sate77 Privacy Policy

sate77 ("we", "us", "our") operates the online casino and sportsbook platform accessible at sate77.app. As part of providing these services to players in Indonesia and internationally, we necessarily collect and process certain personal data. We are committed to handling that data responsibly, transparently, and in accordance with applicable data protection principles.

This Privacy Policy applies to all personal data collected through:

• The sate77 website and all pages and subdomains thereof.
• The account registration and verification process.
• Deposits, withdrawals, and all cashier transactions.
• Gameplay activity across all products on the platform, including live casino, sportsbook, slots, and card games.
• Customer support communications via live chat, email, or any other contact channel.
• Promotional participation and loyalty programme activity.

This Privacy Policy should be read alongside the sate77 Terms & Conditions, which govern the overall relationship between sate77 and its registered Players. In the event of a conflict between this Privacy Policy and the Terms & Conditions on a data-related matter, this Privacy Policy shall prevail.

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

• "Personal Data" means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly, including by reference to a name, identification number, location data, online identifier, or one or more factors specific to that person's identity.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, deletion, and destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For data collected through the sate77 platform, sate77 is the Data Controller.
• "Data Processor" means an entity that processes Personal Data on behalf of the Data Controller — for example, a third-party payment gateway that processes transaction data on sate77's behalf.
• "Player" or "User" means any registered account holder or visitor who accesses the sate77 platform.
• "KYC Data" means identity verification documents and associated personal information collected as part of the Know Your Customer process required prior to a Player's first withdrawal.
• "Cookies" means small text files placed on a Player's device by the sate77 platform to support functionality, analytics, and security.

sate77 collects Personal Data through several distinct channels and processes. The categories of data we collect are as follows:

3.1 Registration Data

When you create a sate77 account, we collect the information you provide during the registration process, which typically includes:

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Email address
• Mobile telephone number
• Residential address (city, province, postal code)
• Preferred currency (IDR)
• Username and password (password is stored in encrypted, hashed form only — sate77 staff cannot access your plaintext password)

3.2 KYC and Identity Verification Data

Before processing your first withdrawal, sate77 requires you to complete KYC verification. This involves collecting:

• A copy or photograph of a valid government-issued identity document (Indonesian National Identity Card / KTP, or passport)
• A selfie or live photograph for facial verification purposes (in some cases)
• Proof of residential address (utility bill, bank statement, or equivalent, dated within the last three months)
• Proof of the payment method used for deposits (e.g., a screenshot of your bank account or e-wallet registered in your name)

3.3 Financial and Transaction Data

All deposit and withdrawal transactions generate financial records that sate77 retains for compliance, audit, and fraud prevention purposes. This includes:

• Deposit amounts, dates, times, and payment channels (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, LinkAja)
• Withdrawal requests, amounts, processing times, and destination payment account identifiers
• Account balance history and transaction logs
• Bonus claims, wagering records, and cashback calculations

3.4 Gameplay and Behavioural Data

• Game session logs (start time, duration, game title, stake amounts, outcomes)
• Sports betting history (event, market, odds, stake, settlement)
• Platform navigation patterns and feature usage
• Responsible gaming tool usage (deposit limit settings, self-exclusion requests, cooling-off activations)

3.5 Technical and Device Data

• IP address and approximate geolocation at time of login
• Device type, operating system, and browser version
• Session identifiers and authentication tokens
• Platform performance data and error logs

3.6 Communications Data

• Live chat transcripts with the sate77 support team
• Emails sent to or received from sate77 support addresses
• Promotional communication preferences (opt-in / opt-out status)
• Any feedback, complaints, or dispute submissions submitted to sate77

sate77 uses the Personal Data we collect for the following purposes:

sate77 does not use Personal Data for any purpose not listed above without first obtaining your explicit consent or unless required by applicable law. We do not sell, rent, or trade your Personal Data to third parties for their own independent marketing or commercial purposes.

sate77 processes your Personal Data on the following legal grounds, depending on the specific processing activity:

• Contractual necessity: Processing that is required to fulfil our obligations to you under the sate77 Terms & Conditions — including account creation, payment processing, and game delivery — is carried out on the basis that it is necessary for the performance of the contract between sate77 and the Player.
• Legal obligation: Certain processing activities — including KYC identity verification, anti-money laundering record-keeping, and the maintenance of transaction logs — are carried out to comply with applicable legal and regulatory obligations. sate77 cannot waive these obligations at a Player's request.
• Legitimate interests: sate77 processes some data on the basis of its legitimate interests as a platform operator, including fraud detection, platform security, responsible gaming monitoring, and service improvement. When relying on legitimate interests, sate77 has assessed that those interests are not overridden by the rights and interests of the data subject.
• Consent: Where sate77 sends promotional communications by email or other electronic means, this is done only where you have provided explicit consent during registration or subsequently opted in. You may withdraw consent for marketing communications at any time by contacting support or using the unsubscribe mechanism in any promotional email.

sate77 does not share your Personal Data with third parties except in the circumstances described below. In all cases where data is shared with third-party processors, sate77 requires those parties to maintain appropriate technical and organisational security measures and to process data only for the purposes specified by sate77.

6.1 Payment Service Providers

To process deposits and withdrawals through Indonesian bank channels (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja), sate77 shares the minimum necessary transaction data with the relevant payment processor or intermediary. Payment processors are engaged under data processing agreements and are not permitted to use your data for their own purposes.

6.2 Identity Verification Providers

KYC documents and identity verification data may be shared with specialist third-party KYC and anti-fraud service providers for document authentication and fraud screening. These providers act as Data Processors under sate77's instruction and are contractually prohibited from using your KYC data for any purpose other than verification.

6.3 Game Content Providers

Third-party game studios — including Evolution Gaming, Pragmatic Play, PG Soft, Microgaming, NetEnt, Spribe, and Asia Gaming — may receive limited gameplay session data (such as a session token, stake amount, and game result) as part of the technical operation of their games. These providers operate under their own privacy frameworks and data processing agreements with sate77.

6.4 Legal and Regulatory Disclosure

sate77 may disclose Personal Data to law enforcement agencies, regulatory authorities, or other public bodies where required to do so by law, court order, or lawful governmental request. sate77 will endeavour to notify you of any such disclosure unless prohibited from doing so by law.

6.5 Business Transfers

In the event that sate77 undergoes a merger, acquisition, or sale of all or substantially all of its assets, Player Personal Data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and any material changes to how your data is handled that result from it.

6.6 What We Do Not Do

sate77 does not sell, rent, licence, or otherwise transfer your Personal Data to third parties for their own marketing, advertising, or commercial purposes. sate77 does not share Personal Data with data brokers. sate77 does not share your data with affiliates or referring partners beyond the minimum information necessary to calculate and pay affiliate commission where applicable.

The sate77 platform uses cookies and similar tracking technologies to support platform functionality, maintain session security, and gather anonymised analytics about how Players use the platform. The categories of cookies used are as follows:

• Essential Cookies: Required for the platform to function. These include session authentication tokens, CSRF protection cookies, and load-balancing cookies. The platform cannot operate without them and they cannot be disabled.
• Functional Cookies: Store your preferences such as language settings, preferred game lobby view, and responsible gaming reminder configurations. Disabling these may affect your experience but will not prevent access to the platform.
• Analytics Cookies: Collect anonymised data about page visits, feature usage, and navigation paths to help sate77 understand how the platform is used and identify areas for improvement. No personally identifiable information is transmitted through analytics cookies.
• Security Cookies: Support fraud detection and account security functions, including the detection of unusual login patterns and device fingerprinting for multi-account prevention.

sate77 does not use advertising or behavioural retargeting cookies. Your browser settings allow you to manage, restrict, or delete cookies at any time. Note that disabling essential cookies will prevent you from logging in to your sate77 account.

sate77 retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal obligations. The following retention periods apply as a general guide:

When data is no longer required for its primary purpose or any applicable retention period, sate77 securely deletes or anonymises it in a manner that prevents reconstruction of the original Personal Data.

The technical security measures sate77 employs include:

• 256-bit SSL/TLS encryption on all connections between your browser and the sate77 platform, protecting data in transit from interception.
• Encrypted password storage using industry-standard one-way hashing algorithms. sate77 staff cannot read your plaintext password under any circumstances.
• Access controls restricting internal access to Personal Data to authorised personnel on a need-to-know basis, with full audit logging of data access events.
• Account lockout protection activating after repeated failed login attempts to prevent brute-force credential attacks.
• Encrypted at-rest storage for KYC documents and other sensitive identity data.
• Regular security assessments of platform infrastructure and third-party integrations.

In the event of a data security incident that is likely to result in a risk to your rights and freedoms, sate77 will notify affected Players without undue delay and will take all reasonable steps to contain and remediate the incident.

Players are responsible for maintaining the security of their own login credentials and devices. If you suspect your sate77 account has been accessed without your authorisation, contact support immediately via live chat.

Subject to applicable data protection laws and the limitations described below, you have the following rights in relation to your Personal Data held by sate77:

• Right of Access: You may request a copy of the Personal Data sate77 holds about you. sate77 will provide this within 30 days of a verified request, free of charge for the first request in any 12-month period.
• Right to Rectification: If any Personal Data sate77 holds about you is inaccurate or incomplete, you may request that it be corrected. For account details such as name and address, you may also update certain fields directly through your account settings.
• Right to Erasure: You may request that sate77 delete your Personal Data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (where processing was based on consent), or where the data has been processed unlawfully. This right does not apply where sate77 is required to retain data by law — for example, KYC and transaction records subject to regulatory retention obligations cannot be deleted on request.
• Right to Restriction: In certain circumstances — for example, where you contest the accuracy of your data while sate77 verifies it — you may request that sate77 restrict processing of your data to storage only, pending resolution.
• Right to Data Portability: Where processing is based on your consent or contractual necessity and is carried out by automated means, you may request that sate77 provide your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You may object at any time to processing carried out on the basis of sate77's legitimate interests, including responsible gaming monitoring. sate77 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based solely on your consent — for example, marketing communications — you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, submit a written request to support@sate77.app with the subject line "Data Rights Request — [your registered email address]". sate77 will verify your identity before acting on any request and will respond within 30 calendar days.

If sate77 becomes aware that it has inadvertently collected Personal Data from a person under 21 years of age, it will immediately suspend the associated account, delete the data collected, and — where a deposit has been made — return any real-money funds to the source payment method after verifying the circumstances.

If you are a parent or guardian and believe that a minor in your care has registered an account on the sate77 platform, please contact us immediately at support@sate77.app. We will act on such reports with priority.

The sate77 platform does not contain links to third-party websites. However, third-party game content embedded within the platform (such as live casino streams and slot games operated by Evolution Gaming, Pragmatic Play, PG Soft, and others) is delivered by those providers' own technical infrastructure. While sate77 maintains data processing agreements with all integrated game providers, sate77 is not responsible for the privacy practices of those providers in relation to data processed within their own systems outside of sate77's direct control.

Players who access third-party platforms independently — for example, by navigating directly to a game provider's website — do so outside the scope of this Privacy Policy, and sate77 accepts no responsibility for how those third parties handle personal data on their own platforms.

sate77 primarily serves Players based in Indonesia, and its core data infrastructure is designed with the Indonesian market in mind. However, certain third-party service providers engaged by sate77 — including game content providers, KYC verification platforms, and cloud infrastructure partners — may process data in jurisdictions outside Indonesia.

Where Personal Data is transferred to a jurisdiction that does not have data protection laws equivalent to those applicable to sate77's operations, sate77 ensures that appropriate safeguards are in place before such a transfer occurs. These safeguards include:

• Data processing agreements incorporating standard contractual clauses that obligate the receiving party to protect the data to a standard equivalent to that required under applicable data protection principles.
• Transfer impact assessments where required, to evaluate whether the destination jurisdiction presents a material risk to the rights of Indonesian data subjects.
• Contractual restrictions limiting the use of transferred data to the specified processing purpose and prohibiting onward transfers without sate77's prior written authorisation.

By using the sate77 platform, you acknowledge that your Personal Data may be processed in jurisdictions outside Indonesia as described above, subject to the safeguards in place.

sate77 reserves the right to update this Privacy Policy at any time. When material changes are made — such as changes to the categories of data collected, the purposes for which it is used, or the third parties with whom it is shared — sate77 will notify registered Players by email to the address on file and by displaying a notice on the platform prior to the effective date of the change.

The current version of this Privacy Policy, together with its effective date, is always accessible at sate77.app/privacy-policy. Your continued use of the platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with any material change, you may close your account by contacting support prior to the effective date.

Minor, non-material updates — such as corrections of typographical errors or clarifications that do not change the substance of the policy — may be made without advance notice. The "Last Updated" date at the top of this document will always reflect the most recent revision.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how sate77 has handled your Personal Data, please contact us through the following channels:

• Email: support@sate77.app — use the subject line "Privacy Enquiry" for general questions or "Data Rights Request" for formal rights exercises.
• Live Chat: Available 24/7 on the sate77 platform. For data rights requests, please follow up in writing by email to ensure a complete audit trail.

sate77 will acknowledge all privacy-related enquiries within 48 hours and aims to provide a substantive response within 14 calendar days. Complex requests — such as full data subject access requests — may take up to 30 calendar days to fulfil.

If you are dissatisfied with sate77's response to a privacy complaint, you have the right to escalate the matter to the relevant data protection authority in your jurisdiction, or to pursue dispute resolution through the mechanism specified in the sate77 Terms & Conditions.