Privacy Policy — odin77 Data Protection Notice

1 Introduction

odin77 ("we", "us", "our", "the Platform") operates the online gaming and sports betting website accessible at odin77.cam. In the course of delivering our Services to players across Indonesia and other permitted jurisdictions, we necessarily collect, process, store, and in certain circumstances disclose personal data relating to our registered players and website visitors.

This Privacy Policy sets out a complete and transparent account of our data practices, consistent with internationally recognized data protection principles including the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.

odin77 serves a primarily Indonesian player base, including users in Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, Semarang, Makassar, and Palembang. All data processing activities described in this Policy apply equally to all registered players regardless of their city of residence.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern the overall contractual relationship between odin77 and each registered Player.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, or one or more factors specific to the physical, economic, or social identity of that person.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction.
• "Data Controller" refers to odin77, which determines the purposes and means of processing your Personal Data.
• "Data Processor" refers to any third party that processes Personal Data on behalf of odin77 under a formal data processing agreement.
• "Player" / "You" / "User" refers to any natural person who accesses, registers on, or uses the odin77 Platform in any capacity.
• "Account" refers to a registered player profile on the odin77 Platform, containing personal details, balance information, transaction history, and betting records.
• "KYC" (Know Your Customer) refers to odin77's mandatory identity and document verification process.
• "Cookies" refers to small text files placed on your device by the odin77 website to enable certain technical and analytical functions.

3 Data We Collect

odin77 collects the following categories of Personal Data from Players and website visitors. We collect only the minimum data necessary to deliver our Services effectively and securely.

Data Category	Specific Data Points	Collection Stage
Identity Data	Full legal name, date of birth, gender, nationality, government ID number (e.g., KTP number)	Registration & KYC
Contact Data	Email address, mobile telephone number, residential address (including city and province)	Registration
Financial Data	Bank account name and number (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon), e-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja), deposit and withdrawal history, transaction amounts in IDR	Cashier & KYC
Identity Documents	Scanned copies or photographs of KTP, SIM, passport, proof of address documents, selfie/liveness verification images	KYC
Technical Data	IP address, browser type and version, operating system, device type, screen resolution, time zone, session duration, login timestamps	Automatic (all visits)
Behavioral Data	Game preferences, betting history, deposit frequency, bonus utilization, session duration, pages visited	Ongoing platform use
Communications Data	Contents of support tickets, live chat transcripts, email correspondence with odin77 support staff	Support interactions

odin77 does not collect sensitive categories of Personal Data (such as health data, racial or ethnic origin, political opinions, or religious beliefs) unless specifically required by applicable law or licensing regulations, and only with your explicit consent in such cases.

4 How We Collect Your Data

odin77 collects Personal Data through the following channels:

• Direct submission: Data you voluntarily provide when completing the registration form, KYC verification upload, cashier transactions, or support requests.
• Automated technical collection: Data collected automatically when you access the odin77 website, including IP addresses, browser fingerprinting data, and session analytics through server-side logging and analytics tools.
• Cookie and tracking technologies: Behavioral and preference data gathered via first-party cookies and, where applicable, third-party analytics pixels embedded in the Platform. See Clause 10 for full details.
• Payment processor data: Transaction confirmation data relayed by your bank (BCA, BRI, BNI, Mandiri, etc.) or e-wallet provider (OVO, DANA, GoPay, ShopeePay, LinkAja) upon completion of a deposit or withdrawal.
• Third-party identity verification services: Where odin77 engages a KYC technology provider to assist with document verification, that provider may return structured data fields (e.g., confirmed full name, date of birth, document validity status) to odin77 systems.
• Fraud detection and security tools: Device fingerprinting and behavioral analytics data generated by anti-fraud systems operating on the Platform to detect multiple-account creation, bonus abuse, and suspicious transaction patterns.

5 Legal Basis for Processing

odin77 processes your Personal Data on one or more of the following legal grounds, depending on the nature of the processing activity:

• Contractual necessity: Processing required to enter into and perform the contract between odin77 and the Player (i.e., the Terms & Conditions), including Account creation, transaction processing, and customer support.
• Compliance with legal obligations: Processing required to fulfill odin77's obligations under applicable law and licensing conditions, including KYC/AML (Anti-Money Laundering) verification, fraud prevention, and regulatory reporting.
• Legitimate interests: Processing necessary for purposes of odin77's legitimate business interests, where those interests are not overridden by your fundamental privacy rights — for example, security monitoring, fraud prevention, and internal analytics to improve Platform performance.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — for example, sending you promotional communications and personalized bonus offers. You may withdraw consent at any time by contacting support.

6 How We Use Your Data

odin77 uses collected Personal Data for the following specific purposes:

• Account management: Creating, maintaining, and administering your Player Account, including authentication, password recovery, and Account security.
• Transaction processing: Executing deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja; reconciling balances; issuing receipts.
• Identity and age verification: Confirming that all Players are aged 21 or above and are who they claim to be, in compliance with odin77's licensing obligations and responsible gaming commitments.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, multiple-account creation, bonus abuse, money laundering, and unauthorized Account access.
• Customer support: Responding to your inquiries, resolving disputes, processing complaints, and providing technical assistance through our 24/7 support team, including native Indonesian-speaking agents.
• Legal compliance: Meeting regulatory requirements imposed by odin77's licensing authority, including retention of transaction records and submission of required reports.
• Personalization and marketing: Where you have given explicit consent, sending you tailored promotional offers, bonus notifications, and event reminders (e.g., BRI Liga 1 match promotions, seasonal offers during Idul Fitri or Ramadhan). You may opt out at any time.
• Platform improvement: Analyzing aggregated, anonymized behavioral data to improve game selection, payment flows, and overall user experience on the Platform.
• Responsible gaming monitoring: Using Account behavior data to identify players who may be exhibiting signs of problem gambling, in order to proactively offer responsible gaming tools and support.

7 Data Sharing & Disclosure

odin77 does not sell, rent, or trade your Personal Data to any third party for commercial purposes. We may disclose your Personal Data only in the following circumstances:

7.1 Service Providers and Data Processors

odin77 engages carefully vetted third-party service providers who process Personal Data on our behalf under strict contractual data processing agreements. These include:

• Payment processing partners (banks and e-wallet operators such as BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja) for the sole purpose of executing transactions.
• KYC and identity verification technology providers who assist with document authentication and age verification.
• Anti-fraud and security technology providers who analyze transaction patterns and device data to protect the integrity of the Platform.
• Game content providers (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) who may receive anonymized session data necessary to deliver their game interfaces.
• Customer support platform providers who host our ticketing and live chat systems.
• Analytics and performance monitoring tools that process aggregated, anonymized usage data to help us improve Platform performance.

All third-party data processors engaged by odin77 are contractually prohibited from using your Personal Data for any purpose other than the specific service they provide to odin77.

7.2 Legal and Regulatory Disclosure

odin77 may disclose Personal Data to competent authorities, regulators, or law enforcement agencies where required by applicable law, a valid court order, or the conditions of odin77's international gaming license. Such disclosures will be made only to the extent strictly necessary and, where legally permissible, we will notify you in advance.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of odin77's business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will notify you via the email address registered to your Account before your Personal Data becomes subject to a materially different privacy policy as a result of such a transfer.

8 Data Retention

odin77 retains Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law or licensing obligations. Our standard retention periods are as follows:

• Account and identity data: Retained for the lifetime of your active Account, plus a minimum of 5 years following Account closure, to comply with anti-money laundering and licensing record-keeping obligations.
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction, in accordance with standard financial record-keeping requirements.
• KYC documents: Retained for the lifetime of your Account plus 5 years following Account closure or the date of the last regulated transaction, whichever is later.
• Customer support communications: Retained for 3 years from the date of the last interaction, or longer if the communication relates to an unresolved dispute or legal matter.
• Technical and behavioral data: Aggregated and anonymized after 12 months from collection; individual-level records are deleted within 24 months of collection unless required for an ongoing investigation.
• Marketing consent records: Retained for the duration of your consent plus 3 years after withdrawal, to demonstrate proof of consent.

When Personal Data is no longer required, odin77 will securely delete or irreversibly anonymize it using industry-standard data destruction methods.

9 Security Measures

odin77 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption applied to all data transmitted between your browser or device and odin77's servers, protecting login credentials, financial transactions, and personal information in transit.
• Encryption at rest for all sensitive Personal Data stored on odin77's servers, including KYC documents and financial account details.
• Access controls and role-based permissions ensuring that only authorized odin77 personnel with a legitimate operational need can access Personal Data, and only to the minimum extent necessary for their role.
• Multi-factor authentication for all internal staff systems that provide access to Player data.
• Regular penetration testing and security audits conducted by qualified third-party security professionals to identify and remediate vulnerabilities.
• Anti-fraud and anomaly detection systems that monitor transaction patterns and login behavior in real time to flag and investigate suspicious activity.
• Secure data center infrastructure with physical access controls, redundant systems, and disaster recovery protocols.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, odin77 will notify affected Players without undue delay and will report the breach to the relevant supervisory authority as required by applicable law.

10 Cookies & Tracking Technologies

odin77 uses cookies and similar tracking technologies on the Platform. Cookies are small data files stored on your device that enable certain website functions and help us understand how users interact with our Platform. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the basic operation of the Platform, including maintaining your login session, securing your Account, and enabling the cashier to process transactions. These cookies cannot be disabled without impairing core Platform functionality.
• Functional Cookies: Used to remember your preferences (such as preferred language display, game filters, and deposit method) to provide a more personalized experience across sessions.
• Analytics Cookies: Used to collect aggregated data about how visitors use the Platform — including pages visited, session duration, and navigation paths — to help odin77 improve the user experience. This data is processed in anonymized or pseudonymized form.
• Security and Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, multiple-account creation, and unauthorized access by assigning a unique device identifier and monitoring behavioral consistency across sessions.

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary or security cookies may significantly impair your ability to use the Platform, including preventing login and payment processing. odin77 does not use third-party advertising cookies or behavioral targeting cookies that track you across external websites.

11 Your Rights

Subject to applicable data protection law and certain conditions and exceptions, you hold the following rights in respect of your Personal Data held by odin77:

• Right of Access: You have the right to request a copy of the Personal Data odin77 holds about you, along with information about how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data we hold about you.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where processing is unlawful. Note that this right is subject to overriding legal obligations — for example, we are required to retain certain transaction and KYC records for a minimum statutory period.
• Right to Restrict Processing: You may request that odin77 restrict the processing of your Personal Data in certain circumstances, for example while the accuracy of data you have contested is being verified.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, and is carried out by automated means, you may request that odin77 provide your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing of your Personal Data where that processing is based on odin77's legitimate interests, including profiling for responsible gaming monitoring purposes.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, please submit a written request to [email protected]. odin77 will respond to all verified requests within 30 days of receipt. We may require proof of identity before processing your request to protect against unauthorized access to another person's data.

12 Minors & Age Verification

odin77 is strictly an adults-only platform. We do not knowingly collect Personal Data from any person under the age of 21. Age verification is a mandatory component of our registration and KYC processes. Where odin77 discovers or has reasonable grounds to suspect that Personal Data has been provided by or collected from a person under 21 years of age, we will:

• Immediately suspend the associated Account pending investigation.
• Delete all Personal Data associated with the underage individual as promptly as possible, except where retention is required by law.
• Reverse any financial transactions associated with the Account to the greatest extent practicable.
• Report the matter to the relevant regulatory authority or safeguarding body where required by applicable law.

If you are a parent or guardian and believe that a minor under your care has registered on odin77, please contact us immediately at [email protected] so that we can take prompt remedial action.

13 International Data Transfers

odin77 operates internationally, and your Personal Data may be transferred to, stored on, and processed by servers or service providers located outside of Indonesia. Where such transfers occur, odin77 ensures that appropriate safeguards are in place to maintain the level of protection described in this Privacy Policy. These safeguards may include:

• Contractual clauses in data processing agreements with service providers that impose data protection obligations equivalent to those described in this Policy.
• Transfers to jurisdictions recognized as providing an adequate level of data protection by relevant international standards.
• Technical measures such as end-to-end encryption ensuring that data remains protected in transit regardless of the physical location of the receiving server.

By using the odin77 Platform, you acknowledge and consent to the transfer of your Personal Data to servers and service providers in jurisdictions outside Indonesia, subject to the safeguards described above.

14 Third-Party Services

The odin77 Platform integrates third-party services including game engines from providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. These providers may collect certain technical data (such as game session identifiers and RNG seed data) necessary to deliver their games. Such data collection is governed by each provider's own privacy practices and is subject to their respective data processing agreements with odin77.

odin77 does not host external links to third-party websites. However, if you independently navigate to any third-party site, please be aware that odin77 has no control over and accepts no responsibility for the privacy practices or content of those sites. This Privacy Policy applies solely to data processed in connection with the odin77 Platform at odin77.cam.

15 Policy Amendments

odin77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or licensing requirements. The "Last Updated" date displayed at the top of this page will be revised whenever a material change is made.

Where a change is material — meaning it significantly affects how we use your Personal Data or the rights available to you — odin77 will notify registered Players via the email address on their Account at least 14 days before the change takes effect. Your continued use of the Platform after the effective date of any amendment constitutes acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed of how odin77 handles your Personal Data.

16 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or odin77's data practices, please contact our Data Protection team in writing:

If you are dissatisfied with odin77's response to your privacy inquiry or data subject request, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction. odin77 will cooperate fully with any such authority in the investigation of complaints relating to our data practices.

For general account support, game queries, or payment assistance, our 24/7 customer support team — including native Indonesian-speaking agents — is available at the same support address. Please use the subject line above specifically for privacy and data protection matters to ensure your inquiry is directed to the appropriate team.