sp999 Privacy Policy

1. Introduction

sp999 is committed to handling the personal data of its players with the highest standards of care, transparency, and security. This Policy has been drafted to give players — including those based across Indonesia in cities such as Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, and Makassar — a clear and complete picture of the data practices that underpin the sp999 platform.

sp999 operates in accordance with international gaming licence requirements, which include specific obligations relating to the collection, processing, and protection of player data. These obligations inform every aspect of this Policy.

This Policy should be read alongside the Terms & Conditions and the Responsible Gaming policy, both of which form part of the overall agreement between sp999 and each registered player.

2. Definitions

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, address, email address, phone number, financial account details, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" means sp999 in its capacity as the entity that determines the purposes and means of Processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of sp999 under a written data processing agreement.
• "Cookies" means small text files placed on your device by the Platform for the purposes of session management, preference storage, analytics, and fraud detection.
• "KYC Data" means identity and age verification documents submitted by a player as part of the Know Your Customer process, including government-issued identification (KTP, passport), proof of address, and payment method evidence.
• "Sensitive Data" means a subset of Personal Data that warrants heightened protection, including financial account details, payment card numbers, and identity document numbers.

3. Data We Collect

sp999 collects Personal Data through several channels and at different points during your use of the Platform. The categories of data we collect are described below.

3.1 Registration Data

When you create an sp999 account, we collect the information you voluntarily provide, including your full legal name, date of birth, residential address, email address, and your chosen username. This information is required to establish and maintain your account.

3.2 KYC Verification Data

To comply with our international gaming licence obligations and responsible gaming commitments, sp999 requires players to complete identity verification. This may involve submitting copies of a government-issued national identity card (KTP), passport, or driver's licence; a proof of address document (such as a bank statement or utility bill dated within 90 days); and evidence of the payment method used for deposits (for example, a screenshot of your BCA, BRI, BNI, Mandiri, OVO, DANA, or GoPay account).

3.3 Transaction Data

sp999 records details of all deposits, withdrawals, and wagers placed on the Platform, including the amounts (in IDR / Rp), timestamps, payment methods used, and the games or markets on which bets were placed. This data is retained for audit, fraud prevention, and regulatory compliance purposes.

3.4 Technical and Device Data

When you access the Platform, our servers automatically collect certain technical information, including your IP address, browser type and version, operating system, device type, screen resolution, referring URL, and session duration. This data is used for security monitoring, fraud detection, and platform optimisation.

3.5 Communications Data

If you contact sp999 via live chat, email, or any other support channel, we retain a record of that correspondence, including the content of messages and any attachments, for the purposes of customer service, dispute resolution, and quality assurance.

3.6 Behavioural and Analytics Data

sp999 collects aggregated data about how players navigate and interact with the Platform — for example, which games are accessed most frequently, session lengths, and feature usage patterns. Where this data is linked to an identifiable individual, it is handled as Personal Data under this Policy.

4. How We Use Your Data

sp999 uses your Personal Data for the following purposes:

sp999 will not use your Personal Data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for that additional use.

5. Legal Basis for Processing

sp999 relies on one or more of the following legal bases when processing your Personal Data:

• Contractual Necessity: Processing is necessary to perform the contract between sp999 and you as a registered player — for example, to operate your account, process transactions, and provide access to games.
• Legal Obligation: Processing is required to comply with applicable laws and our international gaming licence requirements — for example, KYC verification, anti-money-laundering checks, and record-keeping obligations.
• Legitimate Interests: Processing is necessary for the legitimate interests of sp999 — for example, fraud prevention, platform security, and service improvement — provided those interests are not overridden by your rights and freedoms.
• Consent: Where sp999 relies on your consent as the legal basis for processing — for example, sending personalised promotional communications — you have the right to withdraw that consent at any time by contacting us or updating your account preferences.

6. Data Sharing & Third Parties

6.1 sp999 does not sell, rent, or trade your Personal Data to any third party. We share your data only in the limited circumstances described in this section.

6.1 Service Providers

sp999 engages carefully vetted third-party service providers to assist with specific operational functions, including payment processing (e.g., processing transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja), KYC verification providers, IT infrastructure and hosting, fraud detection and analytics, and customer support platform software. Each provider is bound by a data processing agreement that restricts their use of your data to the specific service they are contracted to perform.

6.2 Gaming Software Providers

Game studios and platform providers (such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft) may receive certain session and technical data necessary to deliver their games through the sp999 Platform. This data is processed under their own privacy frameworks and is limited to what is operationally required.

6.3 Legal and Regulatory Disclosures

sp999 may disclose your Personal Data to regulatory bodies, law enforcement agencies, courts, or other competent authorities where we are legally required to do so, or where we determine in good faith that disclosure is reasonably necessary to protect the rights, property, or safety of sp999, its players, or the public.

6.4 Business Transfers

In the event that sp999 undergoes a merger, acquisition, restructuring, or sale of all or part of its assets, your Personal Data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and of any changes to the applicable privacy policy that result from it.

7. Cookies & Tracking Technologies

7.1 sp999 uses cookies and similar tracking technologies (such as web beacons and local storage objects) on the Platform for the following purposes:

• Essential Cookies: Required for core platform functionality, including maintaining your login session, preserving game state, and enabling secure transactions. These cannot be disabled without impacting your ability to use the Platform.
• Analytics Cookies: Used to collect aggregated data on how players interact with the Platform, which helps us identify usability issues and improve the overall experience. Data collected via analytics cookies does not directly identify you as an individual.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats. These cookies help sp999 protect the integrity of the platform and your account.
• Preference Cookies: Used to remember your platform settings and preferences (such as display language and notification choices) between sessions.

7.2 Most web browsers allow you to control cookies through their settings. Disabling essential cookies will affect the functionality of the sp999 Platform and may prevent you from logging in or completing transactions. Disabling analytics and preference cookies will not prevent you from using the Platform but may result in a less personalised experience.

7.3 sp999 does not use third-party advertising or retargeting cookies for the purpose of displaying sp999 advertisements on other websites.

8. Data Security

8.1 sp999 implements a multi-layered technical and organisational security framework to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and sp999's servers.
• Encryption at rest for all sensitive data stored in our databases, including identity document scans and payment method records.
• Role-based access controls that restrict internal access to Personal Data to authorised personnel with a demonstrated business need.
• Regular penetration testing and vulnerability assessments conducted by independent third-party security specialists.
• Continuous server monitoring and intrusion detection systems operating around the clock.
• Secure, geographically redundant data centre infrastructure with strict physical access controls.

8.2 While sp999 takes all reasonable measures to protect your data, no online platform can guarantee absolute security. You also play a role in keeping your account safe: use a strong, unique password for your sp999 account, do not share your login credentials with anyone, and contact us immediately if you suspect unauthorised access.

9. Data Retention

9.1 sp999 retains your Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by our international gaming licence and applicable law. The following retention periods apply as a general guide:

9.2 At the end of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised and aggregated data may be retained indefinitely for analytical and reporting purposes.

10. Your Privacy Rights

10.1 As a player on the sp999 Platform, you have the following rights in relation to your Personal Data. To exercise any of these rights, please contact our privacy team using the details in Section 14.

• Right of Access: You have the right to request a copy of the Personal Data sp999 holds about you, along with information about how it is being used.
• Right to Rectification: If any Personal Data sp999 holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure: Subject to our legal retention obligations (see Section 9), you may request that sp999 delete your Personal Data. We will comply unless we are required by law or our gaming licence to retain the data.
• Right to Restriction: You may request that sp999 restrict the processing of your Personal Data in certain circumstances — for example, while a dispute regarding its accuracy is being resolved.
• Right to Data Portability: Where sp999 processes your data on the basis of your consent or a contractual necessity, you have the right to receive that data in a structured, machine-readable format so that it can be transferred to another service provider.
• Right to Object: You have the right to object to sp999 processing your Personal Data where we rely on legitimate interests as the legal basis, and where you believe your rights and freedoms override those interests.
• Right to Withdraw Consent: Where sp999 processes your data based on your consent (for example, for marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.

10.2 sp999 will respond to all verified privacy rights requests within 30 calendar days. In complex cases, this period may be extended by a further 30 days, in which case we will notify you of the extension and the reason for it.

10.3 sp999 will not charge a fee for handling routine privacy rights requests. However, where requests are manifestly unfounded or excessive, sp999 reserves the right to charge a reasonable administrative fee or to decline the request, with written reasons provided.

11. Minors

11.1 The sp999 Platform is strictly intended for adults aged 21 and over. sp999 does not knowingly collect Personal Data from individuals under the age of 21. If we become aware that an account has been registered by or on behalf of a minor, we will immediately close that account, erase the associated Personal Data (subject to any mandatory legal retention requirements), and return any eligible funds.

11.2 If you believe that a minor has accessed or registered on the sp999 Platform using your payment details or contact information, please contact our support team immediately. We take underage gambling extremely seriously and will act swiftly to investigate and remediate any such case.

12. International Data Transfers

12.1 sp999 operates through data centres and service providers located in multiple jurisdictions. As a result, your Personal Data may be transferred to, stored in, or processed in a country other than Indonesia. In all cases, sp999 ensures that such transfers are subject to appropriate safeguards, including contractual data protection clauses and, where applicable, adequacy determinations.

12.2 By using the sp999 Platform and accepting this Privacy Policy, you acknowledge and consent to the transfer of your Personal Data to sp999's servers and service providers in the jurisdictions required for the provision of the service.

12.3 Regardless of where your data is processed, sp999 applies the same level of data protection described in this Policy to all Personal Data it holds, irrespective of the country of processing.

13. Amendments to This Policy

13.1 sp999 may update this Privacy Policy from time to time to reflect changes in our data practices, operational requirements, or applicable law. The most current version of the Policy will always be available on this page, with the "Last Updated" date revised accordingly.

13.2 Where a material change is made to this Policy, sp999 will provide reasonable advance notice to active players via the Platform or by email. Your continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Policy.

13.3 We recommend reviewing this page periodically — at least once every quarter — to stay informed about how sp999 is protecting your data.

14. Contact & Privacy Enquiries

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to report a privacy concern, please contact sp999's dedicated privacy team using the details below. All contacts are displayed as plain text — they are not clickable links.

• General Support: [email protected]
• Privacy Enquiries & Data Rights Requests: [email protected]
• Security Incidents: [email protected]
• Live Chat: Available 24/7 via the Platform, with peak response times of 2–5 minutes (WIB).

sp999 acknowledges all written privacy enquiries within 5 business days and provides a substantive response within 30 calendar days of receiving a verified request.