Privacy Policy

This Privacy Policy ("Policy") describes how sip69 — the online betting platform accessible at sip69.cam and operated by the Operator — collects, processes, stores, and protects the personal data of individuals who access or use the Platform ("Members", "you", "your").

This Policy applies to all personal data collected through the Platform, including via the website, any mobile-optimized interface, customer support communications, and any other channel through which you interact with sip69. It applies regardless of your location, though it is specifically designed to meet the expectations of Members primarily based in Indonesia.

This Policy should be read alongside sip69's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of a conflict between this Policy and the Terms & Conditions on matters of data handling, this Policy takes precedence.

sip69 acts as the data controller in respect of personal data collected directly from Members through the Platform. Where data is processed by third-party service providers (payment processors, game studios, fraud prevention services), those providers act as data processors under contract with sip69 and are bound by data protection obligations consistent with those described in this Policy.

In this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — i. e., any data that can directly or indirectly identify you as an individual.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, the Operator of sip69.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a contractual arrangement.
• "Cookies" means small text files placed on your device by the Platform to store session information, preferences, and usage analytics.
• "KYC" means Know Your Customer — the identity and age verification process mandated by the Operator prior to processing any withdrawal.
• "Platform" means the sip69 website at sip69.cam, its mobile-optimized interface, and all related services.
• "Sensitive Data" means a subset of Personal Data that warrants heightened protection, including government-issued identity document numbers, financial account details, and any health-related information provided in the context of responsible gaming self-assessments.

sip69 collects only the data that is necessary and proportionate to the purposes described in this Policy. The categories of Personal Data we collect include:

sip69 collects Personal Data through the following channels:

• Direct submission: Data you provide when completing the registration form, submitting KYC documents, initiating a deposit or withdrawal, contacting customer support, or responding to a survey or promotion.
• Automated technical collection: Data gathered automatically as you navigate the Platform, including via cookies, web beacons, server logs, and similar tracking technologies. See Clause 8 for full cookie details.
• Third-party payment providers: Transaction confirmation data (amount, timestamp, payment method reference) received from BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, and LinkAja when you initiate a financial transaction.
• Identity verification services: Confirmation signals from third-party KYC and fraud-screening providers engaged to verify the authenticity of identity documents submitted during the verification process.
• Responsible gaming assessments: Any voluntary information you provide when using self-assessment tools, setting limits, or requesting self-exclusion through the Platform's responsible gaming features.

sip69 processes your Personal Data only where a valid legal basis exists. The applicable bases are:

• Contractual necessity: Processing required to open and manage your Account, verify your identity, process deposits and withdrawals, settle bets, and deliver customer support — without which the services cannot be provided.
• Legal obligation: Processing required to comply with anti-money laundering (AML) obligations, record-keeping requirements under the Operator's international gaming licence, and any lawful order from a regulatory or law-enforcement authority.
• Legitimate interests: Processing carried out to detect and prevent fraud, improve Platform security, analyse aggregated usage patterns to develop new features, and manage the Operator's business operations — provided these interests are not overridden by your fundamental rights.
• Consent: Processing for optional purposes — specifically, sending you promotional communications by email or in-app notification about bonuses, seasonal offers (such as Idul Fitri or Chinese New Year promotions), and new game launches. You may withdraw consent at any time by updating your Account preferences or contacting support.

sip69 uses your Personal Data for the following specific purposes, each tied to a legal basis identified in Clause 5:

• Account creation and management: Creating your Account, verifying your identity and age (21+), maintaining Account records, and enabling you to log in securely.
• Transaction processing: Receiving and crediting deposits in IDR via your chosen local bank or e-wallet; processing withdrawal requests to your verified payment account; maintaining a full and accurate transaction ledger.
• KYC and fraud prevention: Verifying that your identity documents are authentic, confirming you are not operating duplicate accounts, and screening transactions against AML risk indicators.
• Responsible gaming compliance: Applying the deposit limits, session timers, loss limits, and self-exclusion periods you have set; monitoring for behavioural patterns that may indicate problem gambling; and proactively reaching out where required under the Platform's duty-of-care obligations.
• Customer support: Investigating and resolving Account queries, technical issues, payment disputes, and complaints submitted via live chat or email.
• Platform improvement: Analysing aggregated, de-identified usage data to identify performance bottlenecks, improve user experience, and develop new features.
• Marketing communications (consent-based): Sending you personalised bonus offers, promotional newsletters, and event-specific campaigns — only where you have opted in. You may opt out at any time.
• Legal and regulatory compliance: Retaining records as required by the Operator's licence obligations; responding to lawful requests from competent authorities.

sip69 does not sell, rent, or trade your Personal Data to any third party for their own commercial purposes. Data is shared only in the following circumstances and only to the minimum extent necessary:

• Payment processors and banks: Your name, account details, and transaction amount are shared with BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, or LinkAja solely to execute your requested deposit or withdrawal.
• KYC and identity verification providers: Your identity documents and biometric data (if applicable) are shared with contracted verification service providers for the sole purpose of confirming your identity and age.
• Game studio providers: A pseudonymous player identifier (not your name or contact data) is shared with game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft to enable gameplay, log results, and settle winnings.
• Fraud and security services: Technical identifiers (IP address, device fingerprint, session data) are shared with fraud-prevention platforms to detect bot activity, multi-accounting, and financial crime.
• Legal and regulatory authorities: Where required by applicable law, a valid court order, or a lawful request from a regulatory authority, sip69 will disclose Personal Data to the extent legally mandated. We will notify you of such disclosure where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of the Operator's business assets, your Personal Data may be transferred to the acquiring entity. You will be notified in advance, and the acquiring entity will be bound by obligations consistent with this Policy.

sip69 uses cookies and similar tracking technologies to ensure the Platform operates correctly, to analyse how Members use the Platform, and — where consent has been given — to personalise your experience.

You can manage cookie preferences at any time through your Account settings or by adjusting your browser settings to block or delete cookies. Note that disabling strictly necessary cookies will prevent core Platform functionality from operating correctly.

sip69 retains Personal Data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law and the Operator's licence obligations. The following indicative retention periods apply:

• Account and KYC records: Retained for a minimum of 5 years following Account closure, in compliance with AML record-keeping obligations under the Operator's international licence.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction, including deposit and withdrawal ledger entries.
• Customer support communications: Retained for 3 years from the date of last interaction, to allow reference in the event of a subsequent dispute.
• Marketing preference records: Retained for the duration of your Account and for 1 year following Account closure, to evidence consent and respect opt-out requests.
• Technical and usage logs: Retained for 12 months in an identifiable form; thereafter aggregated and de-identified for long-term analytics purposes.

On expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Where anonymisation is not technically feasible, the data is archived with strictly restricted access.

sip69 implements a layered security architecture designed to protect your Personal Data against unauthorized access, disclosure, alteration, and destruction. Key technical and organizational measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your browser or device and sip69 servers, ensuring that your login credentials, financial data, and personal information cannot be intercepted in transit.
• Encrypted data storage: Sensitive Data at rest — including identity document scans and financial account identifiers — is stored using AES-256 encryption on access-controlled infrastructure.
• Access controls: Access to Personal Data is restricted on a strict need-to-know basis. Staff with access undergo background checks and mandatory data privacy training. All access events are logged and audited.
• Two-factor authentication (2FA): Available to all Members as an additional layer of Account login security. Strongly recommended for all accounts with an active Balance.
• Intrusion detection and monitoring: Continuous automated monitoring of Platform infrastructure for anomalous access patterns, brute-force attempts, and data exfiltration indicators.
• Third-party security audits: The Platform undergoes periodic security assessments conducted by independent cybersecurity professionals.

In the event of a data breach that poses a risk to your rights and freedoms, sip69 will notify affected Members without undue delay and will take all reasonable steps to contain and remediate the incident.

As a Member of sip69, you have the following rights in relation to your Personal Data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We will respond within 30 days of receiving a valid request.

Please note that certain rights — particularly the right to erasure — may be limited where sip69 is required to retain data to comply with AML obligations, licence conditions, or an ongoing legal dispute. We will always explain our reasoning clearly if a request cannot be fulfilled in full.

sip69 is an internationally operated platform. Your Personal Data may be transferred to, stored on, and processed by servers or service providers located outside Indonesia. This includes the Operator's primary hosting infrastructure and contracted third-party processors such as KYC verification services and fraud screening platforms.

Wherever Personal Data is transferred internationally, sip69 takes appropriate safeguards to ensure the data receives a level of protection consistent with the standards described in this Policy. These safeguards include contractual data processing agreements that impose equivalent data protection obligations on all processors, regardless of their location.

By creating an Account on sip69 and using the Platform, you acknowledge that your Personal Data may be transferred internationally as described in this clause.

sip69 is strictly an adults-only platform. The Platform is not directed at, and does not knowingly collect Personal Data from, any person under the age of 21. In Indonesia, sip69 enforces a minimum age requirement of 21 years for all Account registrations.

If sip69 becomes aware that Personal Data has been collected from a person under the age of 21, the Account will be immediately suspended, all associated data will be securely deleted to the extent permitted by law, and any Balance will be handled in accordance with applicable regulatory guidelines.

If you are a parent or guardian and believe that a minor under your care has registered an Account on sip69, contact us immediately at [email protected] so that we can take prompt action.

The sip69 Platform may contain references to or integrations with third-party services — including payment providers' interfaces and game studio environments — that operate under their own distinct privacy policies. sip69 is not responsible for the data practices of these third parties once you leave the sip69 Platform environment or interact directly with a third-party interface.

We encourage you to review the privacy policies of any third-party service you interact with through or in connection with sip69, particularly those of your bank or e-wallet provider, as their data practices are governed independently of this Policy.

sip69 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, new legal requirements, or improvements to the Platform. The effective date at the top of this page will be updated whenever a substantive revision is made.

For material changes — those that significantly affect how your Personal Data is used or your rights in relation to it — sip69 will provide advance notice via a prominent in-platform notification or by email to your registered address. For non-material updates (such as clarifications of existing practices or formatting corrections), we may update the Policy without separate notification beyond updating the effective date.

Your continued use of the Platform following the effective date of any revision constitutes acceptance of the revised Policy. If you do not accept the revised Policy, you may close your Account and request withdrawal of your real-money Balance prior to the effective date.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the sip69 Data Privacy team through the following channels:

• Email: [email protected] — use the subject line "Privacy Inquiry" or "Data Rights Request" for fastest routing
• Live Chat: Available 24/7 via the Platform — ask to be connected to the Data Privacy team
• Response Time: We aim to acknowledge all data-related requests within 48 hours and to provide a full response within 30 calendar days
• Service Hours: 24/7, all times in WIB (UTC+7), including all Indonesian public holidays

If you are not satisfied with our response to a data rights request or a privacy complaint, you have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction.