cun77 Privacy Policy

Definitions

The following defined terms apply throughout this Privacy Policy. Where a term is also defined in the cun77 Terms & Conditions, the same meaning applies here unless otherwise stated.

Data We Collect

cun77 collects Personal Data through several distinct channels. The categories of data collected and the specific channel through which each is gathered are set out below.

2.1 Registration Data. When you create a Member Account, we collect: full legal name, date of birth, residential address in Indonesia (including city — Jakarta, Surabaya, Medan, Bandung, Bali, Yogyakarta, or elsewhere), email address, and Indonesian mobile phone number. This data is mandatory; without it, we cannot open an Account for you.

2.2 Identity Verification (KYC) Data. To verify your identity and comply with anti-money-laundering (AML) obligations, we may request copies of: your Indonesian national identity card (KTP), passport, driver's licence, selfie photograph for biometric comparison, and proof of payment method ownership (e.g., a screenshot of your BCA or OVO account showing your name and account number). KYC documents are processed by our internal compliance team and, where applicable, by a vetted third-party identity verification provider.

2.3 Transaction Data. Every deposit, withdrawal, bonus credit, and bet placed on the Platform is recorded. Transaction records include: transaction ID, timestamp (WIB, UTC+7), amount in IDR, payment method used (e.g., BRI, GoPay, ShopeePay), and transaction status. This data is retained for audit, fraud prevention, and dispute resolution purposes.

2.4 Gameplay Data. We record your activity across all Platform products: sports bets (BRI Liga 1, EPL, Champions League, mix parlay accumulators, voor bola handicap markets), live casino sessions (Evolution Gaming, Pragmatic Play Live), slot spins (Pragmatic Play, Microgaming, NetEnt, Pocket Games Soft), togel number selections, Bandar Q hands, and Video Poker sessions. Gameplay data is used for account management, responsible gaming monitoring, and product improvement.

2.5 Device and Technical Data. When you access the Platform, we automatically collect: IP address, browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution, referring URL, session duration, and pages visited. This technical data is used for security monitoring, fraud detection, and platform optimisation.

2.6 Communication Data. Records of your interactions with our customer support team — including live chat transcripts, email correspondence to [email protected], and WhatsApp messages to +62 811 0000 7777 — are retained to ensure service continuity and for quality assurance purposes.

2.7 Marketing Preferences. If you opt in to receive promotional communications from cun77, we record your marketing preferences. You may withdraw this consent at any time by contacting our support team or by using the unsubscribe mechanism in any marketing email we send you.

How We Use Your Data

cun77 processes your Personal Data only for the specific, legitimate purposes listed below. We do not process your data for any purpose that is incompatible with these stated purposes without first obtaining your explicit consent.

• Account Management: Creating, verifying, and maintaining your Member Account; authenticating your login sessions; processing password resets and account updates.
• Transaction Processing: Facilitating deposits in IDR via local Indonesian banks and e-wallets; processing withdrawal requests to your registered payment method; applying bonus credits and processing wagering requirement tracking.
• Identity Verification: Completing KYC checks to confirm you are at least 21 years of age, a genuine individual, and the legitimate owner of the payment methods used on your Account.
• Fraud and Security: Detecting, investigating, and preventing fraudulent activity, collusion, money laundering, unauthorised access, and other prohibited conduct on the Platform.
• Responsible Gaming: Monitoring gameplay patterns to identify early indicators of problem gambling behaviour; enforcing self-exclusion requests and deposit/loss limits set by Members; proactively contacting Members whose activity patterns suggest risk.
• Customer Support: Responding to your enquiries, complaints, and dispute requests via live chat, email, and WhatsApp; maintaining records of support interactions for quality assurance.
• Legal Compliance: Meeting applicable AML, counter-terrorism financing (CTF), and data protection obligations; responding to lawful requests from competent authorities.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the Platform's functionality, game selection, payment infrastructure, and user experience for Indonesian Members.
• Marketing Communications: Sending promotional offers, bonus notifications, and seasonal promotions (e.g., Idul Fitri bonus offers, Ramadhan cashback promotions, Indonesian Independence Day specials) to Members who have opted in to receive such communications. You may opt out at any time.

Data Sharing

4.1 We Do Not Sell Your Data. cun77 does not sell, rent, or trade your Personal Data to any third party for their independent marketing or commercial purposes. Your data is shared only in the specific circumstances described in this Clause.

4.2 Third-Party Service Providers. We share Personal Data with vetted Data Processors who assist us in operating the Platform. All such processors are bound by contractual data processing agreements that prohibit them from using your data for any purpose beyond the specific service they provide to cun77. Categories of Data Processors include:

• Payment processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, and LinkAja — receive transaction data necessary to execute deposits and withdrawals.
• Game providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Pocket Games Soft, and Spribe — receive a session token and anonymised player ID to deliver their game content. They do not receive your full registration details.
• Identity verification providers: Our KYC partner receives copies of your identity documents solely for the purpose of verifying your identity and age in accordance with AML requirements.
• Fraud prevention and security vendors: Receive device fingerprint data, IP address logs, and behavioural analytics signals to detect suspicious activity on the Platform.
• Customer support platforms: Our live chat software provider processes the content of your chat sessions to deliver real-time support.

4.3 Legal and Regulatory Disclosures. cun77 may disclose your Personal Data to competent government authorities, law enforcement agencies, or regulatory bodies where we are legally compelled to do so, or where disclosure is necessary to protect the rights, property, or safety of cun77, its Members, or the public.

4.4 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of cun77's assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified via email or a prominent notice on the Platform prior to such transfer, and the acquiring entity will be bound by privacy commitments no less protective than those in this Policy.

4.5 No Cross-Border Transfers Without Safeguards. Where Personal Data is transferred to a Data Processor located outside of Indonesia, cun77 ensures that appropriate safeguards are in place — including contractual clauses that impose equivalent data protection standards — before any such transfer takes place.

Data Retention

5.1 Active Accounts. We retain your Personal Data for as long as your Member Account remains active and for as long as is necessary to provide you with the Platform's services.

5.2 Closed Accounts. Following the closure of your Member Account — whether initiated by you or by cun77 — we retain your Personal Data for a minimum period of five (5) years from the date of closure. This retention period is required to: (a) comply with applicable AML and CTF record-keeping obligations; (b) resolve any outstanding disputes or legal claims; and (c) prevent fraudulent re-registration attempts.

5.3 KYC Documents. Identity verification documents are retained for a minimum of five (5) years from the date of verification or from the date of Account closure, whichever is later, in accordance with internationally recognised AML standards.

5.4 Marketing Data. If you have opted in to receive marketing communications, we retain your marketing preferences and contact details for this purpose until you withdraw your consent. Following withdrawal of consent, your data is removed from our marketing lists within 30 days, though it may be retained in suppression lists to ensure we do not inadvertently contact you again.

5.5 Technical and Log Data. Server logs, IP address records, and session data are retained for up to 24 months for security monitoring and fraud prevention purposes, after which they are permanently deleted or anonymised.

5.6 Deletion Requests. Where you submit a valid data deletion request (see Clause 8 — Your Rights), cun77 will delete or anonymise your Personal Data as soon as practicable, subject to the retention obligations described above. Where we are legally required to retain certain data, we will inform you of the applicable retention period and the reason for it at the time we respond to your request.

Security Measures

cun77 applies a layered, defence-in-depth approach to data security. The following technical and organisational measures are in place to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction.

6.1 Encryption in Transit. All data transmitted between your browser or mobile device and our servers is encrypted using 256-bit TLS 1.3. We enforce HTTPS across the entire Platform; any HTTP request is automatically redirected to HTTPS. Our SSL certificate is maintained and renewed on a proactive schedule with zero tolerance for certificate lapses.

6.2 Encryption at Rest. Personal Data and financial records stored in our databases are encrypted at rest using AES-256 encryption. Database access is restricted to a strictly limited number of authorised personnel operating under role-based access controls (RBAC).

6.3 Access Controls. All internal systems that hold Personal Data are protected by multi-factor authentication (MFA). Employee access to Member data is granted on a least-privilege basis — each team member can access only the data strictly necessary for their role. All access is logged and subject to regular audits.

6.4 Fraud Detection Systems. cun77 operates real-time fraud detection systems that monitor for anomalous login behaviour, unusual transaction patterns, VPN usage, and device fingerprint mismatches. Accounts flagged by our fraud systems are automatically suspended pending investigation to protect both the Member and the integrity of the Platform.

6.5 Third-Party Security Audits. Our Platform undergoes regular independent security penetration testing conducted by accredited third-party cybersecurity firms. Identified vulnerabilities are remediated according to a risk-tiered schedule, with critical issues addressed within 24 hours of identification.

6.6 Incident Response. In the event of a data security incident that poses a material risk to your rights and freedoms, cun77 will notify affected Members without undue delay following discovery of the incident, and will take all reasonable steps to contain, investigate, and remediate the breach. Notifications will include a description of the nature of the incident, the categories of data affected, and the steps you should take to protect yourself.

6.7 Member Responsibility. While cun77 maintains robust security on the Platform's side, you are also responsible for keeping your login credentials secure. Do not share your username or password with any third party. Use a strong, unique password for your cun77 Account and update it regularly. If you believe your Account has been compromised, contact our support team immediately via live chat.

Cookies & Tracking Technologies

7.1 What Are Cookies? Cookies are small text files that our Platform places on your device when you visit cun77.bet. They enable the Platform to remember your session state, language preferences, and certain settings between visits, and allow us to understand how Members use the Platform so we can improve it.

7.2 Types of Cookies We Use.

7.3 Managing Cookies. You can control cookie behaviour through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies will prevent the Platform from functioning correctly — you will not be able to log in or place bets if these cookies are blocked. Functional and analytics cookies can be disabled without affecting core Platform functionality, though doing so may reduce the quality of your personalised experience.

7.4 No Third-Party Advertising Cookies. cun77 does not allow third-party advertising networks to place tracking cookies on cun77.bet for the purpose of building advertising profiles or retargeting you on other websites. Any analytics tools we use are configured to anonymise your IP address and are prohibited from sharing your data with their own advertising networks.

Your Rights

As a Member of cun77, you have the following rights with respect to your Personal Data. To exercise any of these rights, please contact our Data Protection team at support@cun77.bet with the subject line "Data Rights Request" and your registered Account username. We will acknowledge your request within 48 hours and provide a substantive response within 30 calendar days.

Minors

9.1 Age Restriction. The Platform is strictly intended for adults aged 21 and over. cun77 does not knowingly collect Personal Data from any individual under the age of 21. By registering a Member Account, you represent and warrant that you are at least 21 years of age.

9.2 Age Verification. cun77 operates a mandatory age verification check as part of its KYC process. Any Account where the Member's age cannot be verified as 21 or older will be suspended, and any funds in that Account will be returned via the deposit payment method pending resolution. cun77 reserves the right to request proof of age at any point during the life of a Member's Account.

9.3 Discovery of Underage Use. If cun77 discovers or is notified that Personal Data belonging to an individual under the age of 21 has been collected on the Platform, we will: (a) immediately suspend the associated Account; (b) permanently delete all Personal Data associated with that Account as quickly as practicable; and (c) refund any deposited funds to the payment method from which they originated. If you believe a minor may have accessed the Platform, please notify us immediately at support@cun77.bet.

9.4 Parental Controls. cun77 strongly encourages parents and guardians to make use of internet filtering tools to prevent minors from accessing online gambling platforms. Many devices and internet service providers offer parental control features that can be configured to block gambling-related websites. More information on responsible gaming tools — including guidance for families — is available on our Responsible Gaming page.

Policy Changes

10.1 Right to Update. cun77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. All updates will be published on this page with a revised "Last Revised" date at the top of the Policy.

10.2 Notification of Material Changes. Where a proposed change is material — meaning it meaningfully affects how we use your Personal Data or reduces your rights under this Policy — we will notify active Members by email to their registered address at least 14 days before the change takes effect. The notification will summarise the key changes and provide a link to the revised Policy in full.

10.3 Continued Use as Acceptance. Your continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acceptance of those changes. If you do not agree with the revised terms, you should close your Account before the effective date of the change. Account closure instructions are available on our FAQ page or by contacting our support team.

10.4 Archived Versions. cun77 maintains a record of previous versions of this Privacy Policy. If you need access to a prior version for reference or dispute purposes, please contact our support team and we will provide it on request.

Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or cun77's data practices, please contact our Data Protection team through any of the following channels. Indonesian-speaking agents are available via live chat and WhatsApp during support hours.

• Live Chat: Available directly on the Platform, 24 hours a day, 7 days a week. Fastest response channel.
• Email: support@cun77.bet — use subject line "Privacy Policy Query" or "Data Rights Request". Responses within 48 hours.
• WhatsApp: +62 811 0000 7777 — available 07:00–23:00 WIB daily.

When submitting a data rights request by email, please include: (a) your registered Account username; (b) the email address associated with your Account; (c) a clear description of the right you wish to exercise or the query you have; and (d) any relevant supporting information. This will allow our team to authenticate your request and respond as efficiently as possible.