Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all users of the she777 online gaming platform accessible at https://she777.cam, including our website, mobile-optimized site, and any associated applications or services. she777 operates as a data controller responsible for the personal information we collect and process. We comply with applicable data protection laws in Indonesia and international standards for data privacy and security.

This policy should be read in conjunction with our Terms & Conditions, which govern your use of she777 services. Where there is a conflict between this Privacy Policy and our Terms & Conditions regarding data handling, this Privacy Policy shall prevail.

2. Information We Collect

2.1 Personal Identification Information

When you register for a she777 account, we collect the following personal information:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (Indonesian KTP number, passport number, or driver's license number)
• Contact Data: Email address, Indonesian mobile phone number, residential address including city and postal code
• Financial Data: Bank account details (bank name, account number, account holder name), e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history
• Authentication Data: Username, password (stored in encrypted format), security questions and answers, two-factor authentication settings

2.2 Identity Verification Documents

To comply with anti-money-laundering regulations and responsible gaming requirements, we collect copies of identity verification documents including Indonesian identity cards (KTP), passports, driver's licenses, proof of address documents (utility bills, bank statements), and selfie photographs for facial verification. These documents are securely stored and accessed only by authorized compliance personnel.

2.3 Gaming Activity and Transaction Data

We automatically collect information about your gaming activity on the she777 platform, including:

• Deposit and withdrawal amounts, dates, payment methods, and transaction status
• Bets placed, stakes, winnings, losses, and game choices across sports betting, casino games, slots, and lottery games
• Bonus claims, wagering progress, and promotional participation
• Account balance history and currency conversions
• Responsible gaming tool usage including deposit limits, loss limits, self-exclusion periods, and session time settings

2.4 Technical and Usage Data

When you access she777, we collect technical information including IP address, device type, operating system, browser type and version, screen resolution, language preference, referring website URL, pages visited, time spent on pages, click patterns, and session duration. We also collect geolocation data to verify that you are accessing our platform from within Indonesian territory, as required by our licensing conditions.

2.5 Communication Data

We retain records of all communications between you and she777, including live chat transcripts, email correspondence, customer support tickets, feedback submissions, and phone call recordings (where permitted by law and with your consent). This information helps us improve service quality and resolve disputes.

3. How We Use Your Information

3.1 Account Management and Service Delivery

she777 uses your personal information to create and manage your account, process deposits and withdrawals, verify your identity (KYC compliance), authenticate your login sessions, provide customer support, and deliver gaming services including sports betting, live casino games, slots, and lottery draws. We also use your data to communicate important account notifications such as password resets, transaction confirmations, and account status changes.

3.2 Legal and Regulatory Compliance

We process your personal information to comply with legal obligations including anti-money-laundering (AML) regulations, counter-terrorism financing (CTF) requirements, age verification to prevent underage gambling, fraud prevention and detection, tax reporting obligations, and regulatory audits. We maintain transaction records for the minimum periods required by Indonesian law and our international licensing jurisdiction.

3.3 Responsible Gaming and Player Protection

she777 uses your gaming activity data to monitor for signs of problem gambling, enforce deposit limits and loss limits that you set, implement self-exclusion periods, detect unusual betting patterns that may indicate addiction, and provide targeted responsible gaming resources when appropriate. This processing is essential to our commitment to player welfare and harm minimization.

3.4 Marketing and Promotional Communications

With your consent, we may send you promotional emails, SMS messages, and push notifications about new games, special bonuses, tournaments, and other offers tailored to your gaming preferences. You can opt out of marketing communications at any time by clicking the unsubscribe link in emails, replying STOP to SMS messages, or adjusting notification settings in your account dashboard. Even if you opt out of marketing, we will still send essential account-related communications.

3.5 Platform Improvement and Analytics

We analyze aggregated and anonymized usage data to understand player behavior, improve website performance, optimize game selection, identify technical issues, enhance user experience design, and develop new features. This analytics processing does not identify individual users and is used solely for business intelligence purposes.

4. Legal Basis for Processing

she777 processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations under the Terms & Conditions, including providing gaming services and processing transactions.
• Legal Obligation: Processing is required to comply with Indonesian and international laws, including AML/CTF regulations, age verification requirements, and tax reporting obligations.
• Legitimate Interest: Processing serves our legitimate business interests in fraud prevention, security, platform improvement, and customer support, provided these interests do not override your fundamental rights.
• Consent: Where we rely on your consent (such as for marketing communications), you have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

5. Data Sharing and Disclosure

5.1 Service Providers and Business Partners

she777 shares your personal information with trusted third-party service providers who assist in delivering our services, including:

• Payment processors and banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata) for deposit and withdrawal processing
• E-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) for electronic payment transactions
• Identity verification services that conduct KYC checks and document authentication
• Gaming software providers that supply casino games, live dealer platforms, and sports betting odds feeds
• Customer support platforms and live chat software providers
• Cloud hosting and data storage providers that maintain secure servers
• Analytics and performance monitoring tools

All service providers are contractually bound to protect your personal information and use it only for the specific purposes authorized by she777. We conduct due diligence on all third parties before sharing data and monitor their compliance with data protection standards.

5.2 Legal and Regulatory Authorities

We may disclose your personal information to government authorities, law enforcement agencies, regulatory bodies, and courts when required by law, compelled by legal process, or necessary to protect our legal rights. This includes responding to subpoenas, court orders, regulatory investigations, and anti-money-laundering reporting obligations.

5.3 Corporate Transactions

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on our platform before your information is transferred and becomes subject to a different privacy policy.

5.4 With Your Consent

We will not share your personal information with any third party for their own marketing purposes without your explicit consent. You have the right to withdraw such consent at any time.

6. Data Security Measures

she777 implements robust technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data transmitted between your device and our servers is protected by industry-standard SSL/TLS encryption (256-bit). Sensitive data stored in our databases, including passwords and financial information, is encrypted at rest.
• Access Controls: Access to personal information is restricted to authorized personnel only, based on role-based access controls and the principle of least privilege. All access is logged and audited regularly.
• Secure Infrastructure: Our servers are hosted in secure data centers with physical security measures including 24/7 surveillance, biometric access controls, and redundant power supplies.
• Network Security: We employ firewalls, intrusion detection systems, DDoS protection, and regular security patching to protect against cyber threats.
• Employee Training: All she777 employees receive regular training on data protection principles, security best practices, and confidentiality obligations.
• Incident Response: We maintain an incident response plan to quickly detect, contain, and remediate any data security breaches, and we will notify affected users in accordance with applicable breach notification laws.

7. Data Retention

she777 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Account Information: Retained for the duration of your account lifetime plus 5 years after account closure to comply with AML/CTF record-keeping requirements.
• Transaction Records: Retained for 7 years after the transaction date as required by Indonesian tax and financial regulations.
• Identity Verification Documents: Retained for 5 years after account closure to meet regulatory compliance obligations.
• Communication Records: Retained for 3 years to support customer service quality and dispute resolution.
• Marketing Data: Retained until you withdraw consent or close your account, whichever occurs first.

After the retention period expires, we securely delete or anonymize your personal information so that it can no longer identify you.

8. Your Privacy Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

• Right of Access: You can request a copy of the personal information we hold about you. We will provide this in a commonly used electronic format within 30 days of your request.
• Right to Rectification: You can update or correct inaccurate personal information through your account settings or by contacting customer support.
• Right to Erasure: You can request deletion of your personal information, subject to our legal retention obligations and legitimate business needs.
• Right to Restrict Processing: You can request that we limit how we use your personal information in certain circumstances.
• Right to Data Portability: You can request a machine-readable copy of your personal information to transfer to another service provider.
• Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw that consent at any time.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with "Privacy Rights Request" in the subject line. We will respond within 30 days and may require identity verification to prevent unauthorized access to your information.

9. Cookies and Tracking Technologies

she777 uses cookies, web beacons, and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device that help us remember your preferences, keep you logged in, analyze site traffic, and deliver personalized content. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a set period).

You can control cookie settings through your browser preferences. However, disabling cookies may limit your ability to use certain features of the she777 platform. For detailed information about the cookies we use, please refer to our Cookie Policy available on the platform.

10. Third-Party Links

The she777 platform may contain links to third-party websites, including payment processor sites and game developer platforms. This Privacy Policy does not apply to those external sites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

11. Children's Privacy

she777 services are strictly intended for adults aged 21 and over. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected information from a minor, we will delete it immediately and terminate the associated account. Parents or guardians who believe their child has provided personal information to she777 should contact us immediately.

12. International Data Transfers

Your personal information may be transferred to and processed in countries outside Indonesia where our service providers and data centers are located. We ensure that all international data transfers are protected by appropriate safeguards, including standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms that provide equivalent protection to Indonesian data protection standards.

13. Changes to This Privacy Policy

she777 reserves the right to update this Privacy Policy to reflect changes in our data practices, legal requirements, or business operations. We will notify you of material changes by posting the updated policy on this page with a revised "Last Updated" date and, where appropriate, by sending an email notification to the address associated with your account. Your continued use of she777 services after such modifications constitutes your acceptance of the updated Privacy Policy.

14. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data handling practices, please contact us:

• Email: [email protected]
• Subject Line: "Privacy Policy Inquiry"
• Live Chat: Available 24/7 through the she777 platform
• Response Time: We aim to respond to all privacy-related inquiries within 48 hours on business days

Data Collection Summary

Data Category	Purpose	Retention Period
Identity & Contact Information	Account management, KYC compliance, customer support	Account lifetime + 5 years
Financial & Transaction Data	Payment processing, fraud prevention, tax compliance	7 years after transaction
Gaming Activity	Service delivery, responsible gaming monitoring, analytics	Account lifetime + 3 years
Verification Documents	Identity verification, AML/CTF compliance	5 years after account closure
Technical & Usage Data	Platform security, performance optimization, fraud detection	2 years
Communications	Customer support, dispute resolution, service improvement	3 years