Privacy Policy

1Introduction & Scope

This Privacy Policy ("Policy") describes how trpc77 ("we", "us", "our"), the operator of the online gaming platform accessible at https://trpc77.cam ("Platform"), collects, uses, stores, shares, and protects personal data relating to individuals who access or use our services ("you", "Player", "User").

This Policy applies to all personal data processed in connection with your use of the Platform, including data collected during account registration, KYC verification, deposit and withdrawal transactions, customer support interactions, and general browsing of the Platform. It applies to all Players accessing the Platform, with particular relevance to players based in Indonesia.

By registering an account or continuing to use the Platform, you confirm that you have read this Policy in full and consent to the collection and use of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue your use of the Platform immediately.

This Policy should be read alongside our Terms & Conditions, which govern the overall relationship between you and trpc77, and our Responsible Gaming page, which sets out our commitments to player welfare.

2Definitions

The following terms carry the meanings defined below throughout this Policy:

3Data We Collect

trpc77 collects Personal Data through several channels. The categories of data we collect are limited to what is necessary for the purposes described in Section 4 of this Policy.

3.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, email address, Indonesian mobile phone number, and residential address in Indonesia.
• KYC Documents: Copies of your Indonesian National Identity Card (KTP), selfie verification photographs, proof of address documents (utility bills or bank statements), and payment method ownership evidence (e.g., BCA, BRI, BNI, or Mandiri account screenshots).
• Financial Data: Bank account numbers, e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), deposit amounts, withdrawal requests, and transaction history.
• Communications Data: Messages, emails, and live chat transcripts exchanged with our customer support team.
• Responsible Gaming Preferences: Deposit limits, loss limits, session time limits, and self-exclusion requests submitted through the Platform.

3.2 Data Collected Automatically

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device fingerprint identifiers.
• Usage Data: Pages visited, games played, bet history, session duration, click-path data, and feature interactions within the Platform.
• Location Data: Approximate geographic location derived from your IP address (used for fraud detection and jurisdictional compliance — we do not collect precise GPS location).
• Cookie and Tracking Data: As described in Section 7 of this Policy.

3.3 Data Received from Third Parties

• Payment Processors: Transaction status and verification signals from BCA, BRI, BNI, Mandiri, and e-wallet providers to confirm deposit and withdrawal completion.
• Identity Verification Services: Confirmation signals from third-party KYC providers engaged to validate identity documents.
• Fraud Prevention Services: Risk scoring and device reputation data from fraud-detection partners used to protect the integrity of your account.

4How We Use Your Data

We use the Personal Data we collect for the following defined purposes only. We do not use your data for any purpose that is incompatible with the purposes listed below without first obtaining your explicit consent.

If you wish to opt out of receiving promotional communications from trpc77, you may do so at any time by contacting our support team at [email protected]. Opting out of marketing communications will not affect the delivery of transactional or account-essential notifications.

5Legal Basis for Processing

trpc77 processes your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is required to perform our contract with you — including creating and managing your account, processing transactions, and providing gaming services — is carried out on the basis that it is necessary for the performance of the contract between you and trpc77.
• Legal Obligation: Certain processing activities — including KYC verification, AML monitoring, and record-keeping — are carried out because they are required by applicable law or regulatory standards binding on trpc77 under its international gaming license.
• Legitimate Interests: We process certain categories of data — including usage data, device data, and fraud-detection signals — on the basis of our legitimate interest in maintaining a secure, fair, and commercially viable Platform, provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we rely on your consent — for example, for sending promotional emails or placing non-essential cookies — we will request your consent explicitly. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6Data Sharing & Disclosure

trpc77 does not sell your Personal Data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual safeguards:

• Payment Service Providers: BCA, BRI, BNI, Bank Mandiri, CIMB Niaga, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja — to facilitate deposit and withdrawal transactions. These providers receive only the financial and identity data necessary to process the specific transaction.
• KYC and Identity Verification Partners: Third-party providers engaged to validate identity documents submitted during KYC. All such partners are bound by data-processing agreements requiring them to use your data solely for verification purposes.
• Fraud Prevention and Security Providers: Specialists that analyze device and behavioral signals to detect and prevent fraudulent activity on the Platform. Data shared is limited to technical identifiers and risk-scoring inputs.
• Cloud Infrastructure and Hosting Providers: Secure, audited data-center operators who store Platform data on our behalf under strict confidentiality and security obligations.
• Professional Advisors: Legal counsel, auditors, and compliance consultants, where disclosure is necessary to obtain professional advice or to establish, exercise, or defend legal claims.
• Regulatory and Law Enforcement Authorities: We may disclose Personal Data to competent authorities where required by applicable law, court order, or binding regulatory directive. We will notify you of any such disclosure unless prohibited from doing so by law.

7Cookies & Tracking Technologies

The trpc77 Platform uses cookies and similar tracking technologies to enhance your browsing experience, maintain session integrity, and gather aggregated analytics data. The table below describes the categories of cookies we use:

Essential and security cookies are placed on the basis of contractual necessity and legitimate interest and cannot be disabled without materially impairing your ability to use the Platform. Functional and analytics cookies are placed on the basis of your consent. You may manage or withdraw consent for non-essential cookies through your browser settings at any time; however, doing so may affect the functionality of certain Platform features.

8Data Retention

We retain your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following retention periods apply:

• Account and Registration Data: Retained for the duration of your account and for a period of five (5) years following permanent account closure, in compliance with our AML record-keeping obligations.
• KYC Documents: Retained for five (5) years from the date of verification or the date your account is closed, whichever is later.
• Transaction Records: Retained for five (5) years from the date of each transaction to satisfy financial record-keeping requirements.
• Customer Support Communications: Retained for two (2) years from the date of the interaction, or for the duration of any unresolved dispute relating to the interaction.
• Analytics Data: Retained in anonymized or aggregated form for up to twenty-four (24) months and may be retained indefinitely in fully anonymized form for internal benchmarking purposes.
• Marketing Preferences: Retained until you withdraw consent or request deletion, at which point we will suppress your details from future marketing within five (5) business days.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized. Where deletion is not immediately technically feasible (for example, data held in encrypted backup systems), we will isolate the data from further processing until deletion can be completed.

9International Data Transfers

As an internationally operated Platform, trpc77 may transfer your Personal Data to countries outside Indonesia for processing by our cloud infrastructure providers, KYC partners, and fraud-prevention services. Such countries may not provide a level of data protection equivalent to Indonesian law.

Where we transfer Personal Data internationally, we implement appropriate safeguards to protect your data, including:

• Executing data-processing agreements incorporating standard contractual clauses with all third-party recipients.
• Conducting transfer impact assessments where transfers involve jurisdictions with materially lower data-protection standards.
• Applying supplementary technical measures — including end-to-end encryption and data minimization — for transfers to higher-risk destinations.

By registering an account and accepting this Policy, you acknowledge and consent to the transfer of your Personal Data to countries outside Indonesia as described above.

10Your Rights

Subject to applicable law and our legitimate processing interests, you have the following rights in relation to your Personal Data held by trpc77:

To exercise any of the above rights, please contact our Data Protection team at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within two (2) business days and respond in full within thirty (30) calendar days. Where a request is complex or voluminous, we may extend this period by a further thirty (30) days, with prior notification.

11Children's Privacy

If we become aware that we have inadvertently collected Personal Data from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be returned to the originating payment method, less any applicable transaction fees, subject to our verification process.

If you believe a minor has accessed the Platform or created an account, please contact us immediately at [email protected] with the subject line "Minor Account Report" so that we can investigate and act without delay.

12Security Measures

trpc77 implements a comprehensive set of technical and organizational security measures designed to protect your Personal Data against unauthorized access, accidental loss, disclosure, alteration, or destruction. These measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your browser or device and the Platform is encrypted using 256-bit SSL/TLS protocols.
• Encryption at Rest: Sensitive Personal Data stored on our servers — including KYC documents and financial records — is encrypted using AES-256 encryption.
• Access Controls: Access to Personal Data is restricted on a strict role-based, need-to-know basis. All staff with access to Personal Data are subject to confidentiality agreements and regular security training.
• Two-Factor Authentication (2FA): Internal administrative systems require multi-factor authentication for all access attempts.
• Regular Security Audits: We conduct periodic penetration testing and vulnerability assessments of our Platform infrastructure, conducted by independent cybersecurity specialists.
• Incident Response Plan: We maintain a documented data-breach response plan that ensures affected Players are notified without undue delay in the event of a significant security incident.

While we take all reasonable steps to protect your data, no system is completely immune to risk. You are responsible for maintaining the security of your own account credentials. We strongly recommend using a unique, complex password and enabling any two-factor authentication options available in your account settings.

13Third-Party Links

The trpc77 Platform may contain references to or integrations with thi rd-party services — such as payment gateways (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay) and game content providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft). When you interact with these third-party services, you may be subject to their own privacy policies and data-handling practices, which are independent of this Policy.

trpc77 is not responsible for the privacy practices of any third-party service provider. We encourage you to review the privacy policies of any third-party service you interact with in connection with your use of the Platform. Our sharing of data with payment processors is limited strictly to what is required to complete your requested transaction, as described in Section 6 of this Policy.

14Policy Updates

trpc77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data-processing practices, applicable law, or regulatory guidance. The "Last Updated" date at the top of this page will be revised accordingly whenever material changes are made.

Where changes are material — meaning they significantly affect your rights or the way we process your Personal Data — we will notify you by email to the address registered on your account at least seven (7) days before the changes take effect. A prominent notice will also be displayed on the Platform homepage during this notification period.

Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must cease using the Platform and may request deletion of your Personal Data in accordance with Section 10 of this Policy.

15Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way trpc77 handles your Personal Data, please contact our Data Protection team through the following channels:

• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Data Rights Request" as appropriate.
• Live Chat: Available 24 hours a day, 7 days a week via the chat widget on the Platform homepage.
• Response Time: We aim to acknowledge all privacy-related enquiries within two (2) business hours and provide a substantive response within thirty (30) calendar days, in accordance with applicable data-protection standards.

If you are not satisfied with our response to your privacy complaint, you have the right to escalate the matter to the data-protection supervisory authority in the jurisdiction under whose laws trpc77 holds its international gaming license. Details of the relevant supervisory authority will be provided upon request.