Privacy Policy — sma777
Data Protection Statement

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

• "sma777", "we", "us", "our" — refers to the sma777 online betting and gaming platform operated at https://sma777.cam and its controlling entity.
• "Platform" — the sma777 website, any associated mobile applications, and all services offered thereunder.
• "Member", "you", "your" — any individual who has registered an account with sma777, or who accesses the Platform as a visitor.
• "Personal Data" — any information that identifies or can reasonably identify a natural person, including name, email address, phone number, bank account details, IP address, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
• "KYC" — Know Your Customer verification, the identity-verification process required to activate full withdrawal functionality on the sma777 Platform.
• "IDR / Rp" — Indonesian Rupiah, the official currency of Indonesia and the primary transaction currency on the sma777 Platform.

This Privacy Policy applies to all Personal Data collected, processed, or stored by sma777 in connection with your use of the Platform. It applies to all registered Members and to visitors who access the Platform without creating an account.

sma777 primarily targets the Indonesian market. This policy is therefore drafted with reference to Indonesian data-protection standards and international best-practice frameworks. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

This policy should be read in conjunction with our Terms & Conditions, which govern the contractual relationship between you and sma777.

sma777 collects the following categories of Personal Data:

3.1 Registration Data

• Full legal name
• Date of birth (to verify that you are at least 21 years of age, as required for all Indonesian members)
• Email address
• Mobile phone number
• Chosen username and encrypted password
• City and province of residence within Indonesia (e.g., Jakarta, Surabaya, Bandung, Medan, Bali)

3.2 Financial Data

• Bank account name, account number, and bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, or other supported Indonesian banks)
• Digital wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Transaction history — deposits, withdrawals, and wager amounts denominated in IDR/Rp

3.3 Identity Verification (KYC) Data

• Government-issued identification document (e.g., Indonesian national identity card — KTP, or passport)
• A selfie photograph taken during the KYC verification process
• Proof of address documentation where required

3.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, game activity logs, and betting history
• Cookies and similar tracking technologies (see Clause 7)

3.5 Communications Data

• Records of live chat, email, and WhatsApp interactions with the sma777 support team
• Feedback, survey responses, and voluntary information you provide when contacting us

sma777 uses Personal Data for the following purposes:

• Account Management: To create, maintain, and secure your sma777 account, including password recovery and two-factor authentication.
• Identity Verification: To conduct KYC checks and confirm that all members are Indonesian residents aged 21 or above.
• Payment Processing: To process IDR deposits via local bank transfer (BCA, BRI, BNI, Mandiri, CIMB Niaga) and digital wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and to process withdrawal requests to verified accounts.
• Service Delivery: To provide access to sports betting, live casino, togel (traditional numbers lottery), and slot gaming products on the Platform.
• Fraud Prevention & Compliance: To detect and prevent fraudulent activity, money laundering, and multi-account abuse.
• Customer Support: To respond to your queries, complaints, and requests via live chat, email, or WhatsApp.
• Platform Improvement: To analyse aggregate usage data and improve Platform performance, game selection, and user experience.
• Marketing Communications: To send promotional emails and messages about bonuses, seasonal offers (e.g., Idul Fitri promotions, Indonesian Independence Day specials), and VIP program updates — subject to your marketing consent preferences.
• Responsible Gaming: To monitor usage patterns and proactively identify members who may benefit from responsible-gaming interventions, including deposit-limit recommendations and self-exclusion support.

sma777 processes your Personal Data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you as an sma777 member — including account registration, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable anti-money-laundering (AML), counter-terrorist-financing (CTF), and identity-verification obligations.
• Legitimate Interests: Processing necessary for sma777's legitimate business interests, including fraud prevention, platform security, and product improvement — provided such interests are not overridden by your privacy rights.
• Consent: Processing based on your explicit consent, including marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

sma777 does not sell, rent, or trade your Personal Data to third parties for commercial purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Service Providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and digital wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) to process your financial transactions.
• KYC & Identity Verification Providers: Third-party identity verification services engaged to conduct document checks and biometric screening as part of the KYC process.
• Technology Infrastructure Providers: Cloud hosting, database, and content delivery network (CDN) providers who process data on our behalf under strict data-processing agreements.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, court order, or lawful authority, sma777 may disclose Personal Data to relevant regulatory or government bodies.
• Fraud Prevention Networks: Shared fraud-intelligence databases used to prevent account takeovers, payment fraud, and bonus abuse across the online gaming industry.

All third-party service providers engaged by sma777 are contractually required to process Personal Data only as instructed and to maintain appropriate technical and organisational security measures.

sma777 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are in use:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without breaking core Platform functionality.
• Preference Cookies: Used to remember your language, currency display (IDR/Rp), and layout preferences so you do not need to re-enter them on each visit.
• Analytics Cookies: Used to collect aggregated, anonymised data about how members navigate the Platform — including page visit frequency and game-category popularity. This data is used solely for internal product improvement and is never shared with advertising networks.

sma777 does not use cross-site advertising cookies, social-media tracking pixels, or retargeting technologies. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may impair your ability to log in or use the Platform.

sma777 retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account & Registration Data: Retained for the lifetime of your sma777 account, plus a minimum of five (5) years following account closure, to comply with anti-money-laundering record-keeping obligations.
• Transaction & Financial Records: Retained for a minimum of five (5) years from the date of each transaction in accordance with applicable financial record-keeping requirements.
• KYC & Identity Documents: Retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later.
• Support Communications: Retained for up to three (3) years from the date of the relevant interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Analytics & Usage Data: Aggregated and anonymised after thirteen (13) months. No identifiable usage data is retained beyond this period.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised in accordance with our data-destruction procedures.

As an sma777 member, you have the following rights in relation to your Personal Data:

• Right of Access: You may request a copy of all Personal Data that sma777 holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data held in your sma777 account.
• Right to Erasure: You may request deletion of your Personal Data, subject to our legal retention obligations and ongoing contractual requirements.
• Right to Restrict Processing: You may request that we limit how we use your data in certain circumstances — for example, while a rectification request is being assessed.
• Right to Data Portability: You may request that we provide your Personal Data in a structured, machine-readable format for transfer to another service provider.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting prior processing.
• Right to Object: You may object to processing based on sma777's legitimate interests where you believe your fundamental rights override those interests.

To exercise any of the above rights, please contact the sma777 Data Protection team at [email protected] with the subject line "Data Rights Request". We will respond within thirty (30) calendar days of receiving a verifiable request.

sma777 maintains a comprehensive suite of technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction:

• All data in transit is encrypted using TLS 1.2 or higher (256-bit SSL).
• All data at rest on sma777 servers is encrypted using AES-256 encryption.
• Access to member Personal Data is restricted to authorised personnel on a strict need-to-know basis, enforced via role-based access controls.
• All sma777 internal systems are protected by multi-factor authentication and undergo regular penetration testing by independent security firms.
• Suspicious login attempts and unusual transaction patterns trigger automated security alerts and account review processes.
• A documented incident-response procedure is in place. In the event of a data breach that poses a risk to affected members, sma777 will notify relevant parties within 72 hours of becoming aware of the incident.

Whilst sma777 implements industry-standard safeguards, no online platform can guarantee absolute security. We encourage all members to use strong, unique passwords and to enable two-factor authentication on their sma777 accounts.

The sma777 Platform is strictly intended for adults. You must be at least 21 years of age to register an account and participate in any betting or gaming activity on the Platform. This minimum age requirement applies to all members, regardless of the province or city in Indonesia in which they reside.

sma777 does not knowingly collect Personal Data from individuals under the age of 21. If we become aware that a member has provided false age information during registration and is under 21, we will immediately suspend the account, reverse any transactions to the extent technically possible, and permanently delete all Personal Data associated with that account.

If you believe that a minor has registered on the sma777 Platform, please contact us immediately at [email protected].

The sma777 Platform may display informational references to third-party products, leagues, and services — such as BRI Liga 1, EPL, La Liga, Champions League, and payment providers. sma777 is not responsible for the privacy practices of any third-party organisations referenced on the Platform.

Where sma777 engages third-party processors — such as KYC verification providers, cloud hosting services, or payment gateways — those parties are bound by data-processing agreements that require them to handle Personal Data only on sma777's documented instructions and to implement security measures equivalent to or exceeding our own standards.

sma777 does not currently transfer Personal Data outside of its primary processing jurisdiction. Should any international transfer become necessary, sma777 will implement appropriate safeguards prior to such transfer.

sma777 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, platform functionality, or data-processing practices. When material changes are made, sma777 will:

• Update the "Effective Date" and "Last Reviewed" dates at the top of this page;
• Display a prominent notice on the Platform homepage for a minimum of fourteen (14) days following the change; and
• Where required by law or the materiality of the change, notify registered Members directly via the email address on their sma777 account.

Your continued use of the sma777 Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the amended policy, you may close your account by contacting support at [email protected].

This Privacy Policy shall be governed by and construed in accordance with the laws applicable to sma777's operating jurisdiction. To the extent that Indonesian data-protection regulations — including applicable provisions of Law No. 27 of 2022 on Personal Data Protection (Undang-Undang Perlindungan Data Pribadi) — apply to the processing of your Personal Data, sma777 will comply with those provisions.

Any disputes arising in connection with this Privacy Policy that cannot be resolved through direct negotiation shall be referred to binding arbitration in accordance with the procedural rules specified in the sma777 Terms & Conditions.

For all privacy-related enquiries, data-rights requests, or to report a suspected data breach, please contact the sma777 Data Protection team using the following details:

• Email: [email protected] (subject line: "Privacy Enquiry" or "Data Rights Request")
• Response Time: Within 30 calendar days for data-rights requests; within 5 business days for general privacy enquiries
• Support Hours: 24/7 (Western Indonesia Time — WIB, UTC+7)

Please note that for security purposes, sma777 may need to verify your identity before processing any data-rights request. We will not process requests that cannot be authenticated to an existing registered member account.