Privacy Policy — km771 Platform

1.1 This Privacy Policy ("Policy") is issued by km771 ("the Company", "we", "us", "our") and applies to all individuals who access, browse, register an account with, or otherwise interact with the km771 online betting and gaming platform available at km771.cam (the "Platform").

1.2 km771 is committed to handling personal data responsibly, transparently, and in accordance with the data protection principles underpinning internationally recognized privacy frameworks. This Policy is designed to inform you clearly about our data practices so that you can make informed decisions about your engagement with the Platform.

1.3 By accessing the km771 Platform, registering an account, or submitting personal data through any channel (including KYC verification, customer support communications, or promotional form submissions), you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

1.4 This Policy should be read alongside km771's Terms & Conditions, which govern the contractual relationship between you and km771. Where there is a conflict between this Policy and the Terms & Conditions on a data privacy matter, this Policy shall prevail.

2.1 For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person — that is, information that could, directly or indirectly, be used to identify you.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Subject" means the natural person (i.e., you, the Player) to whom Personal Data relates.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, km771.
• "Data Processor" means a third party that processes Personal Data on behalf of km771 under a formal data processing agreement.
• "KYC" means Know Your Customer — the identity and age verification process required by km771 prior to processing withdrawals and for ongoing compliance monitoring.
• "Cookies" means small data files placed on your device when you access the km771 Platform, used to maintain session state, remember preferences, and support analytics.

3.1 km771 collects the following categories of personal data, as set out in the table below:

3.2 km771 does not intentionally collect Special Category Data (as defined under international data protection frameworks) such as racial or ethnic origin, political opinions, religious beliefs, genetic data, or health data, except where health-related data is volunteered by a Player in the context of a responsible gaming self-exclusion or support request, in which case it is handled with heightened confidentiality.

4.1 Directly from You. The majority of personal data km771 holds about you is provided directly by you at the time of account registration, KYC submission, deposit or withdrawal request, customer support interaction, or promotional participation.

4.2 Automatically. When you access the km771 Platform, our servers and analytics systems automatically collect technical data including your IP address, browser fingerprint, device identifiers, and behavioral session data. This collection is facilitated by cookies and similar tracking technologies, as described in Section 10.

4.3 From Third Parties. km771 may receive personal data about you from the following third-party sources:

• KYC verification service providers, who may cross-reference your submitted identity documents against national identity databases and third-party credit reference agencies;
• Payment processors and banking partners (including BCA, BRI, BNI, Mandiri, and e-wallet providers such as OVO, DANA, and GoPay) confirming transaction authenticity;
• Fraud prevention and anti-money-laundering screening services;
• Publicly available sources, such as sanctions lists or politically exposed person (PEP) databases, where required for regulatory compliance.

5.1 km771 processes your personal data for the following purposes, each supported by an appropriate legal basis:

• Account creation and management — necessary for the performance of the contract between you and km771;
• Identity and age verification (KYC) — necessary to comply with km771's licensing obligations and applicable anti-money-laundering regulations; and to verify that you are at least 21 years of age as required by our Terms & Conditions;
• Processing deposits and withdrawals in IDR — necessary for the performance of the contract; further required by payment processing partners for fraud prevention and financial compliance;
• Customer support and complaint handling — necessary for the performance of the contract and for km771's legitimate interest in resolving disputes fairly;
• Fraud detection and prevention — necessary for km771's legitimate interests in protecting the platform and its players against fraudulent activity, and to comply with AML obligations;
• Responsible gaming monitoring — necessary for km771's legitimate interests in identifying and supporting players who may be experiencing gambling-related harm, and to comply with licensing requirements;
• Platform analytics and improvement — necessary for km771's legitimate interests in understanding how players use the platform in order to improve functionality, user experience, and game selection;
• Marketing and promotional communications — based on your explicit opt-in consent, where required, or on km771's legitimate interest in communicating with existing customers about relevant offers, subject always to your right to opt out.

5.2 km771 does not process your personal data for purposes that are incompatible with those set out in clause 5.1. If km771 intends to process your data for a materially new purpose, we will provide advance notice and, where required, seek your consent.

6.1 km771 may disclose your personal data to the following categories of recipients, in each case subject to appropriate data protection safeguards:

• Licensed KYC and identity verification providers — to process the identity documents you submit for account verification. These providers operate under strict confidentiality and data processing agreements with km771.
• Payment service providers and banking partners — including BCA, BRI, BNI, Mandiri, and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja) — to process deposit and withdrawal transactions in IDR.
• Fraud prevention and AML screening services — to screen transactions and account activity against sanctions lists, PEP databases, and suspicious activity patterns.
• IT and infrastructure service providers — including cloud hosting providers, cybersecurity vendors, and platform maintenance contractors, each bound by confidentiality obligations.
• Regulatory and licensing authorities — where disclosure is required by the terms of km771's operating license or by a lawful regulatory demand.
• Law enforcement and governmental authorities — where km771 is required by law, court order, or legal process to disclose personal data. km771 will, where legally permitted, notify the affected Player of such a disclosure request.
• Professional advisers — including lawyers, auditors, and accountants, where necessary for the conduct of km771's business and subject to professional confidentiality obligations.

6.2 In the event that km771 or any part of its business is acquired by, or merged with, another entity, your personal data may be transferred to the acquiring entity as part of that transaction. km771 will notify Players of any such change that materially affects how their data is processed.

7.1 As an internationally operating platform, km771 may transfer your personal data to countries outside of Indonesia for storage, processing, or service delivery purposes. Such transfers may include, for example, data hosted on servers located in the jurisdiction of km771's licensing authority.

7.2 Where personal data is transferred outside of Indonesia, km771 ensures that appropriate safeguards are in place to protect the data to a standard at least equivalent to that applicable within Indonesia. These safeguards may include contractual data transfer agreements with receiving parties, adherence to internationally recognized privacy frameworks, or transfer to countries whose data protection laws have been assessed as providing adequate protection.

7.3 For questions about the specific safeguards applied to any international transfer of your personal data, you may submit a query to km771's privacy team at the contact address set out in Section 15.

8.1 km771 implements a comprehensive set of technical and organizational security measures to protect personal data against unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the km771 Platform;
• Encryption of stored sensitive data (including identity documents and financial data) at rest using industry-standard encryption protocols;
• Role-based access controls ensuring that only authorized km771 personnel with a documented operational need can access personal data;
• Regular internal and third-party security audits and penetration testing;
• Multi-factor authentication for all km771 administrative systems;
• Continuous intrusion detection and anomaly monitoring;
• Physical security controls at all data center locations used by km771 and its infrastructure partners.

8.2 While km771 employs robust security measures, no system is completely immune to security threats. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, km771 will notify affected Players without undue delay and will take all reasonable steps to contain and remediate the breach.

8.3 Players are reminded that the security of their km771 account also depends on the strength of their chosen password and the security of their personal device. km771 recommends using a strong, unique password for your km771 account and enabling any available two-factor authentication features.

9.1 km771 retains your personal data for no longer than is necessary for the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Active account data — retained for the duration of your account's active status on km771, plus a post-closure retention period of 7 years to meet AML and licensing record-keeping requirements;
• KYC verification documents — retained for 7 years from the date of verification, in accordance with anti-money-laundering legislation applicable to km771's licensed operations;
• Transaction records (deposits and withdrawals in IDR) — retained for 7 years from the date of the transaction;
• Customer support communications — retained for 3 years from the date of the last interaction, unless the communication relates to an unresolved dispute or formal complaint, in which case it is retained until the matter is fully resolved;
• Marketing preference records — retained for the duration of your account, or until you withdraw your consent to marketing communications, whichever is earlier;
• Technical and behavioral session data — typically retained in identifiable form for up to 24 months, after which it may be retained in anonymized or aggregated form for platform analytics purposes without limitation.

9.2 Following the expiry of the applicable retention period, km771 will securely delete or permanently anonymize your personal data. Where data is anonymized rather than deleted, the resulting dataset cannot be used to re-identify you.

10.1 km771 uses cookies and similar tracking technologies (including local storage and session tokens) on the Platform for the following purposes:

• Essential / Functional Cookies — required for the basic operation of the Platform, including maintaining your login session, storing your account preferences (such as language and display settings), and enabling the betting cart and deposit flow. These cookies cannot be disabled without materially affecting your ability to use km771.
• Analytics Cookies — used to collect aggregated information about how players navigate and interact with the Platform. This data helps km771 identify popular pages, measure game engagement, and optimize the user experience. Analytics data is processed in anonymized or aggregated form where possible.
• Security Cookies — used to detect and prevent fraudulent activity, such as session hijacking or credential stuffing attacks. These cookies capture technical signals including IP address, device fingerprint, and behavioral patterns.

10.2 km771 does not use third-party advertising tracking cookies, retargeting pixels, or social media tracking scripts for the purpose of serving behavioral advertising to Players off-platform.

10.3 Most web browsers allow you to manage cookie preferences through the browser's settings menu. Disabling essential cookies will affect the functionality of the km771 Platform. Disabling analytics cookies will not affect your ability to use the Platform but will limit km771's ability to improve the service based on usage data.

11.1 As a Data Subject whose personal data is processed by km771, you have the following rights, which you may exercise by submitting a written request to our privacy team at [email protected]:

11.2 km771 will respond to all verified Data Subject Requests within 30 calendar days. Where a request is complex or involves a large volume of data, km771 may extend this period by a further 30 days and will notify you of the extension within the initial 30-day window.

11.3 km771 reserves the right to refuse requests that are manifestly unfounded, excessive, or repetitive, or where fulfilling the request would conflict with km771's legal obligations (for example, AML record-keeping requirements that mandate retention of transaction data). Where a request is refused, km771 will provide written reasons.

12.1 km771 employs age verification technology and manual KYC review processes to ensure that all registered Players are at least 21 years of age. Any account identified as belonging to a person under 21 will be immediately and permanently closed, and any personal data associated with that account will be securely deleted in accordance with this Policy, subject to any legal obligations that require its retention.

12.2 If a parent or guardian believes that a minor has registered or attempted to register an account on km771, they should contact our support team immediately at [email protected]. km771 will investigate all such reports promptly and take appropriate action within 48 hours of a confirmed report.

13.1 The km771 Platform does not contain links to third-party websites, social media platforms, or external services beyond those strictly necessary to facilitate payment processing (e.g., redirects to BCA, BRI, BNI internet banking portals during a deposit transaction).

13.2 Where any such payment-facilitating redirect occurs, km771 is not responsible for the privacy practices or content of the third-party site. Players are encouraged to review the privacy policies of their banking and e-wallet providers directly. km771's Privacy Policy applies only to data collected and processed within the km771 Platform itself.

14.1 km771 may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or platform functionality. When we make material changes to this Policy, we will notify registered Players by email and/or by a prominent notice on the Platform prior to the change taking effect.

14.2 The "Last Updated" date at the top of this page will be revised each time the Policy is amended. Players are encouraged to review the Policy periodically. Your continued use of the km771 Platform after the effective date of an amendment constitutes your acceptance of the revised Policy.

14.3 If you do not agree with any amendment to this Policy, you may request closure of your km771 account by contacting [email protected]. Account closure requests will be processed in accordance with the terms set out in the km771 Terms & Conditions.

15.1 If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or wish to raise a privacy-related complaint, please contact the km771 privacy team using the details below:

15.2 km771 takes all privacy complaints seriously and will investigate each complaint promptly and fairly. If you are not satisfied with our response to your complaint, you have the right to escalate the matter to the regulatory or supervisory authority relevant to your jurisdiction.

15.3 Please note that, for security purposes, km771 may be required to verify your identity before processing any Data Subject Request. We will ask you to provide sufficient information to confirm that you are the account holder before releasing any personal data or making changes to your account records.