Privacy Policy

1. Introduction

1.1 Our Commitment to Privacy

At leo77, we recognize that privacy is a fundamental right and a critical component of user trust. We are committed to protecting your personal information and being transparent about our data practices. This Privacy Policy explains what information we collect, why we collect it, how we use it, and what choices you have regarding your data.

1.2 Scope of This Policy

This Privacy Policy applies to all users of the leo77 platform, including:

• Visitors who browse our website without registering an account.
• Registered users who create accounts and use our gaming services.
• Mobile app users accessing leo77 services via mobile applications.
• Individuals who contact our customer support or subscribe to promotional communications.

This policy covers the leo77 website (leo77.cam), mobile applications, and all related services. It does not apply to third-party websites or services that may be linked from our platform.

1.3 Controller Information

For the purposes of data protection law, leo77 acts as the data controller responsible for your personal information. We determine how and why your data is processed. Questions about data processing should be directed to our Data Protection Officer at the contact information provided in Section 12 of this policy.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a leo77 account or use our services, you provide personal information directly to us, including:

Account Registration Information:

• Full legal name (as it appears on your Indonesian identification document)
• Date of birth (to verify you meet the 21+ age requirement)
• Email address and mobile phone number
• Residential address in Indonesia
• Username and password (password is encrypted and not accessible to leo77 staff)
• Preferred language and currency settings

Identity Verification (KYC) Information:

• Government-issued identification documents (KTP, passport, or driver's license)
• Proof of address documents (utility bills, bank statements dated within last 3 months)
• Selfie photographs for facial verification (when required for enhanced security)
• Source of funds documentation (for large deposits or unusual transaction patterns)

Financial Information:

• Bank account details for deposits and withdrawals (account holder name, bank name, account number)
• E-wallet account information (OVO, DANA, GoPay account details)
• Transaction history including deposits, withdrawals, bets, and winnings
• Payment method preferences

Communication Information:

• Messages sent through customer support channels (live chat, email, WhatsApp)
• Feedback, survey responses, and reviews
• Marketing preference selections (opt-in/opt-out status)

2.2 Information Collected Automatically

When you access or use leo77 services, we automatically collect certain technical and usage information:

Device and Technical Information:

• IP address and approximate geographic location (city/region level)
• Device type, operating system, browser type and version
• Screen resolution and device settings
• Unique device identifiers and mobile network information
• Time zone settings and language preferences

Usage Information:

• Pages visited, features used, and time spent on the platform
• Games played, bet amounts, and gaming patterns
• Login and logout times, session duration
• Referral sources (how you arrived at leo77)
• Search queries and navigation paths

Cookies and Similar Technologies:

• Session cookies for account authentication and security
• Preference cookies to remember your settings
• Analytics cookies to understand platform usage patterns
• Local storage and cache data for improved performance

See Section 7 for detailed information about cookies and how to manage them.

2.3 Information from Third Parties

In certain circumstances, we may receive information about you from third-party sources:

• Payment Processors: Transaction confirmation, payment method validation, and fraud detection signals from banks and e-wallet providers.
• Identity Verification Services: KYC verification results from third-party identity verification providers.
• Fraud Prevention Services: Fraud risk scores and security alerts from specialized fraud detection platforms.
• Publicly Available Sources: Information from public databases to verify identity or comply with regulatory requirements.

3. How We Use Your Information

3.1 Primary Purposes

leo77 uses your personal information for the following primary purposes:

Account Management and Service Delivery:

• Create and maintain your user account
• Process deposits, withdrawals, and other financial transactions
• Enable you to place bets and participate in games
• Track your account balance, transaction history, and gaming activity
• Manage VIP tier status and loyalty program benefits
• Process bonus claims and enforce wagering requirements

Identity Verification and Security:

• Verify your age (21+ requirement) and identity to prevent underage gambling
• Conduct KYC (Know Your Customer) checks as required by anti-money laundering regulations
• Detect and prevent fraud, cheating, collusion, and unauthorized account access
• Monitor for suspicious activities and protect against security threats
• Enforce our Terms & Conditions and prevent prohibited activities

Customer Support:

• Respond to your inquiries, requests, and complaints
• Troubleshoot technical issues and resolve disputes
• Provide assistance with deposits, withdrawals, and account issues
• Investigate and address responsible gaming concerns

Marketing and Personalization:

• Send promotional offers, bonuses, and tournament announcements (only if you opted in)
• Personalize your gaming experience based on your preferences and activity
• Recommend games and betting markets that may interest you
• Conduct market research and gather feedback to improve our services

Note: You can opt out of marketing communications at any time via your account settings or unsubscribe links in emails.

Legal Compliance and Protection:

• Comply with legal obligations including licensing requirements, tax reporting, and regulatory audits
• Respond to legal requests from courts, law enforcement, or government authorities
• Protect our legal rights, enforce our Terms & Conditions, and defend against legal claims
• Detect, investigate, and prevent illegal activities including money laundering and terrorist financing

3.2 Legal Basis for Processing

Under data protection law, we must have a legal basis to process your personal information. leo77 relies on the following legal bases:

• Contractual Necessity: Processing necessary to perform our contract with you (providing gaming services, processing transactions, account management).
• Legal Obligation: Processing required to comply with laws and regulations (KYC verification, anti-money laundering compliance, tax obligations).
• Legitimate Interests: Processing necessary for our legitimate business interests (fraud prevention, security, platform improvement, analytics) where not overridden by your rights.
• Consent: Processing based on your explicit consent (marketing communications, optional features). You can withdraw consent at any time.

4. Data Sharing and Disclosure

4.1 When We Share Your Information

leo77 does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for specific purposes:

Service Providers and Partners:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) to process your deposits and withdrawals.
• Game Providers: Third-party casino game and live dealer providers to deliver gaming content (they receive only the minimum information needed to operate games).
• Identity Verification Services: KYC verification providers to confirm your identity and age.
• Cloud Hosting Providers: Secure data centers and cloud infrastructure providers where our systems and databases are hosted.
• Customer Support Tools: Live chat and helpdesk software providers to facilitate customer service.
• Analytics Providers: Website analytics tools to understand platform usage and improve user experience.

All service providers are contractually obligated to protect your data, use it only for specified purposes, and comply with applicable privacy laws.

Legal and Regulatory Authorities:

• Indonesian government agencies, tax authorities, and financial intelligence units (when required by law)
• Gaming regulatory bodies and licensing authorities (to maintain our operating license)
• Law enforcement and judicial authorities (in response to valid legal requests, court orders, or subpoenas)
• Anti-fraud and financial crime prevention networks (to report suspicious activities)

Business Transfers:

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email or prominent notice on the platform before your information is transferred and becomes subject to a different privacy policy.

Protection of Rights:

We may disclose your information if necessary to:

• Protect the rights, property, or safety of leo77, our users, or the public
• Detect, prevent, or investigate fraud, security breaches, or illegal activities
• Enforce our Terms & Conditions or other agreements
• Defend against legal claims or litigation

4.2 What We Never Do

• We never sell your personal information to data brokers, advertisers, or marketers
• We never share your information with third parties for their own marketing purposes
• We never publicly disclose your personal information (your identity remains confidential)
• We never share more information than necessary for the specific purpose

5. Data Security Measures

5.1 Technical Security

leo77 employs industry-standard security measures to protect your personal information:

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL (Secure Socket Layer) encryption. Sensitive data is also encrypted at rest in our databases.
• Secure Infrastructure: Our systems are hosted in secure data centers with physical security controls, redundant power supplies, and environmental monitoring.
• Firewalls and Intrusion Detection: Multi-layered firewalls and intrusion detection systems protect against unauthorized access and cyber attacks.
• Access Controls: Strict access controls ensure that only authorized personnel can access personal information, and only for legitimate business purposes.
• Password Protection: Your password is hashed using strong cryptographic algorithms. leo77 staff cannot access your actual password.
• Regular Security Audits: Independent security firms conduct regular penetration testing and vulnerability assessments.

5.2 Organizational Security

• Employee Training: All staff members receive data protection training and are bound by confidentiality obligations.
• Need-to-Know Principle: Access to personal information is restricted based on job role and necessity.
• Incident Response Plan: We maintain a comprehensive data breach response plan to quickly address and mitigate any security incidents.
• Vendor Management: Third-party service providers are carefully vetted and must meet our security standards.

5.3 Your Security Responsibilities

While we implement robust security measures, you also play a role in protecting your account:

• Choose a strong, unique password and change it regularly
• Never share your password with anyone, including individuals claiming to be leo77 staff
• Log out after each session, especially on shared or public devices
• Keep your email and phone number secure, as they are used for account recovery
• Immediately notify us if you suspect unauthorized account access
• Be cautious of phishing emails or fake websites impersonating leo77

5.4 Limitations

No system is completely secure. While we strive to protect your information, we cannot guarantee absolute security. You acknowledge that you provide your personal information at your own risk. In the event of a data breach affecting your information, we will notify you promptly and take appropriate remedial action as required by law.

6. Data Retention and Deletion

6.1 How Long We Keep Your Data

leo77 retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Active Account Data:

• Account information and profile data are retained while your account remains active.
• Transaction history and gaming records are retained for the duration of your account activity plus 7 years for regulatory and legal compliance.

Closed Account Data:

• After account closure, certain information must be retained for legal compliance (typically 5-7 years depending on the data type and jurisdiction).
• This includes identity verification records, financial transactions, and documentation related to anti-money laundering compliance.
• Marketing communication preferences are retained to respect your opt-out choices.

Anonymized Data:

• After retention periods expire, we may anonymize data (remove all identifying information) for statistical analysis and research. Anonymized data cannot be linked back to you and is not considered personal information.

6.2 Right to Deletion

You have the right to request deletion of your personal information, subject to certain legal exceptions. To request deletion:

1. Contact customer support via email, live chat, or WhatsApp.
2. Verify your identity (for security purposes).
3. Specify which data you wish to delete (or request complete account deletion).

We will process your request within 30 days. However, we may retain certain information if required by law (e.g., financial records for tax purposes, KYC documentation for anti-money laundering compliance) or to defend legal claims.

7. Cookies and Tracking Technologies

7.1 What Are Cookies

Cookies are small text files stored on your device when you visit websites. They help websites remember your preferences, authenticate your login, and provide personalized experiences. leo77 uses cookies and similar technologies (web beacons, pixels, local storage) to enhance your user experience and maintain platform functionality.

7.2 Types of Cookies We Use

Essential Cookies (Strictly Necessary):

• Required for core platform functionality (login authentication, session management, security)
• Cannot be disabled as they are necessary for the service to function
• Examples: session cookies, security tokens, load balancing cookies

Functional Cookies:

• Remember your preferences and settings (language, currency, display options)
• Improve user experience by personalizing your interface
• Examples: preference cookies, recently played games, favorite betting markets

Performance and Analytics Cookies:

• Help us understand how visitors use the platform (pages visited, time spent, navigation patterns)
• Identify technical issues and areas for improvement
• Aggregate and anonymize data for statistical analysis
• Examples: Google Analytics, internal analytics tools

7.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to:

• View cookies stored on your device
• Delete existing cookies
• Block all cookies or only third-party cookies
• Receive notifications before cookies are set

Note: Disabling essential cookies will prevent you from using leo77 services, as they are necessary for account authentication and security. Disabling functional or analytics cookies may limit features but will not prevent core service usage.

8. Your Privacy Rights

8.1 Access and Portability

Right to Access: You have the right to request a copy of all personal information we hold about you. We will provide this information in a commonly used electronic format.

Right to Data Portability: You can request that we transfer your personal information to another service provider (where technically feasible).

8.2 Correction and Update

You have the right to correct inaccurate or incomplete personal information. You can update most information directly through your account settings. For information you cannot change yourself, contact customer support.

8.3 Deletion and Erasure

You have the right to request deletion of your personal information (see Section 6.2). We will honor deletion requests unless we have a legal obligation to retain the data.

8.4 Objection and Restriction

Right to Object: You can object to processing of your personal information for certain purposes (e.g., marketing, profiling). We will stop processing unless we have compelling legitimate grounds.

Right to Restrict Processing: You can request that we limit how we use your data while we investigate a complaint or verify accuracy.

8.5 Withdraw Consent

Where we process your data based on consent (e.g., marketing emails), you can withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

8.6 How to Exercise Your Rights

To exercise any privacy rights:

1. Contact customer support via email ([email protected]), live chat, or WhatsApp
2. Clearly state which right you wish to exercise and what action you want us to take
3. Provide proof of identity (for security purposes)
4. We will respond within 30 days

9. Children's Privacy

9.1 Age Restriction

leo77 services are strictly for individuals aged 21 years or older. We do not knowingly collect personal information from anyone under the age of 21. Online gambling by minors is illegal and against our Terms & Conditions.

9.2 Parental Notice

If you are a parent or guardian and believe your child under 21 has provided personal information to leo77, please contact us immediately at [email protected]. We will promptly delete the account and all associated information.

9.3 Age Verification

We implement age verification procedures including:

• Date of birth verification during registration
• Government-issued ID verification (KYC process)
• Ongoing monitoring for suspicious underage activity

10. International Data Transfers

10.1 Data Storage Location

While leo77 primarily serves Indonesian users, your personal information may be transferred to and stored on servers located outside of Indonesia. This may include data centers in Singapore, Hong Kong, or other jurisdictions where our hosting providers operate secure facilities.

10.2 Safeguards for International Transfers

When transferring data internationally, we ensure appropriate safeguards are in place:

• All international data transfers comply with applicable data protection laws
• We use secure data centers with equivalent or superior security standards
• Contractual agreements require recipients to protect your data in accordance with this Privacy Policy
• Data is encrypted during transit and at rest

11. Changes to This Policy

11.1 Policy Updates

leo77 may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting the updated policy on this page with a new "Last Updated" date
• Sending an email notification to your registered email address
• Displaying a prominent notice on the platform homepage

11.2 Your Acceptance

Your continued use of leo77 services after changes become effective constitutes your acceptance of the updated Privacy Policy. If you do not agree with changes, you should discontinue using the platform and request account closure.

11.3 Review Policy Regularly

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. The "Last Updated" date at the top of this page indicates when the policy was last revised.

12. Contact Information

12.1 Privacy Questions and Requests

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how your data is handled, please contact us:

• Email: [email protected] (for privacy-specific inquiries)
• Customer Support Email: [email protected]
• Live Chat: Available 24/7 via your account dashboard
• WhatsApp: +62 812 3456 7890

12.2 Data Protection Officer

For formal privacy complaints or data protection concerns, you may contact our Data Protection Officer directly at [email protected]. We will acknowledge your inquiry within 5 business days and provide a substantive response within 30 days.

12.3 Complaints to Authorities

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.