Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by sby77 through our website (sby77.cam), mobile applications, customer support channels, and any other digital or offline touchpoints where sby77 collects personal information from users in connection with our online betting, casino gaming, togel (traditional Indonesian lottery), and related services.

sby77 operates as an online betting platform licensed and regulated under international gaming authorities. We serve primarily Indonesian residents aged 21 and above. Our data processing activities comply with applicable international data protection standards and, where applicable, Indonesian data privacy regulations including but not limited to requirements for consent, data minimization, purpose limitation, and security.

As the data controller, sby77 determines the purposes and means of processing your personal data. We take this responsibility seriously and have implemented comprehensive technical and organizational measures to protect your information. If you have questions or concerns about how we handle your data, please contact our Data Protection Officer using the details provided in Section 10 of this policy.

2. Information We Collect

sby77 collects various categories of personal information necessary to provide our services, comply with legal obligations, and improve user experience. The types of data we collect include:

2.1 Account Registration Information

When you create an sby77 account, we collect identification and contact details including your full legal name, date of birth, gender, residential address, email address, mobile phone number, and username. This information is essential to establish your account, verify your identity, and communicate with you about your account activity.

2.2 Identity Verification (KYC) Documents

To comply with anti-money laundering (AML) regulations and age verification requirements, we collect copies of government-issued identification documents such as your Indonesian KTP (identity card) or passport, proof of address documents (utility bills, bank statements, or rental agreements), and in some cases, photographs or selfies for biometric verification. These documents are encrypted and stored securely in compliance with data protection standards.

2.3 Financial and Transaction Data

We collect information about your payment methods including bank account details (bank name, account number, account holder name) for Indonesian banks such as BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, and BSI, as well as e-wallet account identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja. We also maintain comprehensive transaction records including deposit amounts, withdrawal requests, bet history, win/loss records, bonus claims, and account balance changes. Payment card information is processed through PCI-DSS compliant third-party processors and is not directly stored on sby77 servers.

2.4 Gameplay and Betting Activity

To operate our services and detect fraudulent activity, we log all gameplay and betting activity including sports bets placed, casino games played, togel number selections, stake amounts, odds accepted, settlement outcomes, game session durations, and responsible gaming tool usage (deposit limits, time-outs, self-exclusion). This data helps us provide better services, resolve disputes, and identify problem gambling patterns.

2.5 Technical and Device Information

When you access sby77, we automatically collect technical data including IP address, device type and model, operating system, browser type and version, screen resolution, language preferences, time zone settings, referring URLs, pages viewed, clickstream data, and access times. This information is used for security monitoring, fraud prevention, service optimization, and analytics.

2.6 Communications and Support Interactions

We retain records of all communications between you and sby77 including live chat transcripts, email correspondence, phone call recordings (where permitted by law and with notice), support tickets, and feedback submissions. These records help us improve customer service quality, resolve disputes, and comply with regulatory requirements.

2.7 Marketing Preferences and Behavior

With your consent, we collect information about your marketing preferences, promotional email engagement (opens, clicks), SMS response rates, push notification interactions, and website behavioral data to personalize offers and improve marketing effectiveness. You can opt out of marketing communications at any time through your account settings or by contacting support.

3. How We Use Your Information

sby77 processes your personal data only for specified, explicit, and legitimate purposes. We do not process your data in ways incompatible with these purposes without obtaining your additional consent. The primary purposes for which we use your information include:

3.1 Service Provision and Account Management

We use your personal data to create and maintain your sby77 account, process your bets and gaming activity, calculate winnings and losses, manage your account balance, process deposits and withdrawals, provide customer support, and send transactional communications such as deposit confirmations, withdrawal notifications, and important account updates. This processing is necessary to fulfill our contractual obligations to you.

3.2 Compliance and Legal Obligations

sby77 processes your data to comply with legal and regulatory requirements including Know Your Customer (KYC) and age verification, anti-money laundering (AML) monitoring and suspicious activity reporting, tax reporting obligations, response to lawful requests from law enforcement or regulatory authorities, maintenance of legally required records and audit trails, and compliance with gaming license conditions. This processing is necessary to meet our legal obligations.

3.3 Security and Fraud Prevention

We analyze your data to detect and prevent fraudulent activity, identify multiple accounts or bonus abuse, monitor for money laundering or other financial crimes, prevent underage gambling, protect against cyber attacks and unauthorized access, and investigate suspected terms violations. We continuously monitor account activity using automated systems and manual review processes to maintain platform integrity. This processing is based on our legitimate interest in protecting our business and other users.

3.4 Responsible Gaming and Player Protection

sby77 uses your gameplay data and activity patterns to identify potential problem gambling behaviors, enforce deposit limits and session time limits, implement cooling-off periods and self-exclusion requests, provide responsible gaming resources and interventions, and comply with safer gambling regulations. Your wellbeing is a priority and we take proactive steps to promote healthy gambling habits.

3.5 Service Improvement and Analytics

We analyze aggregated and anonymized data to understand user preferences and behavior, improve website and application functionality, optimize user experience and interface design, develop new features and services, conduct market research and trend analysis, and measure service performance and user satisfaction. This processing is based on our legitimate interest in improving our services.

3.6 Marketing and Promotional Communications

With your explicit consent, we use your contact information and activity history to send promotional offers, bonus notifications, and personalized recommendations, inform you about new games and features, invite you to VIP events or tournaments, conduct customer satisfaction surveys, and send newsletters about sby77 updates. You can withdraw consent and opt out of marketing communications at any time without affecting your ability to use sby77 services.

4. Data Sharing and Disclosure

sby77 does not sell your personal data to third parties. However, we may share your information with carefully selected partners and service providers in the following circumstances:

4.1 Service Providers and Processors

We engage third-party service providers to perform functions on our behalf, including payment processors (for deposit and withdrawal transactions with Indonesian banks and e-wallets), identity verification services (for KYC document validation), cloud hosting providers (for secure data storage), customer support platforms (for live chat and ticketing systems), marketing and analytics tools, and security and fraud detection services. All service providers are bound by contractual obligations to protect your data and process it only according to our instructions.

4.2 Game and Content Providers

When you play casino games, slots, or live dealer games, certain gameplay data is shared with the respective game providers (such as live casino studios and slot developers) to facilitate game operation, verify results, and resolve disputes. These providers are bound by strict confidentiality and data protection requirements.

4.3 Legal and Regulatory Authorities

We may disclose your personal information to regulatory bodies, gaming commissions, law enforcement agencies, tax authorities, and courts when legally required to do so, in response to valid legal processes such as subpoenas or court orders, to investigate or prevent illegal activities, to protect sby77's legal rights and interests, or to comply with anti-money laundering reporting obligations. We will make reasonable efforts to notify you of such disclosures unless prohibited by law.

4.4 Business Transfers

In the event that sby77 undergoes a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the acquiring entity as part of the transaction. We will notify you via email and prominent notice on our website before your data is transferred and becomes subject to a different privacy policy.

5. Data Security Measures

sby77 implements industry-leading technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our comprehensive security framework includes:

5.1 Encryption and Network Security

All data transmission between your device and sby77 servers is protected by 256-bit SSL/TLS encryption, the same technology used by banks and financial institutions. Sensitive personal data including passwords, identification documents, and financial information is encrypted at rest using AES-256 encryption. Our network infrastructure includes firewalls, intrusion detection systems, DDoS protection, and 24/7 security monitoring.

5.2 Access Controls and Authentication

Access to personal data is restricted on a need-to-know basis through role-based access controls. Our employees and contractors with access to personal data are bound by confidentiality obligations and receive regular data protection training. We employ multi-factor authentication for administrative access and maintain detailed audit logs of all data access activities.

5.3 Regular Security Audits and Testing

sby77 conducts regular penetration testing, vulnerability assessments, and security audits performed by independent third-party security firms. We maintain incident response procedures and have a dedicated security team monitoring for threats. All identified vulnerabilities are prioritized and remediated according to risk level.

5.4 Physical and Environmental Security

Our data centers employ physical security measures including 24/7 surveillance, biometric access controls, environmental monitoring, redundant power supplies, and fire suppression systems. Data backups are performed regularly and stored in geographically separate locations to ensure business continuity and disaster recovery capabilities.

6. Data Retention and Deletion

sby77 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods vary by data type:

• Account Information: Retained for the duration of your active account plus 7 years after account closure to comply with financial record-keeping and AML regulations.
• Transaction Records: Maintained for 7 years after the transaction date to comply with financial reporting, tax, and audit requirements.
• KYC Documents: Retained for 7 years after account closure or business relationship termination as required by anti-money laundering laws.
• Gameplay History: Stored for 7 years to resolve disputes, detect fraud, and comply with gaming regulations.
• Marketing Communications: Retained until you opt out or withdraw consent, after which your data is removed from marketing lists within 30 days.
• Technical Logs: Typically retained for 12-24 months for security analysis and troubleshooting, then archived or deleted.
• Support Communications: Kept for 3 years after case closure to improve service quality and handle follow-up inquiries.

After retention periods expire, personal data is securely deleted or anonymized such that it can no longer be associated with you. Anonymized data may be retained indefinitely for statistical analysis and service improvement. If you request deletion of your data before the retention period expires, we will delete all data not subject to legal retention requirements.

7. Your Privacy Rights

Under applicable data protection laws, you have specific rights regarding your personal data. sby77 respects these rights and provides mechanisms to exercise them:

7.1 Right to Access

You have the right to obtain confirmation of whether we process your personal data and to request a copy of that data. You can request access by contacting [email protected]. We will provide the requested information within 30 days in a commonly used electronic format.

7.2 Right to Rectification

If your personal data is inaccurate or incomplete, you can update most information directly through your account settings. For data you cannot modify yourself, contact our support team and we will correct verified inaccuracies within 30 days.

7.3 Right to Erasure (Right to Be Forgotten)

You may request deletion of your personal data in certain circumstances, such as when data is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when you object to processing. However, we may retain data necessary to comply with legal obligations, resolve disputes, or enforce our agreements. Account deletion requests can be submitted to [email protected].

7.4 Right to Restrict Processing

You can request that we limit the processing of your personal data while we verify data accuracy, assess the lawfulness of processing, or during dispute resolution. During restriction, we will store but not process your data except with your consent or for legal claims.

7.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller. This applies to data you provided based on consent or contract and that we process by automated means.

7.6 Right to Object

You can object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests or we need the data for legal claims. Marketing objections can be exercised through email unsubscribe links or account settings.

7.7 Right to Withdraw Consent

Where processing is based on consent (such as marketing communications), you can withdraw consent at any time without affecting the lawfulness of processing before withdrawal. Withdrawal does not affect your ability to continue using sby77 services.

7.8 Right to Lodge a Complaint

If you believe sby77 has violated your privacy rights, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. Contact details for your local authority can be found on official government websites.

8. Cookies and Tracking Technologies

sby77 uses cookies, web beacons, and similar tracking technologies to enhance user experience, analyze site usage, and deliver personalized content. Cookies are small text files stored on your device that help us recognize you during subsequent visits.

8.1 Types of Cookies We Use

• Essential Cookies: Required for website operation, account authentication, and security. These cannot be disabled without impairing site functionality.
• Performance Cookies: Collect anonymous information about how visitors use our site, helping us improve performance and user experience.
• Functional Cookies: Remember your preferences (language, region) and provide enhanced features like live chat.
• Targeting/Advertising Cookies: Track your browsing to deliver relevant advertisements and measure campaign effectiveness. These require your consent and can be disabled.

8.2 Managing Cookie Preferences

You can control cookies through your browser settings to accept, reject, or receive notification before cookies are set. Most browsers allow you to delete existing cookies and block future cookies. However, disabling essential cookies may prevent you from accessing certain site features or using your account. For more information about managing cookies, visit your browser's help documentation.

9. International Data Transfers

sby77 primarily serves Indonesian users but operates with international service providers and infrastructure. Your personal data may be transferred to, stored, or processed in jurisdictions outside Indonesia, including countries that may not provide the same level of data protection as Indonesian law.

When transferring data internationally, sby77 implements appropriate safeguards such as standard contractual clauses approved by data protection authorities, adequacy decisions recognizing equivalent protection levels, or explicit consent for specific transfers. We ensure all recipients are bound by equivalent data protection obligations through contracts and compliance requirements.

If you have concerns about international data transfers or want more information about the safeguards we employ, please contact our Data Protection Officer at [email protected].

10. Contact Our Data Protection Officer

sby77 has appointed a Data Protection Officer (DPO) responsible for overseeing our privacy program, ensuring compliance with data protection laws, and serving as your primary contact for privacy-related inquiries, concerns, or requests to exercise your rights.

Data Protection Officer Contact Information:

• Email: [email protected] (monitored daily, response within 48 hours)
• General Support: [email protected] (can forward privacy inquiries to DPO)
• Response Time: We aim to respond to all privacy requests within 30 days, though complex requests may require up to 60 days with notification of the extension.

When contacting our DPO, please include your full name, username, registered email address, detailed description of your request or concern, and any relevant documentation. This helps us verify your identity and respond more efficiently to your inquiry.