Privacy Policy

In this Privacy Policy, the following terms carry the meanings assigned to them below:

• "kode77", "we", "us", or "our" refers to the operator of the website at https://kode77.cam and all related subdomains and applications.
• "Personal Data" means any information that identifies or can reasonably be used to identify a living natural person, directly or in combination with other data, including but not limited to name, email address, date of birth, device identifiers, and financial account details.
• "Player", "User", "you", or "your" refers to any individual who accesses, browses, or registers an account on the kode77 platform.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Controller" means the entity that determines the purposes and means of Processing Personal Data — in this case, kode77.
• "Processor" means a third party that Processes Personal Data on behalf of kode77 under written instruction and binding data-processing agreements.
• "Cookies" means small text files placed on your device by a website to store information about your visit, preferences, or session state.
• "KYC" (Know Your Customer) refers to the identity and document verification process conducted on Players in connection with anti-money laundering obligations.
• "Services" refers to the complete suite of betting, gaming, promotional, support, and ancillary services offered through the kode77 platform.

This Privacy Policy applies to all Personal Data collected by kode77 in connection with the provision of its Services, including data collected through the kode77 website, any associated mobile application, customer support interactions (live chat and email), and any promotional campaigns run by kode77.

This Policy applies to all Players regardless of their country of residence. The platform is principally designed to serve players based in Indonesia, and the data practices described herein are tailored accordingly. References to local payment providers — including BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, and LinkAja — reflect our primary market context.

This Privacy Policy should be read in conjunction with kode77's Terms & Conditions and Responsible Gaming Policy, which together constitute the full framework governing your relationship with kode77.

kode77 collects Personal Data across several categories depending on how you interact with our platform. The table below provides a structured overview:

We do not collect sensitive categories of Personal Data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where a document submitted for KYC purposes incidentally contains such information (e.g., a national identity card that includes religion — as is the case with the Indonesian KTP). In such instances, the document is stored solely for identity verification purposes and the sensitive field is not separately recorded or used.

kode77 collects Personal Data through the following channels:

• Direct Submission: Data you provide voluntarily when registering an account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated Technologies: Data collected automatically when you use our platform, including via Cookies, web beacons, pixel tags, and server logs. This includes Technical Data and Usage Data as described in Section 3.
• Payment Providers: When you transact via a local bank (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) or e-wallet (OVO, DANA, GoPay, ShopeePay, LinkAja), our payment processing partners may share transaction confirmation data with us to reconcile your account balance.
• Identity Verification Partners: Where kode77 uses a third-party KYC or fraud-detection service to assist with account verification, that partner may supply us with the results of their verification checks alongside the data you submitted.
• Publicly Available Sources: In limited circumstances related to fraud prevention or AML compliance, kode77 may consult publicly available databases or sanctions lists to verify information associated with a Player account.

kode77 processes your Personal Data only where a valid legal basis exists. The primary purposes for which we process Personal Data, together with their legal bases, are set out in the table below:

kode77 does not sell your Personal Data. We share Personal Data with third parties only in the following circumstances, and only to the minimum extent necessary:

• Payment Service Providers: We share financial and identity data with local banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposit and withdrawal transactions on your behalf.
• Game Studio Partners: When you play games powered by our studio partners — including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft — certain session and account identifiers are shared with those studios to facilitate game delivery, result recording, and RNG certification compliance.
• KYC and Fraud Detection Services: We share identity and document data with accredited third-party verification providers solely for the purpose of completing KYC checks and detecting fraudulent activity.
• IT and Infrastructure Providers: kode77 uses cloud hosting, content delivery, and database service providers who may process Technical and Usage Data on our behalf as data Processors under binding data-processing agreements.
• Legal and Regulatory Authorities: We may disclose Personal Data to government bodies, law enforcement agencies, or regulatory authorities where required by law, court order, or to protect kode77's legal rights. This may include disclosure to Indonesian authorities or to international financial intelligence units in connection with AML obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a part of kode77's business, Personal Data held by kode77 may be transferred to the acquiring entity, subject to equivalent data-protection commitments being maintained.

All third-party Processors are contractually bound to process your data only on kode77's documented instructions, to maintain appropriate security measures, and to delete or return data upon termination of the service relationship.

kode77 uses Cookies and similar tracking technologies to operate the platform, maintain your session, remember your preferences, and gather analytics data that helps us improve the user experience. The categories of Cookies we use are as follows:

• Strictly Necessary Cookies: These are essential for the platform to function. They enable core features such as user authentication, session management, and security token validation. The platform cannot operate without them, and they do not require your consent.
• Functional Cookies: These remember your preferences and settings — such as your chosen language, display preferences, and last-visited game category — to provide a more personalised experience.
• Analytics Cookies: These collect aggregated and anonymised data about how players navigate the platform, which pages are visited most frequently, and where users encounter errors. This data is used solely to improve platform performance and content.
• Marketing Cookies: Where you have given consent, these Cookies track your activity across sessions to enable relevant promotional messaging. You may withdraw this consent at any time by adjusting your Cookie preferences via your account settings.

You may manage your Cookie preferences through your browser settings. Please note that disabling Strictly Necessary Cookies will prevent you from using the platform. Disabling Functional or Analytics Cookies may result in a reduced browsing experience but will not prevent you from placing bets or accessing your account.

kode77 implements a layered security architecture to protect Personal Data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include, but are not limited to:

• TLS/SSL Encryption: All data in transit between your device and our servers is encrypted using current TLS standards.
• Encryption at Rest: Sensitive data stored in our databases — including financial account details and KYC document references — is encrypted using AES-256 or equivalent standards.
• Two-Factor Authentication (2FA): Players are encouraged to enable 2FA on their kode77 account. Administrative access to systems containing Personal Data is protected by mandatory multi-factor authentication.
• Penetration Testing: kode77 conducts periodic security assessments and penetration tests of its infrastructure to identify and remediate vulnerabilities before they can be exploited.
• Access Logging: All access to systems containing Personal Data is logged with timestamps, user identifiers, and action types. Logs are reviewed regularly for anomalous patterns.
• Incident Response Plan: kode77 maintains a documented data-breach response procedure. In the event of a breach likely to result in a high risk to your rights and freedoms, we will notify affected Players without undue delay and take all reasonable steps to contain and remediate the breach.

While we apply rigorous technical and organisational safeguards, no system connected to the internet can guarantee absolute security. You are responsible for maintaining the confidentiality of your account password and for ensuring that you do not share your login credentials with any third party.

kode77 retains Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with kode77's data disposal procedures. Where data is anonymised rather than deleted, the resulting anonymised dataset is no longer considered Personal Data and may be retained for analytical purposes indefinitely.

Subject to applicable law and to certain exceptions related to our legal obligations (in particular AML and KYC requirements), you have the following rights in relation to the Personal Data kode77 holds about you:

• Right of Access: You may request a copy of all Personal Data kode77 holds about you. We will provide this in a commonly used, machine-readable format where feasible.
• Right to Rectification: You may request that inaccurate or incomplete Personal Data be corrected without undue delay. Minor corrections (such as updating your contact email) can be made directly within your account dashboard.
• Right to Erasure ("Right to be Forgotten"): You may request that kode77 delete your Personal Data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where you object to processing and no overriding legitimate interest exists. Note that we may be required to retain certain data to comply with AML laws notwithstanding such a request.
• Right to Restriction of Processing: You may request that kode77 restrict the Processing of your Personal Data in certain circumstances — for example, while we verify the accuracy of data you have disputed.
• Right to Data Portability: Where Processing is based on consent or contract and is carried out by automated means, you may request that kode77 provide your Personal Data in a structured, commonly used format so that it can be transferred to another controller.
• Right to Object: You may object to Processing based on kode77's legitimate interests at any time. You also have an unconditional right to object to the use of your data for direct marketing purposes.
• Right to Withdraw Consent: Where Processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of Processing carried out prior to withdrawal.

To exercise any of the above rights, please contact us at [email protected] (plain text — not a clickable link) or via our live chat support. We will acknowledge your request within 3 business days and aim to resolve it within 30 days. Complex requests may take up to 60 days, in which case we will provide written notice of the extension.

kode77's Services are strictly for adults aged 21 and above. We do not knowingly collect, process, or retain Personal Data belonging to any person under the age of 21. Our registration process requires users to confirm their date of birth, and age verification is conducted as part of the mandatory KYC process.

If kode77 discovers or is notified that Personal Data belonging to a person under the age of 21 has been submitted to the platform, we will take immediate steps to suspend the associated account, delete the data in question, and — where applicable — report the matter to relevant authorities in line with our responsible gaming obligations.

Parents and guardians who suspect that a minor may have registered on the kode77 platform are urged to contact us immediately at [email protected] so that appropriate action can be taken without delay.

kode77 operates internationally, and your Personal Data may be transferred to and processed in countries outside Indonesia where our servers, infrastructure providers, or third-party service partners are located. These countries may not have data protection laws equivalent to those in your home jurisdiction.

Where such transfers occur, kode77 ensures that appropriate safeguards are in place to protect your data, including:

• Binding data-processing agreements incorporating internationally recognised standard contractual clauses (SCCs) or equivalent data transfer mechanisms.
• Transfers only to countries or organisations that maintain data protection standards acceptable to kode77's compliance framework.
• Technical security measures (encryption, pseudonymisation) applied to data before transfer where appropriate.

You may contact us at [email protected] to request further information about the specific safeguards applied to any international transfer of your Personal Data.

The kode77 platform may contain references to, or integrations with, third-party services such as game studio platforms, payment gateways, and customer communication tools. These third parties operate under their own privacy policies and data practices, for which kode77 accepts no responsibility.

We recommend that you review the privacy policies of any third-party service provider you interact with in connection with your use of kode77, including your chosen local bank or e-wallet provider (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay). kode77 has no control over how those organisations collect or use your data once a transaction has been initiated.

kode77 may send you promotional emails, SMS messages, or in-platform notifications about bonuses, new game releases, seasonal promotions (including campaigns around Idul Fitri, Ramadhan, and Indonesian Independence Day), and other offers that may be of interest to you. We will only send marketing communications where you have given your explicit consent to receive them at the time of registration or subsequently via your account preferences.

You may withdraw your consent to receive marketing communications at any time by:

• Clicking the "Unsubscribe" link included in any promotional email.
• Adjusting your notification preferences within your kode77 account dashboard.
• Contacting our support team at [email protected] and requesting removal from all marketing lists.

Please allow up to 5 business days for your opt-out preference to take effect across all communication channels. Note that even after opting out of marketing communications, you will continue to receive transactional and service-related notifications (such as deposit confirmations, withdrawal updates, and security alerts), as these are necessary for the provision of the Services and do not require separate consent.

kode77 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the Services we offer. The "Last Updated" date at the top of this page will be revised whenever a material change is made.

Where a material change affects the way in which we process your Personal Data, kode77 will notify registered Players via their registered email address or via a prominent notice on the platform prior to the change taking effect. Your continued use of the kode77 platform following such notice constitutes acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how kode77 protects your data. Prior versions of this Policy are available upon written request submitted to [email protected].

If you have any questions, concerns, or complaints about this Privacy Policy or the way kode77 handles your Personal Data, please contact our Data Protection team using the details below. All communications must be submitted in English or Indonesian.

kode77 will acknowledge all privacy-related complaints within 3 business days and aims to resolve them within 30 days. Where a complaint requires additional investigation, we will provide a written update within 7 business days of the initial acknowledgement.

If you are not satisfied with kode77's response to your privacy complaint, you may have the right to escalate the matter to an appropriate data protection authority or supervisory body in your jurisdiction.