Privacy Policy — How ino77 Protects Your Personal Data

This Privacy Policy ("Policy") is issued by ino77 ("ino77", "we", "us", "our") and applies to all personal data collected from individuals ("you", "your", "Member") who access, register with, or otherwise interact with the ino77 online betting and casino platform accessible at https://ino77.pro ("the Platform").

ino77 is committed to protecting the privacy and personal data of all Members in accordance with applicable international data protection principles, including the standards set out under widely recognised frameworks such as the General Data Protection Regulation (GDPR) and equivalent international best-practice guidelines. While ino77 serves an Indonesian market, our data protection practices are designed to meet the highest internationally recognised standards.

This Policy covers:

• All personal data collected via the Platform, including via desktop browsers, mobile browsers, and any future downloadable applications;
• Personal data collected through our customer support channels, including live chat, email, and WhatsApp;
• Personal data collected as part of our Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance processes;
• Behavioural and technical data collected automatically through cookies, analytics tools, and device fingerprinting.

If you do not agree with the terms of this Privacy Policy, you must not register for or use the ino77 Platform. By registering an account or continuing to use the Platform, you confirm that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, national identity number, bank account details, IP address, device identifiers, and behavioural data that can be linked to an individual.
• "Processing" — any operation performed on Personal Data, whether by automated or manual means, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, combination, restriction, erasure, or destruction.
• "Data Controller" — ino77, which determines the purposes and means of processing your Personal Data.
• "Data Processor" — a third party that processes Personal Data on behalf of ino77 under a written agreement and subject to ino77's instructions (e.g., payment processors, cloud infrastructure providers, KYC verification vendors).
• "Sensitive Personal Data" — a subset of Personal Data that warrants heightened protection, including government-issued identification numbers (KTP), financial account credentials, and health-related information submitted in connection with responsible gaming self-exclusion requests.
• "Consent" — a freely given, specific, informed, and unambiguous indication of agreement to the processing of your Personal Data for a stated purpose.
• "KYC" (Know Your Customer) — the identity verification process conducted by ino77 in accordance with AML compliance requirements, involving the review of government-issued identification and supporting documents.

ino77 collects the following categories of personal data from Members and Platform visitors. The specific data points collected depend on how you interact with the Platform.

3.1 Registration Data

When you create a member account on ino77, we collect:

• Full legal name (as it appears on your government-issued identity document);
• Date of birth (to verify that you are 21 years of age or older);
• Email address;
• Mobile phone number (used for account security, transaction alerts, and optional WhatsApp support);
• Chosen username and encrypted password;
• City and province of residence within Indonesia (e.g., Jakarta, Surabaya, Bandung, Bali, Yogyakarta, Medan, Semarang, Makassar).

3.2 KYC Verification Data

To comply with our AML obligations and to verify your eligibility to use the Platform, we collect:

• Copies of government-issued identity documents — Indonesian National Identity Card (KTP), passport, or driving licence;
• Proof of residential address (e.g., recent utility bill or bank statement issued within the past three months);
• Proof of payment method ownership (e.g., a bank account statement from BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI, or OCBC NISP, or a screenshot of a registered OVO, DANA, GoPay, ShopeePay, or LinkAja account confirming your name);
• Selfie or liveness-check image, where required by our KYC verification partner.

3.3 Financial Transaction Data

• Deposit and withdrawal amounts, timestamps, and payment method references;
• Bank account numbers and e-wallet identifiers associated with your transactions;
• Transaction history maintained for regulatory and audit purposes.

3.4 Betting & Gaming Activity Data

• Bet placements, stake amounts, odds accepted, and settlement outcomes across all ino77 products (sportsbook, live casino, slot games, togel (Indonesia's traditional numbers lottery) draws, and other gaming products);
• Session duration and frequency of play;
• Game preference and category interaction history (used for responsible gaming monitoring and personalisation).

3.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser version;
• Unique device identifiers and fingerprint data (used for fraud prevention and duplicate account detection);
• Cookie data and session tokens (see Clause 8 for full cookie disclosure).

3.6 Customer Support Communications

• Records of live chat conversations, emails, and WhatsApp exchanges between you and the ino77 support team;
• Complaint and dispute correspondence and resolution records.

ino77 collects personal data through the following methods:

4.1 Directly from You

The majority of your personal data is collected directly from you when you:

• Complete the ino77 account registration form;
• Submit documents as part of the KYC verification process;
• Make a deposit, request a withdrawal, or link a payment method to your account;
• Contact ino77 customer support via live chat, email (support@ino77.pro), or WhatsApp (+62 811 0077 777);
• Participate in a promotion, bonus programme, or player survey;
• Update your account profile or security settings.

4.2 Automatically Through the Platform

When you visit or use the ino77 Platform, certain technical and behavioural data is collected automatically through:

• Server logs that record your IP address, page requests, timestamps, and referring URLs;
• Cookies and similar tracking technologies placed on your browser or device (see Clause 8);
• Device fingerprinting tools used for fraud prevention and multi-account detection;
• Analytics tools that aggregate user behaviour data to help us improve Platform performance and user experience.

4.3 From Third Parties

In limited circumstances, ino77 may receive personal data about you from authorised third parties, including:

• KYC and identity verification service providers, who return a verification status and summary of the documents you submitted to them on our behalf;
• Payment processors and banking partners, who may confirm transaction status or flag suspicious payment activity;
• Fraud prevention and anti-money laundering screening databases, which may return a risk score or match against watchlists relevant to our compliance obligations.

ino77 processes your personal data only where a valid legal basis exists. The table below summarises the primary legal bases on which we rely for the main categories of processing activity:

Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent for marketing communications, contact our support team via live chat or email.

ino77 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your ino77 member account, including processing your registration, managing your balance, recording your transaction history, and enforcing account security settings such as two-factor authentication.
• Identity & Eligibility Verification: To verify that you are at least 21 years of age, are a resident of Indonesia, and are otherwise eligible to use the Platform in accordance with our Terms & Conditions.
• Payment Processing: To process your deposit and withdrawal instructions through your nominated bank account (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI, OCBC NISP) or e-wallet (GoPay, OVO, DANA, ShopeePay, LinkAja).
• AML & Fraud Prevention: To monitor transactions and account behaviour for indicators of money laundering, terrorist financing, bonus abuse, multi-accounting, and other fraudulent or prohibited activities.
• Responsible Gaming: To monitor your gaming activity patterns against responsible gaming indicators, to action self-exclusion or cooling-off requests, and to reach out proactively where our systems identify potential signs of problem gambling.
• Customer Support: To respond to your enquiries, process complaints, and resolve disputes across our live chat, email, and WhatsApp support channels.
• Promotions & Bonuses: To administer bonus programmes, free bet offers, cashback promotions, and other incentive schemes available to eligible members.
• Legal & Regulatory Compliance: To fulfil our obligations under applicable law and our international licensing requirements, including maintaining records and responding to lawful requests from competent authorities.
• Platform Improvement: To analyse aggregated usage data, identify technical issues, and improve the performance, security, and user experience of the ino77 Platform.
• Marketing Communications (with consent): To send you information about new games, promotions, seasonal bonuses (for example, in connection with Idul Fitri, Independence Day, or other Indonesian cultural occasions), and platform updates — but only where you have opted in to receive such communications.

ino77 does not sell, rent, or trade your personal data to any third party. We share your personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

• KYC & Identity Verification Providers: We share your identity documents and personal details with authorised third-party KYC verification service providers who conduct verification checks on our behalf under strict data processing agreements.
• Payment Processing Partners: We share transaction-relevant data with the payment processors, banks, and e-wallet platforms that facilitate your deposits and withdrawals. These partners receive only the information required to execute the specific transaction.
• Game Content Providers: Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive session tokens and anonymised gameplay identifiers necessary to deliver their game content. These providers do not receive your full personal profile.
• Fraud Prevention & AML Screening Services: We may share data points with third-party compliance screening services to match against sanctions lists, politically exposed person (PEP) databases, and fraud risk registries.
• Cloud Infrastructure & Hosting Providers: Your data is stored on servers managed by enterprise-grade cloud infrastructure providers under contractual data processing agreements that require them to maintain security standards equivalent to those we apply ourselves.
• Regulatory & Law Enforcement Authorities: We will disclose personal data to competent government authorities, law enforcement agencies, or courts where we are required to do so by applicable law, court order, or as part of our licensing obligations — without prior notice to you where the law prohibits such notice.
• Professional Advisers: Our legal counsel, auditors, and compliance consultants may access personal data on a strictly need-to-know basis and are bound by professional confidentiality obligations.

Where ino77 shares data with Data Processors, those processors are contractually required to process your data only on our documented instructions, to implement appropriate security measures, and to delete or return your data upon termination of the processing relationship.

ino77 uses cookies and similar tracking technologies to deliver a functional, secure, and personalised experience on the Platform. This clause explains what we use, why we use it, and how you can control it.

8.1 What Are Cookies?

Cookies are small text files that a website stores on your browser or device when you visit. They allow the website to recognise your device on subsequent visits, remember your preferences, and monitor usage patterns.

8.2 Types of Cookies We Use

8.3 Managing Your Cookie Preferences

You may control or delete cookies at any time through your browser settings. Most modern browsers allow you to block all cookies, accept only certain cookies, or delete existing cookies. Please note that disabling strictly necessary cookies will prevent you from logging in to your ino77 account and may cause core Platform features to malfunction. Performance and functionality cookies may be disabled without affecting core access.

For detailed guidance on managing cookies in your specific browser, refer to the help documentation for Chrome, Firefox, Safari, Edge, or the browser you use.

ino77 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and our licensing obligations. The table below sets out our standard retention periods for the main categories of personal data:

Where a legal hold is placed on data — for example, because an account is subject to an active investigation or litigation — the standard retention period is suspended and data will be retained until the hold is lifted.

Upon expiry of the applicable retention period, personal data is securely and irreversibly deleted or anonymised so that it can no longer be linked to an identified individual.

As an ino77 member, you hold the following rights with respect to your personal data. To exercise any of these rights, please contact us using the details in Clause 12. We will respond to all valid requests within 30 calendar days.

• Right of Access: You have the right to request a copy of the personal data that ino77 holds about you and to receive information about how it is being processed. We will provide this in a structured, commonly used electronic format.
• Right to Rectification: If your personal data is inaccurate or incomplete, you have the right to request that we correct or complete it without undue delay.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw your consent (where processing was based on consent), or where you object to processing and there are no overriding legitimate grounds. This right is subject to our legal obligations to retain certain data as described in Clause 9.
• Right to Restrict Processing: In certain circumstances — for example, while a rectification request is under review — you may request that ino77 restrict the processing of your personal data.
• Right to Data Portability: Where processing is based on your consent or on the performance of a contract and is carried out by automated means, you may request that your personal data be provided to you in a machine-readable format, or transferred directly to another controller where technically feasible.
• Right to Object: You may object to the processing of your personal data where ino77 relies on legitimate interests as the legal basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

ino77 implements a comprehensive, layered security programme designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• Encryption in Transit: All communications between your device and the ino77 Platform are encrypted using TLS 1.3. This applies to login, registration, deposits, withdrawals, and all other Platform interactions.
• Encryption at Rest: Sensitive personal data — including KYC documents, financial account identifiers, and password hashes — is encrypted at rest using AES-256 encryption on our database infrastructure.
• Access Controls: Access to personal data within ino77's internal systems is restricted on a need-to-know basis. Staff who handle personal data receive regular data protection training and are subject to contractual confidentiality obligations.
• Two-Factor Authentication: ino77 offers two-factor authentication (2FA) to all members. We strongly recommend enabling 2FA in your account security settings to add an additional layer of protection to your account.
• Penetration Testing & Security Audits: ino77's Platform and infrastructure are subject to regular independent penetration testing and security audits conducted by qualified third-party security professionals.
• Incident Response: ino77 maintains a documented data breach response procedure. In the event of a security incident that is likely to result in a high risk to your rights, we will notify affected members without undue delay and take immediate steps to contain the incident and prevent recurrence.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way ino77 handles your personal data, please contact us through any of the following channels:

• Live Chat: Available 24/7 directly on the ino77 Platform. Live chat is the fastest way to reach our support team for general privacy enquiries.
• Email: support@ino77.pro — for formal data rights requests, please use the subject line "Data Rights Request" and include your registered username and the nature of your request. We aim to respond within 24 hours and will action valid requests within 30 calendar days.
• WhatsApp: +62 811 0077 777 — available during extended support hours (WIB, UTC+7).

Our support team includes native Indonesian-speaking agents and is available around the clock, 365 days a year, including during Indonesian public holidays such as Idul Fitri, Nyepi, and Independence Day (17 August).

12.1 Formal Complaints

If you believe that ino77 has not handled your personal data in accordance with this Privacy Policy or applicable data protection principles, you have the right to lodge a formal complaint. Please submit your complaint in writing by email to support@ino77.pro with the subject line "Privacy Complaint". ino77 will acknowledge your complaint within 24 hours and provide a substantive written response within 15 business days.

12.2 Policy Updates

ino77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform functionality. When we make material changes, we will notify active members by posting a prominent notice on the Platform and, where appropriate, by sending an email notification to your registered address. The "Effective Date" at the top of this Policy will be updated to reflect the date on which the revised version takes effect. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the updated Policy.