s9s9s Privacy Policy

Throughout this Privacy Policy, the following terms carry the meanings defined below:

• "Platform" — the s9s9s website at s9s9s.org, including all sub-pages, applications, and services operated by s9s9s.
• "Member" — any individual who has registered a s9s9s account, whether or not the account is currently active.
• "Personal Data" — any information that, alone or in combination with other data, can identify a natural person. This includes but is not limited to name, date of birth, address, email address, phone number, national identification number, IP address, and payment account details.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, erasure, and destruction.
• "Data Controller" — s9s9s, as the entity that determines the purposes and means of Processing your Personal Data.
• "Third Party" — any natural or legal person other than the Member and s9s9s, including payment processors, KYC verification providers, game studios, and analytics services.
• "KYC" — Know Your Customer; the identity and document verification process applied by s9s9s to confirm Member identity, age, and residency.
• "Cookies" — small text files placed on your device by the Platform to recognise your browser, preserve session state, and support analytics functions.

This Privacy Policy applies to all Personal Data collected by s9s9s in connection with the Platform, regardless of how that data was provided — whether through the registration process, account usage, payment transactions, customer support interactions, or passive technical collection via cookies and log files.

This policy applies to all Members and prospective Members who are residents of Indonesia and who are aged 21 or older. s9s9s does not knowingly collect or process Personal Data from individuals under the age of 21. If you believe that a minor has provided their data to s9s9s, please contact us immediately at [email protected] so that we may take appropriate action.

This policy does not cover the data practices of third-party game studios (such as Pragmatic Play, Evolution Gaming, or Pocket Games Soft) or payment service providers (such as BCA, BRI, OVO, or DANA) whose services are accessible through the Platform. Their data practices are governed by their own privacy policies.

s9s9s collects the following categories of Personal Data:

s9s9s collects Personal Data through three primary mechanisms:

4.1 Directly From You

The majority of the data we hold is provided by you directly when you register a Member account, complete KYC verification, make a deposit or withdrawal request, claim a bonus, submit a customer support query, or update your account profile. You are not obligated to provide data beyond what is required for a specific service, but failure to supply mandatory data (such as identity documents for KYC) may prevent access to certain features, particularly withdrawals.

4.2 Automatically During Platform Use

When you access the Platform, our servers and analytics tools automatically collect Technical Data and Usage Data. This includes your IP address (which may be used to infer your general geographic location within Indonesia), your device characteristics, and your navigation behaviour within the Platform. This automated collection is necessary for the secure and efficient operation of the Platform and cannot be disabled without discontinuing use.

4.3 From Third Parties

s9s9s may receive supplementary information about you from third-party sources, including KYC verification providers who cross-reference your documents against official databases, payment processors who confirm successful deposit or withdrawal transactions, fraud detection services that flag anomalous account or payment activity, and game studios who relay gameplay metadata required for settlement and dispute resolution.

s9s9s uses the Personal Data it holds for the following purposes:

• Account Management: Creating, maintaining, and securing your Member account; authenticating your identity at login; processing password reset requests.
• Service Delivery: Enabling you to place bets, play games, make deposits and withdrawals, and access all features of the Platform.
• KYC & Age Verification: Verifying that you meet the minimum age requirement of 21 years and that your identity, address, and payment method match the details you have provided. This is a legal and platform-integrity obligation.
• Payments Processing: Initiating and reconciling deposits and withdrawals via local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Fraud & Security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, bonus abuse, money laundering, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible Gaming: Monitoring betting patterns to identify potential signs of problem gambling; enforcing deposit limits, cooling-off periods, and self-exclusion requests activated by the Member; and, where required by our responsible gaming obligations, proactively reaching out to at-risk Members.
• Customer Support: Responding to your queries, resolving complaints, and maintaining records of your support interactions for quality assurance and dispute resolution purposes.
• Promotions & Marketing: Sending promotional offers, bonus notifications, and seasonal campaign communications (such as Idul Fitri or Imlek promotions) to Members who have opted in to receive marketing. You may opt out at any time by adjusting your account communication preferences or by contacting [email protected].
• Platform Improvement: Analysing aggregate usage patterns to improve the platform experience, fix technical issues, and develop new features. This analysis uses anonymised or pseudonymised data wherever practicable.
• Legal Compliance: Meeting our obligations under applicable international gaming, anti-money laundering (AML), counter-terrorism financing (CTF), and data protection regulations.

s9s9s processes your Personal Data on the following legal bases:

s9s9s does not sell, rent, or trade your Personal Data. We share data only where necessary to operate the Platform and only under the conditions set out below:

7.1 Service Providers

We share relevant Personal Data with carefully selected third-party service providers who assist in operating the Platform. These include KYC and identity verification providers, payment processors and banking partners (including the Indonesian banks and e-wallet providers listed in Section 3), cloud hosting and infrastructure providers, fraud detection and cybersecurity services, and customer support platform providers. All such providers are bound by data processing agreements that restrict their use of your data to the specific service they are contracted to deliver.

7.2 Game Studios

When you play a game powered by a third-party studio — such as Pragmatic Play, Evolution Gaming, Pocket Games Soft, Spribe, NetEnt, or Microgaming — the studio receives a session token and the minimum account metadata required to initialise and settle the game session. Studios do not receive your full identity or financial data.

7.3 Legal and Regulatory Disclosure

s9s9s may disclose your Personal Data to law enforcement agencies, regulatory authorities, or courts where required to do so by applicable law, a valid legal order, or where s9s9s reasonably believes disclosure is necessary to prevent fraud, money laundering, or other serious criminal activity. We will notify you of such disclosure where legally permitted to do so.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a material part of s9s9s's business assets, your Personal Data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer by email or by a prominent notice on the Platform prior to your data being transferred and becoming subject to a different privacy policy.

The s9s9s Platform uses cookies and similar tracking technologies to provide a functional, personalised, and secure experience. The types of cookies we use are described below:

Most browsers allow you to view, manage, and delete cookies through the browser settings menu. Please note that disabling functional or analytics cookies will not affect your core ability to deposit, withdraw, or play, but may reduce the quality of your personalised experience on the Platform.

s9s9s retains Personal Data for as long as your Member account is active and for a defined period after account closure, as set out below:

• Identity and KYC documents: Retained for a minimum of 5 years after account closure to satisfy anti-money laundering (AML) record-keeping obligations.
• Financial transaction records: Retained for a minimum of 5 years after each transaction, in line with international financial record-keeping standards applicable to gaming operators.
• Betting and gaming history: Retained for 3 years after account closure, or for the duration of any unresolved dispute, whichever is longer.
• Customer support communications: Retained for 2 years after the support interaction is closed, unless the subject matter is the subject of an ongoing dispute or legal proceeding.
• Marketing preference data: Retained until you withdraw consent or close your account, whichever is earlier. Marketing communications cease immediately upon opt-out.
• Technical and usage logs: Retained for up to 12 months in identifiable form, then anonymised or deleted.

After the applicable retention period expires, Personal Data is securely deleted or permanently anonymised. Where anonymisation is not practicable, data is destroyed using industry-standard secure deletion methods. Retention periods may be extended where required by a legal hold, regulatory instruction, or active dispute.

s9s9s implements a layered set of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction:

• Transport Security: All data transmitted between your device and the Platform is encrypted using TLS 1.2 or higher with 256-bit AES encryption. Our SSL certificate is maintained current and is validated by an independent certificate authority.
• At-Rest Encryption: Sensitive data stored in s9s9s databases — including identity documents, KYC records, and financial data — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data within s9s9s is strictly role-based. Only personnel with a legitimate operational need to access specific data categories are authorised to do so. Access logs are maintained and reviewed regularly.
• Infrastructure Security: Platform servers are hosted in professionally managed, access-controlled data centres with physical and logical security controls, continuous monitoring, and regular vulnerability assessments.
• Penetration Testing: s9s9s conducts periodic independent penetration tests to identify and remediate security vulnerabilities before they can be exploited.
• Incident Response: s9s9s maintains a documented data breach response plan. In the event of a confirmed breach that poses a risk to your rights, affected Members will be notified without undue delay.

As a Member of s9s9s and a data subject whose Personal Data we process, you hold the following rights with respect to your information:

s9s9s will acknowledge all data rights requests within 5 business days and will provide a substantive response within 30 days. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days with notice to you. We may need to verify your identity before processing a data rights request to ensure that data is not disclosed to unauthorised parties.

Please note that certain rights — particularly the right to erasure — may be limited by our legal obligations to retain data for AML, KYC, and financial record-keeping purposes as described in Section 9.

The s9s9s Platform is strictly for adults aged 21 and above. s9s9s does not knowingly collect, process, or retain Personal Data from any individual under the age of 21.

At registration, all Members are required to confirm that they are at least 21 years old and to provide a date of birth, which is cross-referenced against KYC documents. Any account found to have been registered by a person under 21 will be immediately closed, all balances forfeited, and all associated Personal Data securely deleted, except where retention is required to report the underage access incident to relevant authorities.

The s9s9s Platform may contain links to third-party services, including the interfaces of game studios and payment processors. These third-party services operate independently of s9s9s and have their own privacy policies. s9s9s is not responsible for the data practices of any third-party service, and this Privacy Policy does not extend to any website, application, or service that is not operated directly by s9s9s.

We encourage you to review the privacy policies of any third-party service you interact with through or alongside the Platform, including the terms of your bank (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) or e-wallet provider (OVO, DANA, GoPay, ShopeePay, LinkAja) when making transactions.

s9s9s reviews and updates this Privacy Policy periodically to reflect changes in our data practices, applicable law, or platform features. When material changes are made, we will notify active Members by email and by a prominent notice on the Platform at least 7 days before the revised policy takes effect.

The "Last Updated" date at the top of this page indicates when the current version of this policy came into effect. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated policy. If you do not accept the revised policy, you must discontinue use of the Platform and request account closure by contacting [email protected].

We recommend bookmarking this page and reviewing it periodically, particularly following any notification of update that you receive from us.

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data, please contact the s9s9s data support team:

Our support team includes native Indonesian-speaking agents available 24 hours a day, 7 days a week, including during Ramadhan and all Indonesian national public holidays. If you are unsatisfied with our response to a privacy complaint, you may escalate the matter through the dispute resolution process described in our Terms & Conditions.