Privacy Policy

Definitions

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

• "Company," "we," "us," or "our" refers to sr9999, the operator of the Platform at https://sr9999.cam.
• "Platform" means the website at https://sr9999.cam and all associated services, applications, and systems.
• "Member" or "you" means any natural person who has registered an Account on the Platform or who visits and browses the Platform without registering.
• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly — including name, date of birth, email address, device identifiers, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, the Company.
• "Processor" means any third party that processes Personal Data on behalf of the Company under a contractual data processing agreement.
• "KYC" means Know Your Customer — the identity and age verification procedure required before a Member may make a withdrawal from their Account.
• "Cookies" means small text files placed on your device by the Platform to facilitate session management, analytics, and functionality.
• "AML" means Anti-Money Laundering — the regulatory framework and internal controls the Company maintains to detect and prevent financial crime.

Data We Collect

sr9999 collects Personal Data through three primary channels: information you provide directly, information generated automatically through your use of the Platform, and information received from third-party verification and payment partners.

2.1 Data You Provide Directly

• Registration data: Full legal name, date of birth, residential address (including city and province within Indonesia), email address, and chosen username.
• KYC documentation: Government-issued photo identification (Indonesian national identity card / KTP, or passport), proof of address (utility bill or bank statement dated within three months), and payment method verification documents.
• Payment data: Bank account details for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, or Bank Danamon; e-wallet identifiers for OVO, DANA, GoPay, ShopeePay, or LinkAja; and USDT wallet addresses where applicable.
• Communications data: The content of any messages you send to our support team via live chat, WhatsApp, or email, together with metadata such as timestamps and the support agent assigned.
• Responsible gaming data: Any self-imposed deposit limits, loss limits, session time limits, or self-exclusion requests you submit through the Platform's player-protection tools.

2.2 Data Collected Automatically

• Device and browser data: IP address, browser type and version, operating system, screen resolution, and device identifiers.
• Usage data: Pages visited, time spent on each page, navigation paths through the Platform, search queries entered, and game sessions initiated.
• Transaction data: A complete log of all deposits, withdrawal requests, Wager placements, game results, bonus claims, and Account balance movements.
• Session data: Login timestamps, logout timestamps, session duration, and geolocation data derived from your IP address (country and city level).
• Cookie data: Data stored in or read from cookies placed on your device — see Section 7 for full details.

2.3 Data Received from Third Parties

• KYC verification partners: Confirmation of identity document authenticity and age verification results from our contracted identity-verification service providers.
• Payment processors: Transaction status confirmations, fraud-screening flags, and chargeback notifications from our payment partners.
• Fraud prevention services: Risk scores, device fingerprint data, and behavioural analytics signals from our contracted fraud-prevention partners.

How We Use Your Data

The table below summarises the primary purposes for which sr9999 processes your Personal Data, together with the corresponding legal basis for each purpose.

3.1 Marketing Communications

sr9999 may send you promotional emails or WhatsApp messages about new game releases, seasonal bonus offers (including campaigns tied to Idul Fitri, Ramadhan, and Indonesian Independence Day), and platform updates. You will receive marketing communications only if you have explicitly opted in during registration or subsequently through your Account settings. You may withdraw consent and unsubscribe from marketing messages at any time by contacting support or updating your notification preferences within the Platform.

3.2 Automated Decision-Making

sr9999 employs automated systems to screen transactions and player behaviour for fraud indicators and AML red flags. Where an automated decision materially affects your Account — such as a temporary account freeze or withdrawal hold — you have the right to request human review of that decision by contacting our support team. We aim to complete human review within two business days of such a request.

Legal Basis for Processing

The Company processes Personal Data on the following legal bases, consistent with internationally recognised data protection principles:

• Performance of contract: Processing that is necessary to open your Account, provide access to games and markets, process your deposits and withdrawals, and otherwise deliver the services described in the Terms & Conditions.
• Legal obligation: Processing required to comply with AML regulations, KYC requirements, and reporting obligations imposed by our licensing authority and applicable international financial crime regulations.
• Legitimate interests: Processing that serves the Company's genuine operational interests — such as fraud prevention, platform security, responsible gaming monitoring, and improving the quality of the Platform — provided those interests are not overridden by your fundamental rights.
• Consent: Processing for optional purposes — primarily direct marketing communications — for which your freely given, specific, informed, and unambiguous consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing & Disclosure

sr9999 does not sell your Personal Data. We share Personal Data with third parties only in the specific circumstances described below, and only to the extent strictly necessary for the stated purpose.

5.1 Service Providers and Processors

We engage third-party service providers who process Personal Data on our behalf under contractual data processing agreements that require them to implement appropriate security measures and prohibit them from using your data for any purpose beyond the specified service. These include:

• Payment processors and banking partners: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, LinkAja, and our USDT transaction partners.
• KYC and identity verification providers: Third-party document verification services used to authenticate government-issued identification documents and confirm age.
• Fraud prevention partners: Contracted providers of device fingerprinting, behavioural analytics, and transaction risk-scoring services.
• Cloud infrastructure providers: Data centre and hosting partners who store encrypted Member data on our behalf.
• Customer support tools: Live chat and helpdesk software providers used to manage support communications.
• Game content providers: Studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive only the minimum session data necessary to deliver and certify individual game results.

5.2 Regulatory and Law Enforcement Disclosure

The Company may disclose Personal Data to our licensing authority, financial intelligence units, or law enforcement agencies when required to do so by applicable law, court order, or binding regulatory direction. Where legally permissible, we will notify you of such a disclosure request before complying.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of the Company's assets, your Personal Data may be transferred to the acquiring entity. We will notify you of any such transfer via the email address registered to your Account and ensure that the receiving entity is bound by privacy obligations at least as protective as those in this Policy.

International Data Transfers

The Company operates internationally and may transfer your Personal Data to servers or service providers located outside Indonesia. Where such transfers occur, the Company ensures that appropriate safeguards are in place to protect your data, including:

• Contractual data processing agreements incorporating internationally recognised standard contractual clauses or equivalent data transfer mechanisms.
• Transfer only to jurisdictions that maintain data protection standards assessed by the Company as substantially equivalent to those applied under internationally recognised frameworks.
• Technical measures including end-to-end encryption of data in transit and at rest, ensuring that transferred data cannot be intercepted or accessed by unauthorised parties during transmission.

If you would like further information about the safeguards applied to any specific international transfer of your data, please contact our support team using the details in Section 14.

Cookies & Tracking Technologies

The sr9999 Platform uses cookies and similar tracking technologies to ensure the Platform functions correctly, remember your preferences, and help us understand how Members use the Platform so we can continue to improve it.

7.1 Types of Cookies We Use

7.2 Cookies We Do Not Use

sr9999 does not use third-party advertising cookies, social media tracking pixels, or any other tracking technology designed to build a profile of your browsing behaviour across websites for the purpose of targeted advertising.

7.3 Managing Cookies

Strictly necessary cookies cannot be disabled, as they are essential for the Platform to function correctly. You may disable functional and analytics cookies through your browser's privacy settings at any time. Please be aware that disabling functional cookies may affect your Platform experience — for example, your display preferences may not be retained between sessions. Instructions for managing cookies in major browsers are available in each browser's help documentation.

Data Retention

sr9999 retains Personal Data only for as long as necessary to fulfil the purposes described in this Policy or to comply with applicable legal retention obligations. The general retention periods applied are as follows:

• Account and registration data: Retained for the duration of your active Account and for a minimum of five (5) years following Account closure, consistent with our AML record-keeping obligations.
• KYC documentation: Retained for a minimum of five (5) years following the completion of the verification procedure or Account closure, whichever is later.
• Transaction records: Retained for a minimum of five (5) years following the date of each transaction, in compliance with applicable financial crime regulations.
• Support communications: Retained for three (3) years from the date of the communication, or until resolution of any related dispute.
• Analytics and usage data: Retained in aggregated, anonymised form indefinitely; identifiable usage logs are deleted after twenty-four (24) months.
• Marketing consent records: Retained for the duration of your opt-in consent and for three (3) years following withdrawal of consent, to enable us to demonstrate compliance.

When Personal Data reaches the end of its applicable retention period, it is securely deleted or irreversibly anonymised. Data subject to an ongoing legal hold (for example, data relevant to an active regulatory investigation or litigation) is retained until the hold is lifted.

Your Rights

As a data subject, you hold the following rights with respect to your Personal Data held by sr9999. To exercise any of these rights, submit a written request to our support team using the contact details in Section 14. We will acknowledge your request within two (2) business days and provide a substantive written response within thirty (30) calendar days.

• Right of access: You have the right to request a copy of the Personal Data we hold about you, together with information about how it is processed and shared.
• Right to rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or completed without undue delay.
• Right to erasure: You have the right to request deletion of 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 the data has been processed unlawfully. This right is subject to the Company's legal retention obligations — for example, AML records must be retained regardless of an erasure request.
• Right to restrict processing: In certain circumstances, you have the right to request that we restrict the processing of your Personal Data — for example, while the accuracy of the data is contested or a legitimate interests objection is being assessed.
• Right to data portability: Where processing is based on consent or contractual necessity, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format and to have it transmitted to another controller where technically feasible.
• Right to object: You have the right to object to processing based on the Company's legitimate interests, including profiling. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• 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 prior to withdrawal.
• Right not to be subject to solely automated decisions: Where a decision with significant effects on you is made solely by automated means, you have the right to request human review. See Section 3.2 for details.

Children's Privacy

The Platform is strictly intended for adults aged 21 years and over. sr9999 does not knowingly collect, store, or process Personal Data belonging to individuals under the age of 21. If you believe that a person under 21 has registered an Account or provided Personal Data to the Platform, please notify us immediately at the contact details in Section 14. Upon receiving such a notification, we will investigate promptly and, if confirmed, delete all associated Personal Data and close the Account without delay.

Parents and guardians who are concerned about a young person's access to online gambling platforms are encouraged to install parental control software and to review the guidance available on our Responsible Gaming page.

Security Measures

sr9999 implements a layered, defence-in-depth approach to data security. The key technical and organisational measures we maintain include:

• 256-bit SSL/TLS encryption: All data in transit between your browser or device and our servers is encrypted using industry-standard TLS protocols. The padlock icon in your browser's address bar confirms that your session is encrypted.
• Encryption at rest: Sensitive Personal Data stored in our databases — including KYC documentation and payment account details — is encrypted at rest using AES-256 encryption.
• Access controls: Access to Personal Data within our organisation is governed by a strict role-based access control (RBAC) framework. Only staff members with a verified operational need are granted access to Member data, and all access events are logged and audited.
• Two-factor authentication: Administrative access to systems that store Personal Data requires multi-factor authentication.
• Regular security assessments: We conduct periodic internal and third-party penetration tests and vulnerability assessments of our Platform infrastructure.
• Incident response: The Company maintains a documented data breach response procedure. In the event of a security incident that poses a material risk to Members' rights, we will notify affected Members and relevant regulatory authorities within the timeframe required by applicable law.

While we implement all reasonable measures to protect your Personal Data, no transmission over the internet or electronic storage system is entirely immune to security risk. You also play an important role in keeping your Account secure — please use a strong, unique password, enable any available two-factor authentication features, and never share your login credentials with others.

Third-Party Links

The Platform does not contain links to third-party websites. All navigational links on the Platform point exclusively to internal pages within the sr9999 domain. Accordingly, this section is included for completeness: should any third-party reference ever appear in a game interface delivered by a content provider, that provider's own privacy policy governs the handling of data within that specific game session interface. sr9999 is not responsible for the privacy practices of third-party game studios in respect of any data they may independently collect through their game client software.

Policy Amendments

The Company reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, operational requirements, or applicable law. In the event of a material amendment — meaning a change that meaningfully affects your rights or the way we use your Personal Data — we will provide at least seven (7) days' prior notice via the email address registered to your Account, or by displaying a prominent notice on the Platform.

The "Last Updated" date at the top of this page will be revised on each amendment. We encourage you to review this Policy periodically. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the revised terms, you must stop using the Platform and request Account closure before the effective date of the change.

All previous versions of this Privacy Policy are retained in our records and can be provided upon request to any Member who wishes to review the history of our data practices.

Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a concern about how sr9999 handles your Personal Data, please contact our support team using the details below. All privacy-related inquiries are handled by staff with specific data protection training.

• Support Email: [email protected] — please use the subject line "Privacy Inquiry" or "Data Rights Request" for prompt routing.
• WhatsApp: +62 811 9999 000 (available 08:00–24:00 WIB, daily)
• Live Chat: Available directly through the Platform interface, 24 hours a day, 7 days a week.
• Response commitment: We acknowledge all privacy inquiries within two (2) business days and provide a substantive written response within thirty (30) calendar days of receiving a verifiable request.

If you are dissatisfied with our response to any privacy complaint, you have the right to escalate the matter to the data protection authority or regulatory body relevant to your jurisdiction. We will cooperate fully with any investigation conducted by a competent supervisory authority.

This Privacy Policy was last reviewed and updated in January 2026 and supersedes all prior versions of the sr9999 Privacy Policy.