Privacy Policy

This Privacy Policy applies to all services offered by sni77 at https://sni77.pro and governs the collection, processing, storage, and disclosure of personal data submitted by or collected from users resident in Indonesia and other jurisdictions where the platform is accessible. By registering an account or otherwise using sni77, you acknowledge that you have read and understood this Privacy Policy and that you consent to the processing of your personal data as described herein. This Policy is incorporated by reference into the sni77 Terms & Conditions.

1 Introduction

sni77 ("we", "us", "our") is the operator of the online gaming platform accessible at https://sni77.pro. We are committed to handling the personal data of our Members with transparency, integrity, and respect. This Privacy Policy has been drafted to meet internationally recognised standards of data protection practice, including principles drawn from the General Data Protection Regulation (GDPR) and the Indonesian Government Regulation on Personal Data Protection (PP No. 71 of 2019 and subsequent legislation).

We collect only the personal data that is necessary to deliver our services safely, securely, and in compliance with applicable anti-money laundering and responsible gaming requirements. We do not sell personal data to third parties for commercial marketing purposes. We do not engage in automated decision-making that produces legal effects on Members without human review.

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us at the email address provided in Section 16 of this document.

2 Definitions

• "Personal Data" — Any information that relates to an identified or identifiable natural person, including but not limited to names, identification numbers, location data, email addresses, financial account details, and device identifiers.
• "Processing" — Any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" — sni77, the entity that determines the purposes and means by which Personal Data is processed.
• "Data Processor" — A third-party entity that processes Personal Data on behalf of sni77 under a contractual arrangement and in accordance with sni77's documented instructions.
• "Member" — Any natural person who has registered a verified account on the sni77 platform.
• "KYC" — Know Your Customer; the identity and age verification process applied to all sni77 Members.
• "Cookies" — Small text files placed on a Member's device by the sni77 platform for session management, preference storage, and analytics purposes.
• "Sensitive Data" — A subset of Personal Data that warrants heightened protection, including national identity card numbers, passport numbers, biometric data, and financial account credentials.

3 Data We Collect

sni77 collects personal data in the following categories:

3.1 Identity Data

Identity data is collected during the registration and KYC verification process and is required to confirm that each Member meets sni77's eligibility requirements, including the minimum age of 21 years.

3.2 Contact Data

Contact data is used to communicate account notifications, security alerts, promotional offers (where opted in), and responses to support enquiries.

3.3 Financial Data

Financial data is collected to process deposits and withdrawals via Indonesian payment rails (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, LinkAja), to comply with anti-money laundering obligations, and to generate Member account statements.

3.4 Technical Data

Technical data is collected automatically when you access sni77 and is used for security monitoring, fraud prevention, and platform performance optimisation.

3.5 Behavioural & Gaming Data

Behavioural data allows sni77 to tailor the gaming experience to each Member, to identify patterns that may indicate problem gambling, and to fulfil our responsible gaming obligations.

3.6 Communications Data

Records of all communications between you and sni77 — including live chat transcripts, email correspondence, and submitted feedback forms — are retained for quality assurance, dispute resolution, and regulatory compliance purposes.

4 How We Collect Your Data

sni77 collects personal data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated collection: Technical and behavioural data collected automatically via cookies, server logs, and analytics tools when you navigate the sni77 platform.
• Third-party sources: Identity verification data from licensed KYC and anti-fraud service providers; transaction confirmation data from Indonesian banks and e-wallet operators; fraud risk signals from industry-standard screening services.
• Device sensors: Where you access sni77 via a mobile browser, device-level data such as operating system version, screen resolution, and network type may be collected to ensure optimal platform rendering and to flag anomalous access patterns.

5 Legal Basis for Processing

sni77 processes personal data under the following legal bases:

Where sni77 relies on consent as the legal basis for any processing activity, you have the right to withdraw that consent at any time by contacting our support team or adjusting your account notification settings. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

6 How We Use Your Data

sni77 uses the personal data it collects for the following specific purposes:

6.1 Service Delivery

To create and maintain your sni77 account; to verify your identity and age; to process financial transactions in IDR via your nominated Indonesian bank account or e-wallet; to deliver game results and account statements; and to provide 24/7 customer support in both English and Indonesian.

6.2 Security and Fraud Prevention

To monitor login activity for signs of unauthorised access; to screen transactions against anti-money laundering watchlists; to detect and investigate bonus abuse, multi-accounting, and other conduct prohibited under the sni77 Terms & Conditions; and to share confirmed fraud intelligence with licensed industry partners where permitted by applicable law.

6.3 Responsible Gaming

To monitor wagering patterns for indicators of excessive or potentially harmful gambling behaviour; to enforce deposit limits, cooling-off periods, and self-exclusion requests made by Members; and to contact Members where our monitoring systems identify a possible problem gambling pattern that warrants outreach.

6.4 Legal and Regulatory Compliance

To satisfy record-keeping obligations under applicable anti-money laundering regulations; to respond to lawful requests from competent authorities; to enforce sni77's contractual rights in the event of a dispute; and to retain evidence of Member consent and contractual agreements.

6.5 Platform Improvement

To analyse aggregated, anonymised usage data to improve the sni77 platform's performance, navigation, and game library; and to evaluate the uptake and effectiveness of promotional campaigns.

6.6 Marketing Communications

To send you information about promotions, bonuses, and new features that may be relevant to your gaming preferences — but only where you have explicitly opted in to receive such communications. You may opt out of marketing emails at any time by clicking the unsubscribe link in any marketing message or by contacting sni77 support.

7 Data Sharing & Disclosure

sni77 does not sell, rent, or trade personal data to any third party for that party's own commercial purposes. Personal data may be disclosed to the following categories of recipient solely to the extent necessary to fulfil the purposes described in this Policy:

7.1 Payment Processors

Licensed Indonesian banks (including BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, and Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum financial and identity data required to authorise, process, and record deposit and withdrawal transactions.

7.2 Identity Verification Providers

sni77 uses licensed KYC and document verification service providers to automate the initial review of identity documents submitted by Members. These providers process identity data strictly under the terms of a data processing agreement with sni77 and are prohibited from using the data for any other purpose.

7.3 Anti-Fraud and Compliance Services

sni77 shares relevant transaction and identity data with licensed anti-money laundering screening services and fraud prevention networks as required to fulfil its compliance obligations. These services act as Data Processors operating under sni77's instruction.

7.4 Game Software Providers

Third-party game studios — including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Pocket Games Soft, and Spribe — may receive a Member's session token and anonymised game-play data necessary to deliver real-time game content. These providers do not receive Members' full identity or financial data unless required for the specific purpose of resolving a game dispute.

7.5 Legal and Regulatory Authorities

sni77 will disclose personal data to competent governmental or regulatory authorities when required to do so by a lawful order, subpoena, or equivalent legal instrument. sni77 will, where legally permissible, notify the affected Member of any such disclosure request prior to compliance.

7.6 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of sni77's assets, Member personal data may be transferred to the successor entity as part of that transaction. Members will be notified via their registered email address of any such transfer and of any changes to this Privacy Policy that result from it.

8 International Data Transfers

sni77's primary data processing infrastructure is located in server facilities that meet internationally recognised security standards (ISO/IEC 27001 or equivalent). Some of sni77's Data Processors — particularly game software providers and fraud screening services — operate infrastructure in jurisdictions outside Indonesia. Where personal data is transferred to a jurisdiction that does not offer a level of data protection equivalent to that applicable in Indonesia, sni77 ensures that appropriate contractual safeguards are in place, including standard contractual clauses based on internationally recognised models, to protect the rights of Members whose data is transferred.

By using the sni77 platform, you acknowledge that your personal data may be processed in jurisdictions outside your country of residence and that the data protection laws of those jurisdictions may differ from those of Indonesia.

9 Cookies & Tracking Technologies

sni77 uses the following categories of cookies and similar tracking technologies on its platform:

sni77 does not use third-party advertising cookies or cross-site tracking technologies for the purpose of serving behavioural advertising to Members on external websites. You may manage your cookie preferences for non-essential cookies through your browser settings at any time; however, disabling strictly necessary or fraud prevention cookies may impair your ability to use the sni77 platform.

10 Data Retention

sni77 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

After the applicable retention period expires, personal data is securely deleted or irreversibly anonymised. Anonymous, aggregated data (from which no individual can be identified) may be retained indefinitely for statistical and business intelligence purposes.

11 Data Security

sni77 employs a layered security architecture to protect Member personal data against unauthorised access, accidental loss, destruction, or alteration. Our technical and organisational security measures include:

• Transport Encryption: All data transmitted between Members' devices and the sni77 platform is encrypted using TLS 1.3 with 256-bit AES cipher suites. Our SSL certificate is renewed automatically and monitored continuously.
• Data-at-Rest Encryption: Sensitive Member data stored in sni77's databases is encrypted at rest using AES-256. Database access is restricted to authenticated application services operating under the principle of least privilege.
• Access Controls: Administrative access to systems containing Member data is restricted to authorised personnel, requires multi-factor authentication, and is logged for audit purposes. Access rights are reviewed quarterly.
• Penetration Testing: sni77's platform undergoes regular independent security assessments and penetration testing to identify and remediate vulnerabilities proactively.
• Incident Response: sni77 maintains a documented data breach response procedure. In the event of a personal data breach that is likely to result in a risk to Members' rights, sni77 will notify affected Members and relevant authorities within 72 hours of becoming aware of the breach, in accordance with applicable data protection law.
• Staff Training: All sni77 personnel with access to personal data receive regular data protection and information security training.

12 Your Data Rights

As a sni77 Member, you hold the following rights in relation to your personal data. To exercise any of these rights, please submit a written request to our support email address provided in Section 16. sni77 will acknowledge all rights requests within 5 business days (WIB) and will provide a substantive response within 30 calendar days.

• Right of Access: You may request a copy of all personal data that sni77 holds about you, along with information about how it is being processed.
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected. For identity data, corrections may require supporting documentation.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been processed unlawfully. This right is subject to sni77's legal retention obligations; data that must be retained under AML regulation cannot be erased on request.
• Right to Restriction: You may request that processing of your personal data be restricted in certain circumstances, such as while a rectification request is under review.
• Right to Data Portability: You may request that personal data you have provided to sni77 be delivered to you (or transferred directly to another controller) in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling for responsible gaming purposes. sni77 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw consent at any time without affecting the lawfulness of prior processing.

sni77 will not charge a fee for exercising your data rights unless a request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

13 Minors

The sni77 platform is strictly intended for adults aged 21 years and older. sni77 does not knowingly collect personal data from any person under the age of 21. If sni77 discovers or has reasonable grounds to believe that an account has been registered by or on behalf of a minor, that account will be immediately suspended, all associated data will be reviewed, and the matter will be escalated to sni77's compliance team for investigation and potential referral to the relevant authorities.

Parents and guardians are encouraged to use parental control software and to maintain open conversations with young people about the risks of online gambling. If you believe that a minor has accessed the sni77 platform using your payment details or device, please contact sni77 support immediately so that the relevant account can be suspended and the funds can be reviewed.

14 Third-Party Links & Embedded Content

The sni77 platform may contain links to third-party game providers' content portals or to publicly accessible regulatory information pages. sni77 does not operate these third-party resources and is not responsible for their privacy practices. This Privacy Policy applies only to personal data processed by sni77 in connection with the sni77 platform. We encourage you to review the privacy policy of any third-party resource you choose to visit.

Certain game content on sni77 is delivered via embedded technology from licensed game studios (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Pocket Games Soft, Spribe). These studios may process limited technical data (such as your session token and device information) as necessary to render game content in real time. This processing is governed by data processing agreements between sni77 and each studio, under which the studios act solely as Data Processors operating on sni77's instructions.

15 Changes to This Privacy Policy

sni77 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the structure of our services. When material changes are made, sni77 will notify active Members by email to their registered address at least 14 calendar days before the revised Policy takes effect. The updated Policy will be published at https://sni77.pro/privacy-policy with a revised effective date.

Your continued use of the sni77 platform after the revised Privacy Policy takes effect constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must cease using the platform and may request Account closure via sni77 support prior to the effective date.

16 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by sni77, please contact our Data Protection team using the details below. All formal data rights requests must be submitted in writing via email. sni77 targets a 5-business-day acknowledgement and a 30-day substantive response for all data rights requests.

• Platform: sni77
• Website: https://sni77.pro
• Privacy & Data Protection Email: support@sni77.pro
• Support Hours: 24 hours a day, 7 days a week (WIB, UTC+7)
• Languages Supported: English and Indonesian

sni77 maintains native Indonesian-speaking support agents available around the clock for Members who prefer to communicate in Indonesian. However, for formal data protection correspondence, English is the governing language and formal responses will be issued in English.