Privacy Policy — sor77

Definitions

The following terms carry the meanings assigned below throughout this Privacy Policy.

Scope & Data Controller

This Privacy Policy applies to all Personal Data collected by sor77 through the platform at sor77.cam, including data collected via account registration, deposits and withdrawals, customer support interactions, gameplay activity, and promotional participation.

sor77 acts as the data controller in respect of all Personal Data collected directly from players. Where sor77 engages third-party processors — such as payment service providers processing IDR transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, or LinkAja — those processors act under contractual data processing agreements that require them to handle your data only as instructed by sor77 and in compliance with applicable data protection standards.

This Policy is intended for players based in Indonesia and is written in English in accordance with sor77's platform language. Indonesian-speaking support is available at all times for players who require assistance understanding any aspect of this Policy.

Personal Data We Collect

3.1 Registration Data

When you create a sor77 account, we collect the following information:

• Full legal name (as it appears on your government-issued ID);
• Date of birth (to verify you are at least 21 years of age);
• Residential address in Indonesia (city, province, postal code);
• Email address;
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

Prior to your first withdrawal, sor77 requires you to complete a KYC process. This involves submitting:

• A copy of a government-issued photo ID, such as a Kartu Tanda Penduduk (KTP) or valid Indonesian passport;
• Proof of payment method ownership, such as a bank statement or e-wallet screenshot from BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, or Bank Permata;
• Additional documentation if requested as part of an enhanced due diligence review.

3.3 Financial Transaction Data

For every deposit and withdrawal, sor77 records the transaction amount in IDR, the payment method used, the transaction timestamp (in WIB, UTC+7), and the transaction reference number provided by the payment gateway. sor77 does not store full bank account numbers or e-wallet PINs; payment credentials are handled exclusively by the relevant payment service provider.

3.4 Gameplay and Betting Data

sor77 records all bets placed through the sportsbook, live casino, and slot products — including bet amount, odds, game title, outcome, and payout. This data is used for account statement purposes, dispute resolution, responsible gaming monitoring, and regulatory compliance.

3.5 Technical and Device Data

When you access sor77, we automatically collect certain technical data, including:

• IP address and approximate geolocation;
• Device type, operating system, and browser version;
• Session timestamps, page views, and click-path data;
• Cookie identifiers and local storage values.

3.6 Communications Data

If you contact sor77's support team via live chat or email, we retain a record of that communication — including the content of messages, timestamps, and any supporting files you submit — for quality assurance, dispute resolution, and training purposes.

How We Use Your Personal Data

sor77 will not use your Personal Data for any purpose that is incompatible with those listed above without first providing you with clear notice and, where required, obtaining your consent.

Legal Basis for Processing

sor77 processes your Personal Data on one or more of the following legal bases:

• Contractual necessity: Processing required to fulfil the account agreement between you and sor77, including account registration, transaction processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, KYC obligations, and data retention mandates imposed by our international gaming licence.
• Legitimate interests: Processing carried out for sor77's legitimate business interests, such as fraud prevention, platform security, and product analytics — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — for example, receiving promotional emails. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Sharing Your Personal Data

sor77 does not sell your Personal Data. We may share it only in the following circumstances and only to the extent strictly necessary:

6.1 Payment Service Providers

To process IDR deposits and withdrawals, sor77 shares relevant transaction data with our approved Indonesian payment partners, including but not limited to BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja. Each provider operates under its own privacy policy and is bound by applicable Indonesian financial regulations.

6.2 Identity Verification Providers

To fulfil our KYC obligations and enforce the 21+ age restriction, sor77 works with certified third-party identity verification services. Your KYC documents are transmitted to these providers via encrypted channels and are not retained by them beyond the verification process.

6.3 Game Studio Providers

Where you play games supplied by third-party studios — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — limited technical data (such as a pseudonymised player ID and session token) is shared with those studios for game operation and fairness auditing purposes. No directly identifying personal data is shared with game studios.

6.4 Fraud Prevention and Security Services

sor77 uses third-party fraud detection and cybersecurity services to protect both the platform and our players. These services may receive technical data including IP addresses, device fingerprints, and behavioural signals for the sole purpose of identifying and preventing fraudulent activity.

6.5 Legal and Regulatory Disclosure

sor77 may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where required by law, pursuant to a valid legal order, or where disclosure is necessary to protect the rights, property, or safety of sor77, its players, or the public.

International Data Transfers

sor77 operates as an internationally licensed platform and some of the third-party processors we work with — including game studios and fraud prevention services — are located outside Indonesia. When your Personal Data is transferred to a jurisdiction that does not provide a level of data protection equivalent to that available in Indonesia, sor77 ensures appropriate safeguards are in place, such as:

• Standard contractual clauses approved by the relevant data protection authority;
• Binding corporate rules where applicable;
• Data processing agreements that contractually obligate the recipient to apply security and confidentiality standards consistent with this Privacy Policy.

You may request further information about the specific safeguards in place for any international transfer by contacting our support team at [email protected].

Data Retention

sor77 retains your Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

After the applicable retention period has expired, Personal Data is securely deleted or anonymised so that it can no longer be associated with any individual.

Cookies & Tracking Technologies

sor77 uses cookies and similar tracking technologies to ensure the platform functions correctly, to protect session security, and to gather aggregated analytics that help us improve the player experience.

9.1 Types of Cookies We Use

• Essential cookies: Required for the platform to operate. These include session authentication tokens, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
• Analytics cookies: Used to collect anonymised data on how players navigate the platform, which game categories are most popular, and where players encounter errors. This data is aggregated and cannot be used to identify individual players.
• Fraud prevention cookies: Used to detect unusual device behaviour, multiple-account signals, and automated bot activity. These are essential for platform integrity and cannot be disabled.

9.2 What We Do Not Use

sor77 does not use third-party advertising cookies, retargeting pixels, social media tracking tags, or any other technology that tracks your activity across websites other than sor77.cam. We do not use Google Ads conversion tracking, Facebook Pixel, or similar cross-site advertising tools.

9.3 Managing Cookies

You can manage and delete cookies through your browser settings at any time. Please note that disabling essential cookies will prevent you from logging in to your sor77 account and may interrupt platform functionality. Instructions for managing cookies in popular browsers are available from the browser's official help documentation.

Security Measures

sor77 implements a layered security architecture to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. Our technical and organisational security measures include:

• 256-bit SSL/TLS encryption on all data transmissions between your device and our servers;
• At-rest encryption for all stored personal and financial data;
• Role-based access controls ensuring that only authorised personnel with a legitimate need can access player data;
• Continuous intrusion detection and monitoring across all platform infrastructure;
• Regular penetration testing conducted by independent third-party security specialists;
• Multi-factor authentication required for all administrative access to systems holding player data.

Your Data Rights

Subject to applicable law, you hold the following rights in relation to the Personal Data that sor77 holds about you. To exercise any of these rights, contact our support team at [email protected]. We will acknowledge your request within 48 hours and aim to fulfil it within 30 calendar days.

Children & Minors

If you believe that a minor has accessed sor77 and provided Personal Data, please contact us immediately at [email protected] so that we can take prompt remedial action.

Third-Party Links

The sor77 platform may contain links to game studio landing pages, payment provider portals, or other third-party resources. This Privacy Policy applies solely to data processed by sor77 and does not extend to any third-party website or service. We encourage you to review the privacy policies of any third-party service you access through or in connection with the sor77 platform.

sor77 is not responsible for the privacy practices, data security, or content of third-party websites, and cannot accept liability for any data processing conducted by those third parties on their own platforms.

Updates to This Privacy Policy

sor77 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the services we offer. The most current version of this Policy will always be available at sor77.cam/privacy-policy, with the "Last Updated" date revised accordingly.

Where a change to this Policy is material — for example, a new category of data being collected or a new third-party processor being engaged — sor77 will provide at least seven (7) days' advance notice by email to your registered address. Your continued use of the sor77 platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, please close your account and cease using the platform.

Contact & Complaints

For any question, concern, or request relating to this Privacy Policy or sor77's handling of your Personal Data, please contact our support team through one of the following channels:

• Live Chat: Available 24/7 directly within the sor77 platform — the fastest route to a response, typically within five minutes.
• Email: support@sor77.cam — responses typically within four (4) hours.

All privacy-related requests should include your registered username and a clear description of your request or concern. We will acknowledge all requests within 48 hours and aim to resolve them within 30 calendar days. Support is available in both English and Indonesian.

If you are not satisfied with how sor77 has handled your privacy concern, you have the right to escalate your complaint to the relevant data protection authority under whose jurisdiction sor77's licence is granted. Details of the applicable supervisory authority are available on request from our support team.