send77 Privacy Policy

This Policy applies to all personal data collected by send77 in connection with the registration, operation, and closure of Member accounts on the send77 platform, as well as data collected through the send77 website at send77.app and any mobile-optimised interfaces associated with it.

send77 acts as the data controller in respect of all personal data described in this Policy. As data controller, send77 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable data protection laws and internationally recognised privacy standards.

This Policy is directed primarily at Members based in Indonesia and is written in English to align with the language preference of the international-brand segment of the Indonesian market. If you are accessing send77 from a jurisdiction outside Indonesia, this Policy still applies in full to your personal data; however, certain local legal rights referenced in Clause 9 may differ depending on your country of residence.

send77 collects personal data through several distinct channels. The categories of data we collect, and the context in which each category is collected, are set out in the table below.

send77 uses the personal data we collect for the following specific purposes. We do not use your data for any purpose that is incompatible with the purposes listed here without first obtaining your explicit consent.

• Account Management: To create, maintain, and authenticate your send77 account, including verifying your identity and age (21+) at registration and during ongoing account reviews.
• Payment Processing: To process deposits and withdrawals via your nominated Indonesian bank account or e-wallet, and to detect and prevent fraudulent transactions.
• KYC & Anti-Money Laundering (AML) Compliance: To fulfil our obligations under internationally recognised KYC and AML frameworks, including verifying the source of funds for large transactions.
• Responsible Gaming: To monitor wagering patterns that may indicate problem gambling behaviour, to administer self-exclusion and limit-setting tools, and to respond to responsible gaming support requests.
• Platform Improvement: To analyse aggregated usage data to improve the functionality, performance, and user experience of the send77 platform.
• Promotions & Personalisation: To send you information about bonuses, promotions, and platform updates that are relevant to your activity on send77, where you have opted in to receive such communications.
• Customer Support: To investigate and resolve your enquiries, disputes, and complaints efficiently.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, collusion, bot usage, and any other conduct that violates the send77 Terms & Conditions.
• Legal Compliance: To comply with applicable legal obligations, respond to lawful requests from regulatory authorities, and enforce our contractual rights.

Every instance of personal data processing at send77 is grounded in one or more of the following recognised legal bases:

• Contractual Necessity: Processing that is necessary to perform the contract between you and send77 — for example, processing your registration data to create your account, or processing your financial data to handle a withdrawal.
• Legal Obligation: Processing that send77 is required to carry out to comply with a legal requirement — for example, retaining transaction records to satisfy AML obligations or fulfilling KYC requirements imposed by our international licensing authority.
• Legitimate Interests: Processing carried out in pursuit of send77's legitimate business interests where those interests are not overridden by your privacy rights — for example, analysing gameplay data to detect fraud, or using server log data to diagnose and fix technical errors.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — for example, sending you promotional emails about send77 bonuses and offers. Where consent is the legal basis, you may withdraw it at any time by adjusting your communication preferences in your account settings or by contacting the support team.

send77 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following circumstances and only to the minimum extent necessary for each purpose:

• Payment Processors & Banking Partners: To process your deposits and withdrawals, we share your financial account identifiers (bank account number or e-wallet ID) with the relevant Indonesian payment processor, bank (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI), or e-wallet provider (OVO, DANA, GoPay, ShopeePay, LinkAja). These partners process your data under their own privacy policies and are required to implement appropriate data security measures.
• Identity Verification Providers: To complete KYC verification, your identity documents and selfie photograph may be processed by a third-party identity verification service operating under a data processing agreement with send77 that restricts the use of your data to the verification purpose only.
• Game Technology Providers: Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive technical data (session tokens, bet amounts) necessary to deliver game sessions within the send77 platform. These providers operate under data processing agreements with send77 and are not permitted to use your data for their own independent purposes.
• Fraud Prevention & Security Services: Aggregated or pseudonymised data may be shared with third-party fraud detection services to identify and prevent unusual activity patterns that may indicate account compromise or money laundering.
• Regulatory & Legal Authorities: send77 will disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where required to do so by applicable law, a valid court order, or a binding regulatory request. Where legally permitted, send77 will notify you of such a disclosure.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of send77's assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer in advance, and the acquiring entity will be required to honour the commitments set out in this Policy.

send77 uses cookies and similar tracking technologies (collectively, "cookies") to provide core platform functionality, improve your experience, and gather analytical data about platform usage. Cookies are small text files placed on your device when you visit the send77 website.

The categories of cookies used by send77 are as follows:

• Strictly Necessary Cookies: Required for the platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cookies cannot be disabled without impairing your ability to use the platform.
• Functional Cookies: Remember your preferences (such as language settings, preferred payment method, and display preferences) to deliver a more personalised experience across sessions.
• Analytical Cookies: Collect anonymised data about how Members navigate the platform — for example, which pages are visited most frequently and where errors occur. This data is used solely to improve the platform; it is not linked to any individual's identity.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and device fingerprinting, to protect your account and the integrity of the platform.

You may manage your cookie preferences through your browser's settings. Note that disabling strictly necessary cookies will prevent you from logging into your send77 account. send77 does not use third-party advertising or retargeting cookies.

send77 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or to comply with applicable legal, regulatory, or contractual obligations. The following indicative retention periods apply:

When a retention period expires, personal data is either permanently deleted from send77's systems or irreversibly anonymised so that it can no longer be associated with any identifiable individual. Anonymised aggregate data may be retained indefinitely for statistical and platform improvement purposes.

send77 implements a layered security architecture designed to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security measures include, but are not limited to:

• Transport Layer Security (TLS/SSL): All data exchanged between your device and the send77 platform is encrypted in transit using TLS 1.2 or higher. Our SSL certificate is issued by a globally recognised certificate authority.
• Data Encryption at Rest: Sensitive personal data — including identity documents, payment account details, and hashed passwords — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data held in send77's systems is restricted on a strict need-to-know basis. Staff who require access to personal data to perform their job functions are subject to confidentiality obligations and receive regular data protection training.
• Two-Factor Authentication (2FA): send77 offers optional 2FA for Member accounts. Members are strongly encouraged to enable 2FA to add an additional layer of protection against unauthorised account access.
• Penetration Testing: send77's platform infrastructure undergoes regular security audits and penetration testing by independent cybersecurity professionals to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: send77 maintains a documented data breach incident response procedure. In the event of a data breach that poses a risk to Members' rights and freedoms, send77 will notify affected Members and relevant regulatory authorities within the timeframes required by applicable law.

As a send77 Member, you have the following rights in respect of your personal data. To exercise any of these rights, please contact the send77 support team using the details in Clause 13. send77 will respond to all verified requests within 30 days.

Where send77 is unable to fulfil a data rights request — for example, because fulfilling it would conflict with a legal retention obligation — we will explain the reason clearly and advise you of any alternative steps available to you.

The send77 platform is strictly intended for adults aged 21 and above. send77 does not knowingly collect personal data from individuals under the age of 21, and does not permit minors to register for or use the platform under any circumstances.

Age verification is a mandatory step in the send77 registration and KYC process. Any account found to belong to an individual under the age of 21 will be closed immediately, all balances will be returned via the deposit payment method, and all personal data associated with the account will be deleted from send77's systems within 30 days of detection.

If you believe that a person under the age of 21 has registered a send77 account, please notify our support team immediately at the contact address provided in Clause 13. We take all such reports seriously and will act on them without delay.

The send77 platform does not contain links to third-party websites for commercial or advertising purposes. However, game interfaces powered by third-party studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft, and others) are embedded within the platform via licensed APIs. These game providers operate under their own privacy policies and may process limited technical data — such as session tokens and bet results — as necessary to deliver the game experience.

send77 is not responsible for the privacy practices of third-party game studios or payment providers. We encourage you to review the privacy policies of any third-party service provider whose products you interact with through the send77 platform. All such third-party data processing that involves your personal data is governed by a data processing agreement with send77 that restricts use to the stated operational purpose.

send77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, technology, legal requirements, or business operations. When a material change is made — for example, a new category of data being collected, a new third-party processor being engaged, or a change to retention periods — send77 will:

• Publish the updated Policy on the send77 website at send77.app/privacy-policy with a revised "Last updated" date at the top of the document.
• Notify active Members by email at the address registered on their account at least seven days before the change takes effect, where the change materially affects their privacy rights.

Minor or administrative changes — such as typographical corrections or clarifications that do not alter the substantive meaning of any provision — may be made without prior notice and take effect upon publication.

Your continued use of the send77 platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with any change to this Policy, you should stop using the platform and contact the support team to close your account and request the return of your account balance.

If you have any questions about this Privacy Policy, wish to exercise any of the rights described in Clause 9, or wish to raise a complaint about how send77 has handled your personal data, please contact the send77 Data Protection team through any of the following channels:

• Live Chat: Available 24/7 directly from your send77 account dashboard. Our Indonesian-speaking agents can assist with data rights requests in real time.
• Email: [email protected] (plain text — not a clickable link). Please include "Privacy Request" or "Data Complaint" in the subject line so your message is routed to the correct team.

send77 aims to respond to all privacy-related requests and complaints within 30 days of receipt. For complex requests involving large volumes of data or multiple processing activities, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it within the initial 30-day window.

If you are not satisfied with send77's response to your privacy complaint, you have the right to escalate your complaint to the relevant data protection authority in your jurisdiction, or to the regulatory body that oversees send77's international operating licence.