ink77 Privacy Policy — Your Data, Your Rights

For the purposes of this Privacy Policy, the Data Controller is the entity responsible for operating the ink77 platform at ink77.pro. The Data Controller determines the purposes and means by which your personal data is processed.

All enquiries relating to this Privacy Policy, including requests to exercise your data rights, should be directed to the ink77 support team using the contact details set out in Clause 15 of this document. ink77 is committed to responding to all data-related enquiries in English within 30 calendar days of receipt.

This Privacy Policy applies to:

• All individuals who register or apply to register an account on the ink77 platform, including applicants whose registration is declined.
• All active and former account holders who have deposited funds, placed wagers, or otherwise used platform services at any point.
• All visitors to the ink77.pro website, regardless of whether they have an account, to the extent that browsing data is collected automatically as described in Clause 9.
• All individuals who contact ink77 via live chat, email, or WhatsApp support channels, even if they are not registered account holders.

This policy applies to data processing activities carried out in connection with the Indonesian market. Given that ink77 primarily serves players located in Indonesia — in cities including Jakarta, Surabaya, Medan, Bandung, Bali, Semarang, Makassar, and Palembang — this policy reflects data protection standards appropriate for that context.

ink77 collects the following categories of personal data, depending on the nature of your interaction with the platform:

ink77 collects personal data through the following channels:

4.1 Information You Provide Directly

When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or update your account settings, you provide personal data directly to ink77. This is the primary source of identity, contact, financial, and preference data.

4.2 Automated Collection

When you visit or use the ink77 platform, technical data is collected automatically via server logs, cookies, and similar technologies. This includes your IP address, session timestamps, and device characteristics. See Clause 9 for full details on cookies and tracking technologies.

4.3 Third-Party Sources

ink77 may receive data about you from the following third-party sources:

• KYC verification partners: Identity and document verification service providers may return verification results and risk scores that are associated with your account record.
• Payment processors: When you initiate a deposit or withdrawal via a bank transfer (BCA, BRI, BNI, Mandiri) or an e-wallet (OVO, DANA, GoPay), the payment provider confirms the transaction status and associated account details to ink77.
• Fraud detection services: ink77 uses specialist fraud detection tools that may cross-reference your submitted data against known fraud indicators. No personal data is transferred to these services beyond what is necessary for the fraud check.
• Game studios: Third-party game providers (Evolution Gaming, Pragmatic Play, PG Soft) may return game session data including session start and end times, bet amounts, and outcomes to ink77 for account record purposes.

ink77 processes your personal data only for the specific purposes listed below, each of which rests on a defined legal basis:

ink77 does not process personal data for purposes incompatible with those listed above. Where a new processing purpose arises that is materially different from the original purpose, ink77 will inform you and, where required, seek fresh consent before processing begins.

ink77 does not sell, rent, or otherwise commercially transfer your personal data to third parties. We share data only in the limited circumstances described below:

6.1 Essential Service Providers

ink77 engages a small number of carefully vetted third-party service providers who process data on our behalf under binding data processing agreements. These include:

• KYC and identity verification providers
• Payment processors facilitating IDR transactions via Indonesian banks and e-wallets
• Fraud detection and cybersecurity service providers
• Cloud infrastructure and hosting providers on whose servers the platform operates
• Customer support software providers (for the live chat system)
• Email delivery service providers (for account notifications and KYC status updates)

All service providers are contractually prohibited from using your data for any purpose other than providing their designated service to ink77.

6.2 Game Studio Providers

To deliver live casino, slot, and poker products, ink77 shares session-level data with certified third-party game studios including Evolution Gaming, Pragmatic Play, PG Soft, and SA Gaming. This data enables game delivery, result verification, and dispute resolution. Game studio providers are not permitted to use this data for independent marketing or profiling purposes.

6.3 Legal and Regulatory Disclosure

ink77 may be required to disclose personal data to law enforcement agencies, regulatory authorities, or courts where compelled to do so by applicable law, a valid court order, or an official government request. ink77 will disclose only the minimum data necessary to satisfy the legal requirement and will notify the affected player where legally permitted to do so.

6.4 Business Transfers

In the event of a merger, acquisition, asset sale, or other corporate restructuring involving ink77, personal data held by the platform may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and the Privacy Policy applicable to their data following the transfer.

ink77 retains personal data for as long as is necessary to fulfil the purpose for which it was collected, subject to the following retention guidelines:

• Active account data (identity, contact, financial, transaction data) is retained for the lifetime of your account and for a minimum of five years following account closure, in line with standard anti-money-laundering record-keeping obligations.
• KYC documents (copies of national ID, passport, proof of address) are retained for a minimum of five years from the date of submission, or five years from the date of account closure, whichever is later.
• Customer support communications (live chat transcripts, email correspondence) are retained for a maximum of three years from the date of the last interaction, after which they are securely deleted or anonymised.
• Technical / session data (IP addresses, login logs) is retained for a maximum of 12 months in identifiable form, after which it is anonymised and retained only in aggregate for platform analytics purposes.
• Marketing consent records are retained for the duration of your account plus three years, to demonstrate compliance with consent requirements.

When personal data is no longer required for the purpose for which it was collected and no legal retention obligation applies, ink77 will securely delete or irreversibly anonymise it within 90 days of the retention period expiring.

ink77 implements a layered security architecture to protect personal data against unauthorised access, disclosure, alteration, and destruction. Technical and organisational measures in place include:

• Encryption at rest: All personal data stored in ink77's database infrastructure is encrypted using AES-256.
• Encryption in transit: All data exchanged between your browser and ink77 servers is transmitted over TLS 1.2 or TLS 1.3 connections. Pages are served exclusively over HTTPS.
• Access control: Access to personal data within the ink77 organisation is strictly role-based. Only personnel with a documented operational need may access specific data categories. All access is logged and auditable.
• Two-factor authentication: Administrative access to systems holding personal data requires multi-factor authentication. ink77 also offers 2FA to all account holders.
• Penetration testing: ink77's platform infrastructure undergoes regular third-party security audits and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident response: ink77 maintains a documented data breach incident response procedure. In the event of a breach, the response team is activated within one hour of detection, and affected players are notified without undue delay where the breach poses a risk to their rights and freedoms.
• Staff training: All ink77 employees and contractors with access to personal data undergo mandatory data protection and security training upon onboarding and on an annual basis thereafter.

ink77 uses cookies and similar web technologies on the ink77.pro platform. A cookie is a small text file stored on your device by your browser when you visit a website. Cookies serve a range of functional and analytical purposes.

9.1 Categories of Cookies Used

9.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You may disable non-essential cookies via your browser settings at any time. However, disabling strictly necessary or fraud-prevention cookies may prevent you from logging in or using key platform features. ink77 does not use cookies for third-party advertising or retargeting purposes.

The ink77 platform serves players primarily located in Indonesia. Some of the third-party service providers engaged by ink77 — including cloud infrastructure providers, KYC verification partners, and certain game studio providers — may process or store data in locations outside Indonesia.

Where personal data is transferred to a country that does not provide a level of data protection equivalent to Indonesian standards, ink77 ensures that appropriate safeguards are in place. These safeguards include:

• Standard contractual clauses requiring the recipient to apply data protection standards equivalent to those in this Privacy Policy.
• Binding data processing agreements with all service providers that process data on ink77's behalf, regardless of their location.
• Technical measures (encryption in transit and at rest) that protect data during and after transfer.

By registering an account with ink77, you acknowledge that your personal data may be transferred to and processed in countries other than Indonesia as described in this clause, subject to the safeguards set out above.

As a data subject, you hold the following rights over the personal data that ink77 holds about you. ink77 will respond to all valid rights requests within 30 calendar days of receipt. All requests should be submitted via the support channels set out in Clause 15.

To exercise any of the rights above, please contact the ink77 support team via live chat or email as specified in Clause 15. ink77 may need to verify your identity before processing your request to prevent unauthorised access to another person's data.

The ink77 platform is strictly for individuals aged 21 and above. ink77 does not knowingly collect personal data from persons under the age of 21. Age verification (KYC) is a mandatory step before any real-money activity is permitted on an account, and documents confirming date of birth are required from all players.

If ink77 discovers or is notified that it has inadvertently collected personal data from a person under 21, it will:

• Immediately suspend the account and freeze any associated balance pending review.
• Conduct a KYC review to establish the true age of the account holder.
• If the account holder is confirmed to be under 21, permanently close the account and return any deposited real-money funds to the source payment method, net of any bonus amounts.
• Delete all personal data associated with the underage account upon completion of the return of funds process, except where records must be retained for legal purposes.

If you are a parent or guardian and believe your child has registered an ink77 account, please contact the support team immediately using the details in Clause 15 and we will act without delay.

The ink77 platform may contain references to or integrations with third-party game studios whose software is embedded within the platform environment. When you launch a game from a third-party studio (for example, an Evolution Gaming live casino table or a Pragmatic Play slot), you interact with software operated by that third party.

Each third-party game studio has its own privacy practices governing any data they collect directly during your game session. ink77 is not responsible for the privacy practices of third-party studios beyond the contractual data processing obligations it imposes on them as described in Clause 6.2.

ink77 does not include outbound links to unrelated external websites. All navigation links within the ink77 platform lead to internal platform destinations. If you navigate away from ink77.pro to an external site via a bookmark or browser history, ink77's Privacy Policy ceases to apply from the moment you leave the platform.

ink77 reviews this Privacy Policy on a regular basis to ensure it accurately reflects current data processing practices, applicable legal requirements, and platform developments. We reserve the right to update or amend this policy at any time.

Where amendments are material — meaning they significantly affect how your personal data is used, your rights, or our disclosure practices — ink77 will notify registered account holders via email to the address on file at least 14 days before the changes take effect. The updated policy will also be published on this page with a revised "Last Reviewed" date in the document header.

For minor amendments — such as clarifications, corrections of typographical errors, or updates that expand rather than restrict your rights — ink77 may update the policy without advance notice. The "Last Reviewed" date will be updated to reflect any change of any kind.

Your continued use of the ink77 platform after the effective date of any amendment constitutes your acknowledgement and acceptance of the revised Privacy Policy. If you do not agree with any changes, you should stop using the platform and request account closure before the effective date of the amendment.

For any questions, concerns, or requests relating to this Privacy Policy or the personal data ink77 holds about you — including requests to exercise your data rights under Clause 11 — please contact the ink77 data protection team through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly within the ink77 platform. Indonesian-speaking agents are available at all hours.
• Email: [email protected] — please include "Privacy Request" in the subject line for data rights enquiries. Responses are provided within 30 calendar days.
• WhatsApp: +62 811 9988 7700 — for urgent account security or suspected data breach notifications.

All correspondence relating to data rights requests will be handled in English. Indonesian-language support is available through live chat for general account queries; formal data rights responses are issued in English as the governing language of this policy.