Privacy Policy — thr777

1 Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, email address, phone number, financial account details, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, erasure, or destruction, whether carried out by automated or manual means.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, thr777.
• "Data Processor" means any third party that processes Personal Data on behalf of thr777 in accordance with our instructions and applicable data protection obligations.
• "Player" / "You" means any individual who accesses, browses, or holds a registered Account on the thr777 Platform.
• "Platform" means the thr777 website, its mobile-optimized versions, and all associated digital services operating under the thr777 brand at https://thr777.cam.
• "KYC" means Know Your Customer — the identity and age verification process mandated by thr777 to confirm a Player's eligibility and identity prior to withdrawal processing or upon compliance review.
• "Cookies" means small text files placed on your device by the Platform to enable certain functionality, improve user experience, and support analytical measurement.

2 Data Controller

thr777 operates as the Data Controller for all Personal Data collected through the Platform. All inquiries, data subject requests, or complaints relating to the handling of your Personal Data should be directed to thr777 using the contact details provided in Section 14 of this Policy.

Where thr777 engages third-party service providers (Data Processors) to perform functions on our behalf — such as payment gateway processing, identity verification services, or analytics — those providers are bound by contractual data protection obligations consistent with this Policy and applicable law. thr777 remains responsible for ensuring that any Personal Data shared with Data Processors is handled appropriately.

3 Personal Data We Collect

thr777 collects Personal Data across several categories. The specific data collected depends on the nature of your interaction with the Platform:

3.1 Identity & Contact Data

This data is collected during the account registration process and, more comprehensively, during the KYC verification stage. For Indonesian residents, the primary identity document is the Kartu Tanda Penduduk (KTP); international players may submit a valid passport.

3.2 Financial Data

Financial data is collected to facilitate deposits and withdrawals, to verify payment method ownership as part of anti-fraud checks, and to maintain transaction records required for compliance and dispute resolution. thr777 does not store full card numbers or complete banking credentials on its servers.

3.3 Gaming Activity Data

Gaming activity data is essential for administering your Account, resolving disputes, calculating bonus eligibility, and supporting our responsible gaming monitoring obligations. This data also enables us to detect and investigate potential fraud or prohibited conduct as described in our Terms & Conditions.

3.4 Technical & Device Data

Technical data is collected automatically when you access the Platform. It is used for security monitoring, fraud prevention, platform optimization, and to ensure the integrity of the gaming environment. Geolocation data at the country and region level is used to verify eligibility and to tailor the Platform experience for Indonesian users across Jakarta, Surabaya, Bali, Bandung, Medan, and beyond.

3.5 Communications Data

All communications between you and thr777 — whether via email, live chat, or phone — are recorded and stored for quality assurance, training, compliance, and dispute resolution purposes. Communications data enables us to provide effective customer support and to maintain a complete record of your service history with the Platform.

4 How Personal Data Is Collected

4.1 Direct Collection

The majority of Personal Data is provided directly by you when you:

• Register an Account on thr777 and complete the registration form.
• Submit identity documents during the KYC verification process.
• Add or update payment methods in your Account settings.
• Place wagers, make deposits, or request withdrawals.
• Contact our customer support team via email or live chat.
• Participate in promotions, surveys, or feedback requests.
• Configure responsible gaming settings such as deposit limits or self-exclusion.

4.2 Automated Collection

Certain data is collected automatically through the normal operation of the Platform and your device's interaction with our servers:

• IP address, device identifiers, browser fingerprinting data, and session metadata collected via server logs.
• Cookies and similar tracking technologies used for authentication, session management, fraud prevention, and analytics.
• Gaming activity data recorded automatically by the platform software whenever you place a wager or participate in a game.

4.3 Third-Party Sources

In limited circumstances, thr777 may supplement your data with information obtained from third-party sources:

• Identity verification service providers that cross-reference your submitted documents against authoritative databases.
• Payment processors (including Indonesian banks such as BCA, BRI, BNI, Mandiri, and e-wallet providers OVO, DANA, GoPay) that confirm transaction status and account ownership.
• Fraud prevention databases that provide risk scoring and flag suspicious patterns.

5 Purpose of Processing & Legal Basis

thr777 processes your Personal Data only for specified, explicit, and legitimate purposes. The table below outlines the primary purposes for which we process each category of Personal Data and the legal basis that permits such processing:

6 Data Sharing & Third-Party Disclosure

6.1 When We Share Data

thr777 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share Personal Data only in the limited circumstances outlined below:

6.2 Service Providers (Data Processors)

thr777 engages trusted third-party service providers to perform essential functions on our behalf. These Data Processors are contractually obligated to handle your Personal Data only in accordance with our instructions and to implement appropriate security measures. Categories of service providers include:

• Payment Processors: Indonesian bank integrations (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP) and e-wallet providers (OVO, DANA, GoPay) process deposit and withdrawal transactions on our behalf.
• Identity Verification Services: Third-party KYC platforms verify the authenticity of submitted documents and cross-check data against national identity databases.
• Hosting & Infrastructure Providers: Cloud service providers host our servers, databases, and backup systems.
• Anti-Fraud & Security Services: Specialized providers monitor for suspicious activity, bot detection, and account takeover attempts.
• Customer Support Tools: Live chat software and ticketing systems store communications data to enable efficient support operations.
• Analytics Platforms: Aggregated, anonymized usage data may be shared with analytics tools to measure platform performance and user behavior trends.

6.3 Legal & Regulatory Disclosure

thr777 may disclose your Personal Data where required or permitted by law:

• To comply with valid legal processes such as court orders, subpoenas, or regulatory investigations.
• To cooperate with law enforcement authorities investigating fraud, money laundering, or other criminal activity.
• To enforce our Terms & Conditions, including the investigation and resolution of Terms violations.
• To protect the rights, property, or safety of thr777, our players, or the public.

6.4 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or substantially all of thr777's assets, your Personal Data may be transferred to the acquiring entity. In such circumstances, thr777 will notify affected players and ensure that the receiving party commits to handling Personal Data in accordance with this Privacy Policy or a policy of equivalent protection.

6.5 No Cross-Border Transfers Without Safeguards

thr777 operates primarily within Indonesia and processes the majority of Personal Data on servers located within the region. Where it is necessary to transfer Personal Data outside Indonesia — such as to international service providers — thr777 implements appropriate safeguards including standard contractual clauses, data processing agreements, and encryption to ensure that your Personal Data receives an adequate level of protection.

7 Data Retention

7.1 Retention Principles

thr777 retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal, regulatory, or contractual obligations. Retention periods vary by data category:

• Active Account Data: Identity, contact, financial, and gaming activity data are retained for the entire duration of your active Account relationship with thr777 plus an additional period following Account closure as described below.
• Post-Closure Retention: Following voluntary or enforced Account closure, thr777 retains identity, KYC documents, transaction history, and gaming records for a minimum of 5 years to meet anti-money laundering (AML) record-keeping obligations, tax compliance, and to defend against potential legal claims.
• Communications Data: Customer support correspondence and chat transcripts are retained for 3 years to support quality assurance, complaint resolution, and regulatory audit requirements.
• Marketing Consent Records: Records of consent and consent withdrawals are retained indefinitely to demonstrate compliance with applicable data protection and marketing regulations.
• Technical & Analytics Data: Server logs, IP addresses, and anonymized usage data are typically retained for 12 months unless required longer for fraud investigation or security incident response.

7.2 Secure Deletion

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized such that it can no longer be attributed to an identifiable individual. Deletion methods include cryptographic erasure of encryption keys and secure data wiping procedures that meet industry standards.

8 Security Measures

8.1 Technical Safeguards

thr777 employs a comprehensive suite of technical security measures to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and the thr777 Platform is protected by enterprise-grade 256-bit SSL/TLS encryption.
• Encrypted Data Storage: Personal Data stored in our databases is encrypted at rest using AES-256 encryption standards.
• Firewall & Intrusion Detection: Network-level firewalls and real-time intrusion detection systems monitor for and block malicious traffic.
• Multi-Factor Authentication (MFA): Administrative access to sensitive systems requires multi-factor authentication.
• Regular Security Audits: Independent third-party security audits and penetration testing are conducted on a periodic basis to identify and remediate vulnerabilities.
• Automated Fraud Detection: Machine learning algorithms continuously monitor for suspicious patterns indicative of account takeover, payment fraud, or bonus abuse.

8.2 Organizational Safeguards

• Access Controls: Personal Data is accessible only to thr777 employees and contractors who require it to perform their job functions, under strict confidentiality obligations.
• Staff Training: All personnel with access to Personal Data receive regular training on data protection principles, security protocols, and incident response procedures.
• Incident Response Plan: thr777 maintains a documented security incident response plan to ensure rapid detection, containment, and notification in the event of a data breach.

8.3 Your Responsibility

While thr777 implements robust security measures, the security of your Account also depends on your own conduct. You are responsible for:

• Maintaining the confidentiality of your Account password and not sharing it with any third party.
• Using a strong, unique password not used on any other platform.
• Logging out of your Account when using shared or public devices.
• Notifying thr777 immediately if you suspect unauthorized access to your Account.

9 Cookies & Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They enable the website to recognize your device on return visits and to remember certain preferences or settings. thr777 uses both first-party cookies (set directly by our Platform) and third-party cookies (set by external service providers integrated into our Platform).

9.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the basic functioning of the Platform, including user authentication, session management, and load balancing. These cookies cannot be disabled without severely impairing Platform functionality.
• Functional Cookies: Remember your language preference, time zone (WIB, WITA, WIT), and other personalization settings to enhance user experience.
• Analytics Cookies: Collect aggregated, anonymized information about how visitors use the Platform — such as which pages are most frequently visited and whether users encounter error messages — to help us improve site performance and content.
• Security Cookies: Detect and prevent fraudulent activity, identify bot traffic, and protect against brute-force login attempts.

9.3 Managing Cookie Preferences

Most web browsers allow you to control cookies through their settings. You can configure your browser to block all cookies, accept only first-party cookies, or prompt you before accepting each cookie. Please note that blocking strictly necessary cookies will prevent you from accessing certain features of the Platform, including logging into your Account.

10 Your Data Protection Rights

As a data subject, you possess certain rights regarding your Personal Data held by thr777. The availability and scope of these rights may vary depending on the applicable data protection laws in your jurisdiction. thr777 respects and honors the following rights:

10.1 Right of Access

You have the right to request confirmation of whether thr777 processes your Personal Data and, if so, to access that data along with information about the purposes of processing, the categories of data held, and the recipients to whom it has been disclosed.

10.2 Right to Rectification

You may request correction of any inaccurate or incomplete Personal Data held about you. You can update certain Account details (email, phone number) directly through your Account settings; for changes to identity documents or financial details, contact our support team.

10.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your Personal Data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or when you withdraw consent upon which processing was based. Please note that thr777 is legally required to retain certain categories of data (identity, KYC, transaction history) for defined retention periods even after Account closure, as outlined in Section 7.

10.4 Right to Restriction of Processing

You may request that thr777 restrict processing of your Personal Data in specific situations, such as while a dispute over data accuracy is being resolved or where you object to processing but thr777 requires time to verify whether legitimate grounds for processing override your objection.

10.5 Right to Data Portability

Where technically feasible, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and to request that thr777 transmit that data directly to another data controller.

10.6 Right to Object

You may object to processing of your Personal Data where that processing is based on legitimate interests. thr777 will cease processing unless we can demonstrate compelling legitimate grounds that override your interests or where processing is necessary for the establishment, exercise, or defense of legal claims.

10.7 Right to Withdraw Consent

Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

10.8 Exercising Your Rights

To exercise any of the above rights, please submit a written request to [email protected] including sufficient information to verify your identity. thr777 will respond to verified requests within 30 days. In complex cases, we may extend this period by an additional 30 days and will notify you of the extension and the reasons for the delay.

11 Protection of Minors

thr777 is committed to preventing underage gambling and does not knowingly collect Personal Data from individuals under the age of 21. The Platform is intended exclusively for adults who meet the eligibility requirements set out in our Terms & Conditions.

All new players are required to provide date-of-birth information during registration, and age verification is performed during the KYC process through the submission of government-issued identification documents. If thr777 becomes aware that we have inadvertently collected Personal Data from an individual under 21, we will take immediate steps to delete that data, close the Account, and forfeit any associated funds in accordance with our Terms.

Parents and guardians who believe that a minor has accessed thr777 and provided Personal Data should contact us immediately at [email protected] so that appropriate action can be taken.

12 Third-Party Links & Services

The thr777 Platform may contain links to third-party websites, services, or applications operated by payment providers, game studios, or other partners. thr777 is not responsible for the privacy practices or content of these external sites. When you navigate away from the thr777 Platform by clicking a third-party link, this Privacy Policy no longer applies, and you are subject to the privacy policy of the destination site.

We encourage you to review the privacy policies of any third-party sites you visit to understand how your Personal Data will be collected, used, and protected by those entities. thr777 does not endorse or assume any responsibility for third-party privacy practices.

13 Policy Amendments

thr777 reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or business operations. Where changes are material and may adversely affect your rights, we will endeavor to provide reasonable advance notice by publishing the updated Policy on the Platform and, where practicable, notifying registered players via email.

The date of the most recent revision is displayed at the top of this page under "Last Updated." Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you must cease using the Platform and may request Account closure in accordance with our Terms & Conditions.

It is your responsibility to review this Privacy Policy periodically to remain informed of how thr777 collects, uses, and protects your Personal Data.

14 Contact & Complaints

14.1 Data Protection Inquiries

If you have any questions, concerns, or complaints regarding this Privacy Policy, our data processing practices, or the exercise of your data protection rights, please contact the thr777 Data Protection Team:

14.2 Right to Lodge a Complaint

If you believe that thr777 has processed your Personal Data in violation of applicable data protection laws or if you are dissatisfied with our response to your data protection inquiry, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. For Indonesian residents, this may include the Ministry of Communication and Informatics or other competent regulatory bodies with jurisdiction over data protection matters.

14.3 Escalation Process

If your initial inquiry to our support team does not resolve your concern, you may request escalation to a senior member of the thr777 Compliance & Data Protection team by clearly marking your correspondence "ESCALATION REQUEST." Escalated matters will be reviewed independently and a final response issued within 14 business days.