Privacy Policy — sma77

Introduction & Scope

This Privacy Policy ("Policy") describes how sma77 ("sma77", "we", "us", "our"), operating at the domain sma77.cam, collects, uses, stores, discloses, and protects the personal information of individuals ("you", "your", "User") who access or use the sma77 online gaming platform, including all associated website pages, mobile-optimized interfaces, and support services.

This Policy applies to all personal data processed in connection with your use of sma77, regardless of whether you are a registered member, a prospective member browsing our platform, or a visitor who contacts our customer support team. It covers data collected through the sma77 website, live chat interactions, and email communications.

This Policy should be read alongside the sma77 Terms & Conditions, which govern the contractual relationship between you and sma77. In the event of a conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy prevails.

Data Controller

For the purposes of applicable data protection law, sma77 acts as the data controller in respect of all personal data collected through the sma77 platform. This means sma77 determines the purposes for which your personal data is processed and the means by which it is processed.

Where sma77 engages third-party service providers to process personal data on its behalf — for example, payment processors, identity verification providers, or customer support software vendors — those parties act as data processors under sma77's instruction and are subject to contractual data processing agreements that impose obligations equivalent to those described in this Policy.

Questions, requests, and complaints relating to the handling of your personal data should be directed to sma77's data privacy contact point at [email protected] (plain text — not a clickable link).

Data We Collect

sma77 collects personal data through several channels. The categories of data we collect, and the context in which each is collected, are set out below.

3.1 Data Provided Directly by You

3.2 Data Collected Automatically

When you access the sma77 platform, our servers and analytics systems automatically collect the following technical data:

• Device and Browser Data: Device type, operating system, browser type and version, screen resolution.
• Network Data: IP address, internet service provider (ISP), approximate geographic location derived from IP.
• Usage Data: Pages visited, time spent on each page, click paths, search queries within the platform, game sessions initiated, and session duration.
• Transaction Data: Deposit and withdrawal history, bet placement history, game play records, bonus redemption records.
• Cookie Data: See Section 7 (Cookies & Tracking) for full details.

3.3 Data from Third Parties

sma77 may receive personal data about you from the following third-party sources:

• Payment Processors: Transaction confirmation data from BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and other supported payment providers.
• Identity Verification Providers: Validation results from KYC/AML screening services used to confirm the authenticity of documents you submit.
• Fraud Prevention Services: Risk-scoring data from third-party fraud detection systems that help sma77 identify and prevent unauthorized account activity.

How We Use Your Data

sma77 uses the personal data described in Section 3 for the following purposes:

• Account Administration: Creating and managing your sma77 member account, authenticating your identity at login, and maintaining accurate account records.
• Service Delivery: Processing your deposits and withdrawals, crediting and debiting wagers, settling bets, and delivering bonuses and promotional credits to your account.
• Identity and Age Verification (KYC): Confirming that you are who you claim to be and that you meet the 21+ age eligibility requirement for sma77 membership.
• Fraud Prevention and Security: Detecting and preventing unauthorized access, fraudulent transactions, multi-accounting, and other prohibited conduct as described in the Terms & Conditions.
• Anti-Money Laundering (AML) Compliance: Monitoring transaction patterns for indicators of money laundering or other financial crime, and fulfilling mandatory reporting obligations where applicable.
• Customer Support: Responding to your queries, resolving disputes, and maintaining records of support interactions for quality assurance and follow-up purposes.
• Responsible Gaming: Identifying behavioral patterns that may indicate problem gambling and, where appropriate, applying protective measures such as contacting affected users or enforcing account restrictions.
• Platform Improvement: Analyzing aggregated usage data to understand how members interact with sma77, identify areas for improvement, and inform product development decisions.
• Communications: Sending you transactional communications (e.g., deposit confirmations, withdrawal notifications, KYC status updates) and, where you have consented, marketing communications about promotions and offers on sma77.
• Legal Compliance: Meeting obligations imposed by applicable laws, including responding to lawful requests from competent authorities.

Legal Bases for Processing

sma77 processes your personal data on the following legal bases, depending on the purpose of processing:

• Contractual Necessity: Processing your identity data, financial data, and account credentials is necessary to perform the contract between you and sma77 — specifically, to operate your account and deliver the services you have requested.
• Legal Obligation: Processing related to KYC verification, AML monitoring, and record-keeping is required to comply with applicable legal and regulatory obligations. This processing cannot be opted out of — it is a condition of maintaining an sma77 account.
• Legitimate Interests: Processing for fraud prevention, platform security, and platform improvement is carried out on the basis of sma77's legitimate interests in operating a secure and well-functioning service, balanced against your rights and interests.
• Consent: Where sma77 sends you optional marketing communications or uses non-essential cookies, we do so on the basis of your consent, which you may withdraw at any time as described in Section 7 and Section 9 of this Policy.

Data Sharing & Disclosure

sma77 does not sell, rent, or commercially exchange your personal data with any third party. We share personal data only in the circumstances described below:

• Payment Service Providers: We share the minimum necessary financial data with BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and other payment partners to process your deposits and withdrawals. These providers are contractually bound to use your data only for payment processing purposes.
• Identity Verification Providers: KYC document data is shared with accredited identity verification services to confirm the authenticity of submitted documents. These providers process data on sma77's behalf under data processing agreements.
• Fraud Prevention and AML Services: Anonymized or pseudonymized data may be shared with fraud detection and anti-money laundering screening services to identify and prevent financial crime.
• Customer Support Platforms: Support interaction data is processed by our customer service software provider, which operates under a data processing agreement with sma77.
• Legal and Regulatory Authorities: sma77 will disclose personal data to law enforcement agencies, regulatory authorities, or courts where required to do so by applicable law, or where we have a good-faith belief that such disclosure is necessary to prevent or respond to criminal activity or protect the rights, property, or safety of sma77 or others.
• Corporate Transactions: In the event of a merger, acquisition, or sale of substantially all of sma77's assets, personal data held by sma77 may be transferred to the acquiring entity, subject to equivalent privacy protections.

Cookies & Tracking Technologies

sma77 uses cookies and similar tracking technologies on the platform. Cookies are small text files stored on your device that help the platform function correctly, remember your preferences, and gather analytical information about how the platform is used.

The types of cookies sma77 uses are as follows:

• Strictly Necessary Cookies: These cookies are essential for the platform to function and cannot be disabled. They include session authentication cookies, security tokens, and cookies that remember your language and currency preferences.
• Performance and Analytics Cookies: These cookies collect anonymized information about how visitors use the platform — which pages are visited most frequently, where users encounter errors, and how users navigate between sections. This data helps sma77 improve platform performance and usability.
• Functional Cookies: These cookies remember your account preferences, such as your chosen game view, display settings, and responsible gaming configuration, to provide a more personalized experience on subsequent visits.
• Marketing Cookies: Where you have consented, sma77 may use cookies to identify when you have visited the platform and to tailor any promotional communications to your preferences and activity history.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent core platform functions from operating correctly. For non-essential cookies, you may withdraw consent at any time via your browser or by contacting sma77 support.

Data Retention

sma77 retains personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal obligations, whichever is longer. The following retention principles apply:

• Active Account Data: Identity data, contact data, and account credentials are retained for the full duration of your active membership with sma77.
• KYC and Compliance Records: Identity verification documents, AML screening records, and transaction histories are retained for a minimum of five years following account closure, in accordance with standard anti-money laundering record-keeping obligations.
• Financial Transaction Records: Deposit, withdrawal, and betting records are retained for a minimum of five years following each transaction for accounting, dispute resolution, and regulatory compliance purposes.
• Customer Support Records: Live chat transcripts and support email records are retained for three years following the closure of the relevant support case.
• Marketing Data: Where you have consented to marketing communications, your contact data is retained for marketing purposes until you withdraw consent or request deletion, subject to the minimum legal retention periods above.

After the applicable retention period expires, personal data is securely deleted or anonymized in accordance with sma77's data disposal procedures. Anonymized data (from which you cannot be identified) may be retained indefinitely for aggregate statistical and platform improvement purposes.

Your Rights

Subject to applicable law and the limitations described below, you have the following rights in respect of your personal data held by sma77:

To exercise any of the above rights, please contact sma77's data privacy team via the live chat function on the platform or by email at [email protected]. We will respond to all rights requests within 30 calendar days of receipt. We may require you to verify your identity before processing a rights request, to protect against unauthorized requests by third parties.

Where sma77 is unable to fulfill a request — for example, where legal retention obligations prevent erasure — we will explain the reason in writing and advise on any available avenues for further recourse.

Data Security

sma77 implements a multi-layered technical and organizational security framework to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• Transport Encryption: All data transmitted between your device and sma77 servers is protected by TLS 1.2 or TLS 1.3 encryption. HTTP connections are automatically redirected to HTTPS.
• Storage Encryption: Personal data stored on sma77's infrastructure is encrypted at rest using AES-256 encryption. Database access requires multi-factor authentication from authorized personnel only.
• Access Controls: Access to personal data is restricted to sma77 staff and contractors with a documented operational need. Role-based access controls and audit logging ensure that data access is traceable and accountable.
• Password Security: Account passwords are hashed using industry-standard one-way hashing algorithms (bcrypt). sma77 staff cannot view your password in plain text.
• Penetration Testing: sma77's platform undergoes periodic independent security assessments to identify and address vulnerabilities before they can be exploited.
• Incident Response: sma77 maintains a documented data breach response procedure. In the event of a material breach affecting your personal data, we will notify you in accordance with applicable breach notification obligations.

While sma77 takes all reasonable steps to protect your data, no security system is entirely immune to attack. You are also responsible for your own account security — please use a strong, unique password for your sma77 account and do not share your credentials with others.

Minors & Age Policy

sma77 is strictly an adults-only platform. You must be at least 21 years of age to register an account and use any feature of the sma77 service. We do not knowingly collect personal data from individuals under the age of 21.

As part of the account registration and KYC process, sma77 requires all members to verify their date of birth by submitting government-issued identity documentation. Where sma77 identifies or suspects that a registered user is under 21 years of age, the relevant account will be suspended immediately, all activity will be voided, and any funds deposited will be returned to the source payment method following investigation.

If you are a parent or guardian and believe that a person under 21 has created an sma77 account without authorization, please contact our support team immediately via live chat or at [email protected]. We will investigate and take appropriate action promptly.

Third-Party Links

The sma77 platform may contain references to third-party services — such as linked payment providers or identity verification partners — in the course of delivering the sma77 service. Where you are directed to a third-party website or interface to complete a transaction, that third party's own privacy policy governs the handling of any data you submit directly to them.

sma77 is not responsible for the privacy practices of third-party websites or services that are not operated by sma77. We encourage you to review the privacy policies of any third-party service with which you interact in connection with your sma77 account.

International Data Transfers

sma77's infrastructure and the infrastructure of some of its third-party service providers may be located in jurisdictions other than Indonesia. When your personal data is transferred outside Indonesia, sma77 takes steps to ensure that an adequate level of protection is maintained, including by:

• Entering into data processing agreements with third-party recipients that impose data protection obligations no less stringent than those described in this Policy.
• Applying technical and organizational security measures to data in transit to the standards described in Section 10 of this Policy.
• Conducting due diligence on third-party recipients to confirm their data protection practices before establishing a data-sharing relationship.

By using sma77, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Indonesia, subject to the protections described above.

Changes to This Policy

sma77 reserves the right to update or amend this Privacy Policy at any time. When we make material changes to this Policy, we will notify you via the email address registered to your sma77 account and will update the "Last Updated" date at the top of this document.

Where a proposed change materially affects your privacy rights or how we use your data in a way that requires renewed consent, we will request that consent explicitly before the change takes effect. For non-material administrative updates, your continued use of the sma77 platform following the effective date of the revised Policy constitutes your acknowledgment of the changes.

The most current version of this Privacy Policy is always available at sma77.cam/privacy-policy. We encourage you to review this page periodically to stay informed of any updates.

Contact & Complaints

If you have any questions, concerns, or complaints about how sma77 handles your personal data, or if you wish to exercise any of the rights described in Section 9, please contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, via the sma77 platform. This is the fastest way to reach our team for data privacy queries.
• Email: [email protected] — subject line "Privacy Request — [Your Username]". We aim to respond to all privacy-related emails within 5 business days.
• Service Hours: 24 hours / 7 days per week, Western Indonesia Time (WIB, UTC+7).

For formal complaints regarding sma77's data processing practices, please submit your complaint in writing to the email address above with the subject line "Formal Privacy Complaint — [Your Username]", providing a full description of your concern and any supporting information. sma77 will acknowledge receipt within 48 hours and aim to provide a substantive written response within 15 business days.

sma77 is committed to resolving privacy concerns promptly and fairly. If you are not satisfied with our response to a formal complaint, you may escalate your concern to the relevant supervisory authority or dispute resolution body in your jurisdiction.