Privacy Policy — tr99

1 Introduction

tr99 ("we", "us", "our") operates the online betting platform accessible at https://tr99.cam and all associated mobile interfaces, APIs, and services (collectively, "the Platform"). This Privacy Policy describes how tr99 collects, uses, discloses, stores, and safeguards the personal data of individuals who visit or hold an account on the Platform ("you", "your", "Member").

This policy applies to all Members registered on tr99, including players based in Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, Semarang, Makassar, and across the Indonesian archipelago. By accessing the Platform or completing account registration, you confirm that you have read this Privacy Policy in full and consent to the data practices described herein.

This Privacy Policy should be read alongside our Terms & Conditions. In the event of any conflict between the two documents, the Terms & Conditions shall prevail with respect to the contractual relationship between you and tr99, while this Privacy Policy shall govern all matters relating to personal data.

2 Definitions

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, identity number, date of birth, contact details, financial data, and device identifiers.
• "Processing" — any operation performed on personal data, including collection, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" — tr99, as the entity that determines the purposes and means of processing Member personal data.
• "Data Processor" — a third-party service provider engaged by tr99 to process personal data on tr99's behalf and under tr99's instruction.
• "KYC" — Know Your Customer — the identity verification process used to confirm the identity, age, and residency of Members.
• "Cookies" — small text files placed on your device by the Platform to store session information, preferences, and analytical data.
• "IDR" — Indonesian Rupiah, the currency in which all financial transactions on the Platform are denominated.

3 Data We Collect

tr99 collects the following categories of personal data from Members and Platform visitors:

4 How Data Is Collected

tr99 collects your personal data through the following means:

• Directly from you: when you complete the registration form, submit KYC documents, make a deposit or withdrawal, place a wager, contact our support team, or update your account profile.
• Automatically: through cookies, web beacons, server logs, and similar tracking technologies as you browse and interact with the Platform. This includes your IP address, device fingerprint, and session behavior.
• From third-party payment providers: when you transact via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI, OVO, DANA, GoPay, ShopeePay, or LinkAja — we receive confirmation data necessary to credit your account or process your withdrawal.
• From identity verification partners: tr99 may use third-party KYC service providers to assist in validating the authenticity of government-issued identity documents submitted by Members.
• From fraud and risk detection systems: automated systems may flag and record unusual behavioral patterns, device anomalies, or IP-based risk indicators as part of our platform security operations.

5 Purpose of Processing

tr99 processes Member personal data for the following purposes:

• Account Management: to create, maintain, and administer your tr99 account, including processing deposits and withdrawals in IDR and managing your betting activity.
• Identity & Age Verification (KYC): to verify that you are at least 21 years of age and a legitimate account holder, as required by our operational standards and anti-fraud obligations.
• Transaction Processing: to execute and record deposits and withdrawals through local Indonesian payment channels and to reconcile financial records.
• Customer Support: to respond to your inquiries, process complaints, and resolve disputes in a timely and informed manner.
• Security & Fraud Prevention: to detect and investigate suspicious activity, prevent unauthorized account access, identify multi-account abuse, and protect the integrity of our platform.
• Regulatory Compliance: to fulfill obligations under applicable anti-money laundering (AML) regulations, our international operating license, and any lawful order from a competent authority.
• Responsible Gaming: to monitor wagering patterns that may indicate problem gambling behavior and to administer self-exclusion or deposit limit requests.
• Platform Improvement: to analyze aggregate usage data, improve site performance, personalize the user experience, and develop new product features.
• Marketing (where consent is given): to send you information about promotions, bonuses, and seasonal offers relevant to your interests — such as Idul Fitri specials or Champions League betting promotions — where you have opted in to receive such communications.

6 Legal Basis for Processing

tr99 processes your personal data on the following legal grounds:

• Contractual Necessity: processing required to fulfill our obligations under the Terms & Conditions — including account creation, transaction processing, and customer support.
• Legal Obligation: processing required to comply with applicable laws, including KYC/AML obligations, regulatory reporting, and responding to lawful authority requests.
• Legitimate Interests: processing necessary for fraud prevention, platform security, responsible gaming monitoring, and the ongoing improvement of our services — where these interests are not overridden by your fundamental rights.
• Consent: processing for direct marketing communications and non-essential cookies, where you have provided explicit opt-in consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

tr99 does not sell or rent your personal data. We may share your data only in the following limited circumstances:

• Payment Processors: we share the minimum necessary financial data with your chosen payment provider (e.g., BCA, BRI, Mandiri, GoPay, OVO) to process deposits and withdrawals. These providers operate under their own privacy policies and are contractually bound to protect your data.
• KYC & Identity Verification Partners: identity document data submitted during KYC may be shared with certified third-party verification services for authenticity validation.
• Fraud Prevention & Security Services: technical data including IP addresses and device identifiers may be shared with anti-fraud platforms to identify and prevent unauthorized access, bonus abuse, and other prohibited conduct.
• Game Content Providers: where required for the delivery of third-party game content, limited session data may be shared with licensed studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. These studios are bound by data processing agreements with tr99.
• Regulatory & Law Enforcement Authorities: tr99 will disclose personal data to competent authorities where required by a lawful order, court directive, or where disclosure is necessary to prevent serious harm or criminal activity.
• Corporate Transactions: in the event of a merger, acquisition, or sale of all or part of tr99's business operations, Member personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

8 Data Retention

tr99 retains personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by applicable law or regulatory obligation.

• Active Account Data: retained for the full duration of your membership and for a minimum of five (5) years following account closure, in line with standard AML record-keeping requirements.
• KYC Documents: retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later.
• Transaction Records: retained for a minimum of five (5) years from the date of each transaction to satisfy financial audit and regulatory compliance obligations.
• Support Communications: retained for three (3) years from the date of the last interaction to enable resolution of any subsequent complaints or disputes.
• Marketing Preference Data: retained until you withdraw consent or request deletion, after which opt-out records are kept for a further two (2) years to prevent inadvertent re-subscription.
• Technical & Log Data: typically retained for twelve (12) months on a rolling basis, unless flagged for security or fraud investigation purposes.

Once the applicable retention period has expired and no legal obligation requires continued storage, your personal data will be securely deleted or irreversibly anonymized.

9 Security Measures

tr99 employs a layered security architecture to protect Member personal data from unauthorized access, accidental loss, alteration, or disclosure. Our key technical and organizational safeguards include:

• Encryption: all data in transit is protected by TLS 1.3; all data at rest is encrypted using AES-256 encryption standards.
• Access Controls: personal data is accessible only to authorized tr99 personnel on a strict need-to-know basis. Access is governed by role-based permissions and multi-factor authentication.
• SSL Certificate: the Platform operates exclusively over HTTPS. Any attempt to access tr99 over an unencrypted connection is automatically redirected.
• Intrusion Detection: our infrastructure is monitored around the clock by automated intrusion detection and prevention systems, with alerts reviewed by our security operations team (WIB).
• Regular Security Audits: tr99 conducts periodic penetration testing and vulnerability assessments conducted by qualified third-party security firms.
• Incident Response: in the event of a confirmed data breach affecting Member personal data, tr99 will notify affected Members within 72 hours of becoming aware of the incident, in accordance with our incident response protocol.

10 Cookies & Tracking Technologies

tr99 uses cookies and similar tracking technologies to operate the Platform effectively and deliver a personalized experience. The following categories of cookies are used:

• Strictly Necessary Cookies: essential for the Platform to function — these enable login sessions, account security, and transaction processing. They cannot be disabled without breaking core functionality.
• Performance & Analytics Cookies: used to collect anonymous information about how Members interact with the Platform — such as pages visited, session duration, and error events — enabling us to improve site performance and usability.
• Functional Cookies: used to remember your preferences, such as language settings, default stake amounts, and notification choices, so you do not need to re-enter them on each visit.
• Marketing Cookies: used only where you have provided explicit consent to track activity for the purpose of delivering relevant promotional content. These cookies are not shared with external advertising networks.

You may manage or withdraw your consent to non-essential cookies at any time via your browser settings. Please note that disabling certain cookies may affect the functionality of some Platform features. For details on specific cookies deployed on the Platform, contact our support team at [email protected].

11 Your Data Rights

As a Member of tr99, you have the following rights with respect to your personal data. To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request". We will respond within 30 calendar days.

• Right of Access: you may request a copy of all personal data tr99 holds about you, along with information about how it is processed.
• Right to Rectification: you may request correction of any inaccurate or incomplete personal data held in your account profile.
• 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 — subject to our legal retention obligations described in Section 8.
• Right to Restriction: you may request that we limit the processing of your data in certain circumstances — for example, while a dispute regarding data accuracy is being resolved.
• Right to Data Portability: you may request that we provide your personal data in a structured, machine-readable format, enabling transfer to another service provider.
• Right to Object: you may object to processing based on tr99's legitimate interests, including profiling for responsible gaming monitoring — subject to our overriding legal obligations.
• Right to Withdraw Consent: where processing is based on your consent (e.g., marketing communications or non-essential cookies), you may withdraw that consent at any time without affecting prior lawful processing.

12 Minors

The tr99 platform is strictly intended for adults aged 21 years and above. tr99 does not knowingly collect personal data from individuals under 21. If we become aware that an account has been registered by a person under 21, the account will be immediately suspended, all data will be reviewed, and any balances derived from wagering will be forfeited in accordance with our Terms & Conditions.

If you are a parent or guardian and believe your child has created a tr99 account, please contact us immediately at [email protected]. We will take prompt action to verify the situation and close the account if the age restriction has been violated.

13 International Data Transfers

tr99 operates internationally and, as such, your personal data may be processed on servers located outside Indonesia. Where data is transferred across borders, tr99 ensures that appropriate safeguards are in place — including data processing agreements incorporating internationally recognized standard contractual clauses — to provide a level of protection equivalent to that described in this Privacy Policy.

Specifically, where Member data is processed by third-party game studios (including Pragmatic Play, Evolution Gaming, and Spribe) or KYC verification partners, those providers are contractually obligated to maintain data protection standards commensurate with tr99's own obligations and with the requirements of our international operating license.

14 Policy Amendments

tr99 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform operations. When material changes are made, we will notify active Members via email to the address registered on their account and display a prominent notice on the Platform for a period of at least 14 days prior to the changes taking effect.

The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to the updated policy, you must cease using the Platform and may request account closure by contacting our support team.

15 Contact Us

If you have any questions, concerns, or formal requests regarding this Privacy Policy or the way tr99 processes your personal data, please contact our dedicated data privacy team through the following channel:

• Email: [email protected]
• Subject Line: Please use "Privacy Inquiry" or "Data Rights Request" to ensure your message is directed to the appropriate team.
• Response Time: We acknowledge all privacy-related inquiries within 48 hours (WIB) and aim to provide a full written response within 30 calendar days.
• Support Hours: 24 hours a day, 7 days a week, 365 days a year