thr77 staff accessing internal systems are required to use 2FA.
• Penetration testing and vulnerability management: thr77 conducts regular security assessments, including third-party penetration testing, to identify and remediate potential vulnerabilities.
• Real-time fraud monitoring: Our systems continuously monitor transaction and login activity for anomalous patterns indicative of account takeover, payment fraud, or other security incidents.

Notwithstanding these measures, no internet-based system can guarantee absolute security. thr77 cannot warrant that unauthorised third parties will never be able to defeat our security measures. In the event of a data breach that is likely to result in a risk to your rights and freedoms, thr77 will notify affected Members without undue delay and will take all reasonable steps to mitigate the impact of the breach.

thr77 employs age-verification checks as part of the account registration process. If we discover or have reason to believe that a registered Member is under the age of 21, we will immediately suspend the Account, delete the associated personal data (other than data we are legally required to retain for fraud or compliance purposes), and return any deposited funds subject to verification. We encourage parents and guardians to make use of parental control software and Internet filtering tools to prevent minors from accessing gambling-related content online.

The thr77 Platform may from time to time contain links to third-party websites or services — for example, links to game studios, payment provider portals, or responsible gambling organisations. These third-party sites are operated independently of thr77 and have their own privacy policies and data practices, for which thr77 accepts no responsibility.

We encourage you to review the privacy policy of any third-party site you visit before providing any personal data to that site. The inclusion of a link to a third-party site on the thr77 Platform does not constitute an endorsement of that site or its privacy practices.

thr77 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will notify registered Members by email and/or by displaying a prominent notice on the Platform for a reasonable period prior to the changes taking effect. The "Last Updated" date at the top of this page will always reflect the date of the most recent version.

Your continued use of the thr77 Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with the revised Policy, you should cease using the Platform and may request Account closure by contacting [email protected]. We encourage you to review this page periodically to stay informed of our current data practices.

If you have any questions, concerns, or requests regarding this Privacy Policy or thr77's data practices, please contact our Data Privacy team through any of the following channels:

• Email: [email protected] (response target: within 4 hours for general queries, within 10 business days for formal data rights requests, WIB UTC+7)
• Live Chat: Available 24/7 via the live chat widget on the thr77 Platform, including support from Indonesian-speaking agents during Indonesian public holidays such as Idul Fitri, Idul Adha, and Indonesian Independence Day (17 August).

When contacting us with a data rights request, please include your registered username, the email address associated with your Account, and a clear description of the right you wish to exercise or the matter you wish to raise. This will help us process your request efficiently and securely.