Privacy Policy — ljo77

Definitions

The following terms carry the meanings set out below throughout this Privacy Policy:

• "ljo77" / "we" / "us" / "our" — the ljo77 platform, its operators, and affiliated entities responsible for processing personal data collected through https://ljo77.lat.
• "Member" / "you" / "your" — any individual who has registered, or is in the process of registering, an account with ljo77, as well as any visitor who browses the Platform without a registered account.
• "Personal Data" — any information that identifies or could reasonably be used to identify a natural person, either on its own or in combination with other available data. This includes name, email address, date of birth, payment account details, IP address, and device identifiers.
• "Processing" — any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission, erasure, or destruction.
• "Platform" — the ljo77 website at https://ljo77.lat, its mobile-optimised interface, and all services, features, and content made available through it.
• "KYC" — Know Your Customer: the mandatory identity and age verification process conducted by ljo77 before a Member's first withdrawal request is processed.
• "Service Partners" — third-party providers engaged by ljo77 to support the delivery of the Platform's services, including payment processors, KYC verification vendors, fraud detection providers, and hosting infrastructure suppliers.
• "Cookies" — small text files placed on a Member's device by the Platform to enable or enhance certain functionality, remember preferences, and collect usage analytics data.

Data Controller

ljo77 acts as the data controller in respect of Personal Data collected from Members and visitors to the Platform. As data controller, ljo77 determines the purposes and means by which your Personal Data is processed.

ljo77 is licensed and regulated internationally. The platform is operated for the benefit of Members located primarily in Indonesia, and all data practices described in this Policy are designed with the needs and expectations of Indonesian players in mind — including alignment with generally accepted data protection principles applicable to internationally licensed gaming operators.

For any data-related query, request, or concern, you may contact our dedicated data support channel at [email protected] with the subject line "Data Protection Request".

Data We Collect

ljo77 collects only the Personal Data that is necessary to provide, maintain, and improve the Services, to verify member identity, to process financial transactions, and to comply with applicable legal and regulatory obligations. The categories of Personal Data we collect are as follows:

3.1 Registration & Account Data

• Full legal name (as it appears on a government-issued identification document);
• Date of birth (to verify the 21+ age requirement);
• Email address (used as your primary account identifier and for account-related communications);
• Chosen username and encrypted password hash;
• Mobile phone number (used for two-factor authentication and account security alerts, where enabled);
• Residential address (collected at KYC verification stage).

3.2 KYC & Identity Verification Data

• A copy of a government-issued photo identification document valid in Indonesia — for example, your KTP (Kartu Tanda Penduduk), driving licence (SIM), or valid passport;
• A screenshot or statement confirming ownership of the payment account (e.g., showing your name and account number with BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, or LinkAja);
• Proof of residential address, where required (e.g., a recent utility bill or bank statement issued within the last three months).

3.3 Financial Transaction Data

• Deposit amounts, dates, and payment method references;
• Withdrawal requests, amounts, and processing status;
• Payment account identifiers (bank account numbers, e-wallet account references — we do not store full card numbers or CVV codes);
• Transaction history within the ljo77 account cashier.

3.4 Gaming & Betting Activity Data

• Bet history, stake amounts, odds, game selections, and outcomes across all ljo77 products (sportsbook, live casino, slots, video poker, and mahjong);
• Session timestamps, duration, and frequency of play;
• Game preferences and responsible gaming settings (deposit limits, session reminders, self-exclusion status).

3.5 Technical & Usage Data

• IP address and approximate geographic location (country / city level — derived from IP, not GPS);
• Device type, operating system, browser type and version;
• Pages visited on the Platform, time spent on each page, referring URL, and exit URL;
• Cookie identifiers and session tokens (see Section 7 for full cookie details);
• Error logs and diagnostic data generated during your use of the Platform.

3.6 Communications Data

• The content of live chat, email, and WhatsApp conversations between you and ljo77 customer support agents;
• Records of promotional communications sent to you and your engagement with them (open rates, click data — where you have opted in to marketing communications);
• Feedback or complaint submissions made through the Platform.

How We Collect Your Data

ljo77 collects Personal Data through the following channels and mechanisms:

• Directly from you: when you complete the ljo77 account registration form, submit KYC documents, make a deposit or withdrawal, place a bet or wager, contact customer support, or update your account preferences;
• Automatically during Platform use: through cookies, server logs, and similar tracking technologies when you navigate the Platform (see Section 7 for details);
• From Service Partners: ljo77 receives identity verification results from our KYC partner, fraud scoring signals from our fraud detection provider, and transaction confirmation data from our payment processing partners. In each case, these transfers are governed by data processing agreements that restrict the partner's use of your data to the specific service being provided;
• From publicly available sources: in certain circumstances, ljo77 may cross-reference information you provide with publicly available records to verify accuracy or detect fraud. This is conducted only where permitted by applicable law and only to the extent necessary for that specific purpose.

Purpose & Legal Basis for Processing

ljo77 processes your Personal Data only where a lawful basis exists for doing so. The table below summarises the primary processing activities, their purposes, and the corresponding legal basis:

Where ljo77 relies on legitimate interest as the legal basis for processing, we have assessed that our interests do not override your fundamental privacy rights, and we take proportionate steps to ensure data is used only to the minimum extent necessary for the stated purpose.

Data Sharing & Disclosure

ljo77 does not sell or rent your Personal Data. We share data with third parties only in the following circumstances:

6.1 Service Partners

ljo77 engages trusted Service Partners to support core platform functions. These partners process your data solely on ljo77's instructions and for the specific purpose for which they were engaged:

• Payment processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, and LinkAja — to execute deposit and withdrawal transactions;
• KYC verification provider: to validate identity documents and confirm age eligibility in support of the 21+ requirement;
• Fraud detection provider: to identify unusual account activity, suspicious transaction patterns, and potential money laundering signals;
• Cloud hosting & infrastructure provider: to store Platform data on secure, access-controlled servers;
• Game software studios: Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, PG Soft, and Spribe — limited session and game-result data is shared with studios as necessary for game functionality and dispute resolution. These studios are bound by their own data processing obligations under contract with ljo77;
• Customer support platform: the provider of ljo77's live chat and support ticketing system, who may process the content of your support conversations on our behalf.

6.2 Legal & Regulatory Disclosure

ljo77 may disclose Personal Data to regulatory authorities, law enforcement agencies, or courts where we are legally required to do so, including in response to a valid court order, subpoena, or regulatory investigation. In such cases, ljo77 discloses only the minimum data necessary to fulfil the legal obligation.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of ljo77's assets, your Personal Data may be transferred to the acquiring entity as part of the transaction. We will notify registered Members of any such transfer by email or in-platform notification before it takes effect, and the acquiring entity will be required to honour this Privacy Policy.

Cookies & Tracking Technologies

ljo77 uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, and collect aggregated analytics data. The following categories of cookies are used:

Most web browsers allow you to manage cookie settings through the browser's preferences menu. Disabling functional or analytics cookies will not prevent you from using ljo77 but may affect certain preference-based features. Disabling strictly necessary or security cookies may impair your ability to log in or use the Platform's core features.

ljo77 does not use third-party advertising cookies. No data collected through cookies on the ljo77 Platform is shared with advertising networks or used for targeted advertising on other websites.

Data Retention

ljo77 retains Personal Data for the period necessary to fulfil the purpose for which it was collected, subject to longer retention periods required by applicable law or regulatory obligation. The following general retention guidelines apply:

• Active account data: retained for the full duration of your membership and for a minimum of five (5) years following account closure, in compliance with applicable AML regulations;
• KYC documents: retained for a minimum of five (5) years following account closure or the completion of the last transaction to which they relate;
• Financial transaction records: retained for a minimum of five (5) years following the date of the transaction;
• Customer support communications: retained for three (3) years from the date of the last communication, to support dispute resolution and service quality review;
• Marketing preferences and opt-in records: retained for the duration of your marketing consent, and deleted within 30 days of you withdrawing consent;
• Technical and usage data (logs): retained for a rolling period of twelve (12) months, after which they are aggregated or permanently deleted;
• Self-exclusion records: retained indefinitely to prevent a self-excluded member from re-registering an account during the exclusion period.

When Personal Data is no longer required and there is no legal obligation to retain it, ljo77 deletes or anonymises it in a secure and irreversible manner.

Your Data Rights

As a ljo77 member, you have the following rights with respect to your Personal Data. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request", including your registered username and a clear description of your request.

• Right of Access: You have the right to request a copy of the Personal Data that ljo77 holds about you. We will provide this within 30 days of receiving a valid request.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may request the deletion of your Personal Data. This right is subject to overriding legal obligations — for example, we are required to retain financial transaction records and KYC documents for a minimum of five years and cannot delete these upon request during the retention period.
• Right to Restrict Processing: You may request that ljo77 restrict the processing of your Personal Data in certain situations, for example while the accuracy of that data is being contested.
• Right to Data Portability: Where technically feasible and where processing is based on your consent or on the performance of a contract, you may request that we provide your Personal Data in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., for marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• Right to Object: You may object to processing of your Personal Data where that processing is based on ljo77's legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

Children & Minors

ljo77 operates an adult-only gaming platform. Access to and use of ljo77's Services is strictly limited to individuals who are at least 21 years of age. ljo77 does not knowingly collect Personal Data from any person under the age of 21.

The following measures are in place to prevent underage access:

• All registrants are required to declare their date of birth at registration;
• Mandatory KYC verification, including a government-issued photo ID, is required before a Member's first withdrawal is processed;
• Accounts suspected of being operated by a person under 21 years of age are immediately suspended pending investigation;
• Any account confirmed to belong to a person under 21 is permanently closed and all deposits returned.

If you have reason to believe that a person under the age of 21 has registered or is using a ljo77 account, please notify us immediately at [email protected]. ljo77 takes all such reports seriously and will investigate without delay.

For further guidance on protecting minors from online gambling, please visit our Responsible Gaming page.

Security Measures

ljo77 implements a comprehensive set of technical, organisational, and procedural security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. Key measures include:

• 256-bit SSL/TLS encryption: all data transmitted between your device and the ljo77 Platform is encrypted in transit using industry-standard SSL/TLS protocols;
• Encrypted data storage: sensitive Personal Data, including passwords (stored as salted cryptographic hashes) and financial account references, is encrypted at rest;
• Access controls: access to systems containing Personal Data is restricted to authorised personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication for administrative accounts;
• Regular security audits: ljo77's technical infrastructure undergoes regular security assessments, including penetration testing and vulnerability scanning, conducted by qualified third-party security professionals;
• Fraud detection systems: automated and manual monitoring systems are active around the clock to detect and respond to suspicious activity, including unusual login patterns, abnormal transaction volumes, and bot-driven access attempts;
• Staff training: all ljo77 personnel who handle Personal Data receive regular data protection and information security training as part of their onboarding and ongoing professional development.

Third-Party Links

The ljo77 Platform does not contain links to external third-party websites. All links within the Platform navigate to other pages or sections within https://ljo77.lat itself. Accordingly, the question of ljo77's responsibility for third-party privacy practices does not arise in the context of outbound links from the Platform.

However, the game software studios whose titles are hosted on the ljo77 Platform — including Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, PG Soft, and Spribe — operate their own game servers and may process limited session data independently as part of game delivery. Each studio operates under its own privacy framework and data processing terms, which are governed by its licensing agreements with ljo77. ljo77 is not responsible for any data processing carried out by studio partners beyond what is specified in our data processing agreements with those partners.

Changes to This Privacy Policy

ljo77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, Platform features, or applicable legal requirements. The most current version of this Policy will always be available at https://ljo77.lat/privacy-policy. The "Last updated" date at the top of this page reflects the date of the most recent revision.

Where changes to this Policy are material — meaning they significantly affect the rights of Members or the way in which we process your Personal Data — ljo77 will provide advance notice via email to your registered email address, or via an in-platform notification displayed upon your next ljo77 login, no fewer than 7 days before the revised Policy takes effect.

Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the changes. If you do not accept the revised Policy, you must cease using the Platform and may request account closure in accordance with our Terms & Conditions.

Contact Us

For any questions, concerns, or formal requests relating to this Privacy Policy or to the processing of your Personal Data, please contact the ljo77 data support team through any of the following channels:

• Email: [email protected] — use the subject line "Privacy Policy Query" or "Data Rights Request" for the fastest routing to the correct team;
• Live Chat: available 24/7 directly through the ljo77 Platform. Indonesian-speaking agents are available from 08:00 to 24:00 WIB (Western Indonesia Time, UTC+7);
• WhatsApp: accessible via the account dashboard after ljo77 login.

When contacting us about a data-related matter, please include your registered ljo77 username and a clear description of your query or request. This helps our team locate your account record and respond efficiently.