Privacy Policy — polo77 Data Protection

This Privacy Policy applies to all personal data collected, processed, and stored by polo77 in connection with the operation of our online entertainment platform at https://polo77.cam. It covers all Users who access our website, register an account, use our gaming Services, contact our support team, or interact with polo77 through any associated communication channel.

polo77 acts as the Data Controller with respect to the personal information you provide directly to us. Where we engage third-party service providers to process data on our behalf — such as payment processors or KYC verification services — those parties act as Data Processors under binding contractual data protection obligations consistent with this Policy.

By registering an account on polo77 or continuing to use our Services after any revision to this Policy, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein. This Policy should be read alongside our Terms & Conditions, which govern your use of the polo77 platform more broadly.

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or can be used to identify a living individual, directly or indirectly, including by reference to a name, identification number, location data, or online identifier.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, storage, use, disclosure, or erasure.
• "Data Controller" means polo77, the entity that determines the purposes and means of processing personal data.
• "Data Processor" means a third party that processes personal data on behalf of polo77 pursuant to a written agreement.
• "User" or "You" means any person who accesses the polo77 platform, whether as a registered member or an unregistered visitor.
• "Services" means the full suite of online gaming, sports betting, live dealer, and related products offered via polo77.
• "KYC" means Know Your Customer — the identity verification procedure mandated by our licensing and anti-money-laundering obligations.
• "Cookies" means small text files placed on your device by a website to store session and preference information, as further described in Section 11.

polo77 collects personal data in two broad categories: data you provide voluntarily, and data we collect automatically through your use of the Platform. The specific categories are as follows:

Data You Provide Directly:

• Registration Data: Full legal name, date of birth, email address, mobile phone number, and residential address.
• KYC Verification Documents: Government-issued photo ID (e.g., Indonesian KTP or passport), proof of address (utility bill or bank statement dated within 90 days), and, where applicable, selfie photographs for facial-verification matching.
• Payment Information: Bank account details (for local Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, and BSI), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction reference numbers. polo77 does not store full card numbers or banking passwords.
• Support Communications: The content of any messages, emails, or live chat transcripts you initiate with our customer support team.
• Preference & Feedback Data: Game preferences, promotional opt-in status, and any survey or feedback responses you voluntarily submit.

Data We Collect Automatically:

• Device & Technical Data: IP address, browser type and version, operating system, device model, screen resolution, and time zone.
• Usage & Behavioral Data: Pages visited, games played, bet amounts and outcomes, session duration, click-paths, and feature interactions.
• Geolocation Data: Approximate location derived from IP address (city/region level) for compliance and fraud-prevention purposes.
• Cookie & Tracking Data: Session identifiers, analytics tokens, and preference cookies, as described in Section 11.

Personal data reaches polo77 through the following channels:

• Direct Input: When you complete the account registration form, submit KYC documents, initiate a deposit or withdrawal, contact customer support, or fill in any Platform form.
• Automated Technologies: Through cookies, web beacons, and server-side logging as you navigate the polo77 platform. See Section 11 for full details.
• Third-Party Verification Services: Our licensed KYC and anti-money-laundering partners may return additional identity data to us as part of the document verification workflow.
• Payment Providers: Loca l banks and e-wallet providers may share transaction metadata (reference numbers, timestamps, amounts) with polo77 to reconcile deposits and withdrawals.
• Affiliate & Marketing Partners: If you arrive at polo77 via a tracked affiliate link, the referring partner may share a click identifier with us solely for the purpose of crediting the referral. No additional personal data is received from affiliates beyond a session token.

polo77 processes your personal data only for the specific, legitimate purposes set out below. We do not process data in ways incompatible with these stated purposes.

Where we process your data for marketing purposes, we do so only with your explicit opt-in consent, and you may withdraw that consent at any time by updating your communication preferences in your account settings or by contacting support at [email protected].

polo77 processes personal data under one or more of the following legal bases:

• Contractual Necessity: Processing is required to fulfill our contractual obligations to you under the Terms & Conditions — for example, creating your account, processing transactions, and delivering gaming Services.
• Legal Obligation: Processing is necessary to comply with applicable laws and regulatory requirements, including anti-money-laundering legislation, KYC mandates imposed by our international gaming license, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for polo77's legitimate business interests — including fraud detection, platform security, and analytics — where those interests are not overridden by your fundamental rights and freedoms.
• Consent: For optional processing activities such as marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

polo77 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We share your data only in the following limited and controlled circumstances:

• Payment Processors: Local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum data necessary to process your transactions securely.
• KYC & Compliance Providers: Licensed third-party identity verification services receive copies of your KYC documents to perform document authentication and sanctions-screening checks. These providers are contractually bound to use your data solely for verification purposes.
• Game Studio Providers: Studios such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft receive a pseudonymous player identifier and session token to facilitate game delivery. They do not receive your full name, payment details, or government ID.
• Analytics & Technology Providers: We use trusted third-party analytics platforms to monitor platform performance and user experience. Data shared with these providers is aggregated or pseudonymized where technically feasible.
• Legal & Regulatory Authorities: Where required by law, court order, or regulatory authority — including any relevant authority in the jurisdiction of our gaming license — we may disclose personal data without prior notice to you.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of polo77's business assets, personal data may be transferred to the acquiring entity as part of the transaction, subject to equivalent privacy protections.

polo77 operates as an international gaming platform, and some of our service providers and infrastructure partners are located outside Indonesia. As a result, your personal data may be transferred to, stored in, or processed in countries other than Indonesia — including the jurisdiction in which polo77 holds its gaming license.

When we transfer personal data internationally, we apply appropriate safeguards to ensure your data continues to receive a standard of protection consistent with this Privacy Policy. These safeguards may include:

• Contractual clauses that impose equivalent data protection obligations on the recipient;
• Transfers to jurisdictions recognized as providing an adequate level of data protection by the relevant regulatory authority;
• Binding corporate rules applicable within our group of affiliated entities.

By using polo77 and accepting this Privacy Policy, you acknowledge that your personal data may be processed in jurisdictions outside Indonesia, and you consent to such transfers subject to the safeguards described above.

polo77 retains personal data for no longer than is necessary to fulfill the purposes for which it was collected, or as required by applicable legal, regulatory, and licensing obligations. The following general retention periods apply:

When retention periods expire, personal data is securely deleted or irreversibly anonymized so that it can no longer be linked back to any individual.

polo77 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, loss, alteration, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your browser or device and the polo77 platform is encrypted using industry-standard TLS protocols, protecting it from interception during transit.
• Encryption at Rest: Sensitive data fields — including payment information and KYC document files — are encrypted in our databases using AES-256 encryption.
• Access Controls: Internal access to personal data is restricted on a strict need-to-know basis. Staff members are granted the minimum level of access necessary to perform their duties, and all access is logged and audited.
• Two-Factor Authentication (2FA): We support two-factor authentication for Player account logins and enforce it for all internal staff accessing production systems.
• Penetration Testing: polo77 undergoes periodic third-party security assessments and penetration tests to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a personal data breach that poses a risk to your rights and freedoms, polo77 will notify affected Users and relevant authorities within the timeframes required by applicable data protection law.

polo77 uses cookies and similar tracking technologies to operate core platform functions, analyze usage patterns, and — with your consent — deliver relevant promotional content. The categories of cookies we use are as follows:

You may manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies; however, disabling strictly necessary cookies may impair the functionality of your polo77 account. Withdrawing consent for optional cookies does not affect your ability to use core platform features.

As a polo77 member, you hold the following rights with respect to your personal data. To exercise any of these rights, contact our Data Protection team at [email protected] with the subject line "Privacy Rights Request." We will respond within 30 days.

• Right of Access: You may request a copy of all personal data we hold about you, along with information about how it is processed.
• Right to Rectification: If any personal data we hold is inaccurate or incomplete, you have the right to request that it be corrected without undue delay.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to overriding retention obligations under applicable law and our licensing requirements.
• Right to Restriction of Processing: You may request that we limit the processing of your data in certain circumstances — for example, while a dispute over its accuracy is pending.
• Right to Data Portability: You may request a structured, machine-readable copy of the personal data you have provided to us directly, for the purpose of transferring it to another service provider.
• Right to Object: You may object at any time to processing based on legitimate interests, including profiling for marketing purposes. We will cease that processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based solely on your consent (e.g., marketing communications), you may withdraw that consent at any time through your account settings or by contacting us directly.

polo77 strictly prohibits access by anyone under the age of 21. Our platform is designed exclusively for adults, and we do not knowingly collect personal data from individuals below this age threshold. We enforce this restriction through mandatory date-of-birth declaration at registration and through KYC age-verification checks on all accounts.

If polo77 discovers or is notified that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and permanently close the associated account. Any funds deposited by a minor will be handled in accordance with our Terms & Conditions and applicable regulatory guidance.

If you are a parent or guardian and believe that your child has registered on polo77 without your knowledge, please contact us immediately at [email protected] so that we can investigate and act promptly.

polo77 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the structure of our Services. When material changes are made, we will notify registered Users via email to the address on file, or through a prominent notice on the Platform, no fewer than 14 days before the changes take effect.

The "Last Updated" date at the top of this page always reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how we protect your data. Your continued use of polo77 after the effective date of a revised Policy constitutes your acceptance of the changes.

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by polo77, please reach out to our Data Protection team through the following channels:

• Email: [email protected] — please use the subject line "Privacy Inquiry" for fastest routing.
• Live Chat: Available 24/7 via the polo77 platform interface, with Indonesian-speaking agents available around the clock.
• Response Commitment: All privacy-related inquiries are acknowledged within 24 hours and fully responded to within 30 calendar days of receipt.

For issues specifically related to responsible gaming and account self-management tools, please visit our Responsible Gaming page. For general platform rules and eligibility questions, refer to our Terms & Conditions.