Privacy Policy — owl77 Data Protection & Privacy

owl77 ("we," "us," "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, store, and disclose your personal data when you access or use the owl77 platform at https://owl77.cam, including all associated services and features.

By registering an account, accessing the platform, or using any owl77 service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with any part of this Privacy Policy, you must not use the owl77 platform.

This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy, which are incorporated herein by reference.

For the purposes of applicable data protection legislation, owl77 is the data controller responsible for your personal information. We determine the purposes and means of processing your personal data in connection with the operation of the platform.

If you have any questions or concerns about how your personal data is processed, or if you wish to exercise your privacy rights, please contact us using the contact details provided in Section 15 of this Privacy Policy.

owl77 collects personal information from you directly when you register an account, use the platform, or communicate with our support team. We also collect certain data automatically through your use of the platform. The categories of personal data we collect include:

3.1 Information You Provide Directly

• Registration Data: When you create an account, we collect your full legal name, date of birth, gender, email address, residential address, and phone number.
• Identity Verification (KYC) Data: To comply with regulatory requirements, we collect copies of identity documents (Indonesian National Identity Card / KTP), proof of address, selfie photographs, and any other documentation necessary to verify your identity.
• Financial Data: We collect information about your deposits and withdrawals, including payment method details (bank account numbers for BCA, BRI, BNI, Mandiri; e-wallet account identifiers for OVO, DANA, GoPay, ShopeePay), transaction amounts, and transaction history.
• Communications Data: When you contact customer support via live chat or email, we collect the content of your communications, including any attachments you send.

3.2 Information Collected Automatically

• Technical Data: We automatically collect your IP address, browser type and version, device type and operating system, time zone setting, browser plug-in types and versions, and platform usage data.
• Usage Data: We collect information about how you use the platform, including pages visited, time spent on pages, bet placement data (types of bets, stake amounts, game selections), session duration, and click-through patterns.
• Location Data: We collect your approximate geographic location based on your IP address to verify compliance with jurisdictional restrictions and to customize content.

owl77 processes your personal data for the following purposes:

• Account Management: To create and maintain your account, authenticate your identity, and provide you with access to the platform's features and services.
• Transaction Processing: To process deposits and withdrawals, maintain accurate financial records, and reconcile your account balance.
• Regulatory Compliance: To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, verify your age (21+ requirement), and fulfill our legal and regulatory obligations under applicable gaming laws.
• Fraud Prevention & Security: To detect and prevent fraudulent activity, unauthorized access, money laundering, bonus abuse, and other forms of platform misuse.
• Customer Support: To respond to your inquiries, resolve technical issues, investigate disputes, and provide assistance with account-related matters.
• Platform Improvement: To analyze usage patterns, conduct research, test new features, and improve the performance, security, and user experience of the owl77 platform.
• Marketing & Communications: To send you promotional offers, bonus notifications, platform updates, and other marketing communications, subject to your consent where required by law.
• Responsible Gaming: To monitor betting patterns for signs of problem gambling, enforce deposit limits and self-exclusion requests, and fulfill our responsible gaming obligations.

We process your personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions) and to provide the services you have requested.
• Legal Obligation: Processing is necessary to comply with legal obligations to which owl77 is subject, including KYC, AML, age verification, and regulatory reporting requirements.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security, platform improvement, and marketing (provided these interests are not overridden by your data protection rights).
• Consent: Where required by law, we process your data based on your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing prior to withdrawal.

owl77 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality obligations:

• Payment Service Providers: We share transactional data with banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals.
• KYC & Verification Partners: We share identity documents with third-party KYC service providers who assist in verifying your identity and performing AML checks.
• Technology & Service Providers: We share data with cloud hosting providers, data analytics services, customer support platforms, and IT security firms who provide infrastructure and operational support for the platform.
• Regulatory Authorities: We disclose data to gaming regulators, law enforcement agencies, tax authorities, and other government bodies when legally required or requested in connection with an investigation.
• Legal & Compliance Advisors: We may share data with legal counsel, auditors, and compliance consultants for professional advice and audit purposes.
• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections.

All third-party service providers are contractually obligated to process your personal data only for the specific purposes for which it is disclosed and to maintain appropriate security measures.

owl77 primarily stores and processes your personal data on servers located within secure data centers. However, some of our service providers may be located outside Indonesia, which may involve the transfer of your personal data to countries with different data protection standards.

Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Entering into standard contractual clauses approved by relevant data protection authorities;
• Verifying that the receiving jurisdiction provides an adequate level of data protection; or
• Obtaining your explicit consent for the transfer where required by law.

owl77 implements industry-standard technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encrypted storage of personal data and financial information at rest;
• Tokenization of payment card data (where applicable) to prevent storage of sensitive financial information;
• Multi-factor authentication and access controls to restrict internal access to personal data;
• Regular security audits, penetration testing, and vulnerability assessments;
• Employee training on data protection and confidentiality obligations;
• Intrusion detection systems and real-time monitoring for suspicious activity.

While we take every reasonable precaution to secure your data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

owl77 retains your personal data 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 include:

• Active Accounts: Personal data associated with active accounts is retained for the duration of your membership on the platform.
• Closed Accounts: Following voluntary account closure, we retain personal data for a minimum of five (5) to seven (7) years to comply with regulatory record-keeping requirements, after which it is securely deleted.
• Transaction Records: Financial transaction data is retained for up to ten (10) years to satisfy tax, audit, and regulatory obligations.
• Self-Exclusion Records: Records of self-exclusion requests are retained indefinitely to prevent re-registration during the exclusion period.
• Marketing Data: If you opt out of marketing communications, your contact details are retained on a suppression list to ensure we do not contact you again.

Upon expiration of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be associated with you.

owl77 uses cookies, web beacons, and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you and remember your preferences.

The types of cookies we use include:

• Essential Cookies: Required for the platform to function properly, including authentication, session management, and security features. These cannot be disabled.
• Functional Cookies: Enable enhanced functionality such as language preferences, display settings, and user interface customization.
• Analytics Cookies: Help us understand how users interact with the platform by collecting anonymized usage data, which we use to improve performance and user experience.
• Marketing Cookies: Used to deliver personalized promotional offers and measure the effectiveness of our marketing campaigns.

You can manage your cookie preferences through your browser settings. However, disabling certain cookies may limit your ability to use some features of the platform.

Depending on your jurisdiction, you may have certain rights regarding your personal data. These rights may include:

• Right of Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: You have the right to request deletion of your personal data, subject to legal retention requirements.
• Right to Restriction: You have the right to request that we restrict processing of your personal data in certain circumstances.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw consent at any time.

To exercise any of these rights, please contact us using the details in Section 15. We will respond to your request within thirty (30) days. Some rights may be subject to limitations under applicable law.

owl77 may send you promotional emails, SMS messages, and in-platform notifications about special offers, bonuses, new games, and platform updates. You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link at the bottom of any marketing email;
• Adjusting your communication preferences in your account settings; or
• Contacting customer support with an opt-out request.

Please note that opting out of marketing communications does not prevent us from sending you essential service-related messages, such as account notifications, security alerts, and regulatory communications.

The owl77 platform is not intended for use by individuals under the age of 21. We do not knowingly collect personal data from anyone under 21 years of age. If we become aware that we have collected personal data from a person under 21, we will take immediate steps to delete that information and terminate the account.

If you believe that we may have collected data from an individual under 21, please contact us immediately at [email protected].

owl77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. Material changes will be communicated to registered users via email and a prominent notice on the platform at least seven (7) days before the changes take effect.

The "Last updated" date at the top of this Privacy Policy indicates when it was most recently revised. Your continued use of the platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or how owl77 processes your personal data, please contact us through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week through the platform's live chat widget.
• Response Time: We aim to respond to all privacy-related inquiries within twenty-four (24) hours on business days.

For data subject access requests or to exercise your privacy rights, please provide your full name, registered email address, and a description of your request. We may require additional verification to confirm your identity before processing the request.