Privacy Policy

1 Definitions

The following definitions apply throughout this Privacy Policy:

• "cill99", "we", "us", "our" — the internationally registered entity operating the cill99 platform at https://cill99.cam.
• "Platform" — the cill99 website, all associated sub-domains, mobile-optimized pages, and any software interfaces through which Services are delivered.
• "Player", "you", "your" — any natural person who accesses, registers on, or interacts with the cill99 Platform.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, date of birth, national identity number, bank account details, IP address, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, deletion, or destruction.
• "Data Controller" — cill99, which determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" — any third-party entity that processes Personal Data on behalf of cill99 under a formal data-processing agreement.
• "KYC" — the Know Your Customer identity and age verification process conducted before processing withdrawals or at any point cill99's compliance team deems necessary.
• "Cookies" — small text files placed on your device by the Platform to support session management, analytics, and personalization functions.

2 Scope & Application

This Privacy Policy applies to all Personal Data collected by cill99 in connection with the use of the Platform and its Services — including sports betting, live casino, togel (Indonesia's traditional numbers lottery), slot gacor (high-frequency payout slot games), and all other game types offered on the Platform.

This Policy applies regardless of how you access the Platform — whether via desktop browser, mobile browser, or any future application. It applies to Players based in Indonesia as well as to any other individual who accesses the Platform from any other jurisdiction.

By registering an account or continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your Personal Data as described herein.

3 Data We Collect

cill99 collects Personal Data across several categories. The table below summarizes the types of data we collect and their primary purposes:

We do not collect Special Category Data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) unless it is strictly required for a specific regulatory obligation and you have provided explicit consent.

4 How We Collect Your Data

cill99 collects Personal Data through the following channels and mechanisms:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions.
• Automated collection: Technical and behavioral data collected automatically when you access and use the Platform, including via Cookies and similar tracking technologies (see Section 10).
• Payment service providers: Transaction confirmation data received from banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) when you initiate a deposit or withdrawal.
• Identity verification providers: During the KYC process, cill99 may use trusted third-party identity verification services to confirm the authenticity of documents you submit. These providers return a verification result to cill99 and do not retain your documents independently beyond their own stated data retention periods.
• Fraud prevention and risk services: cill99 may receive data signals from third-party fraud detection platforms to help identify suspicious act ivity and protect the integrity of the Platform.

5 Purposes of Processing

cill99 processes your Personal Data for the following specific purposes:

• Account creation and management: To register your account, verify your identity, maintain your account profile, and deliver the full range of Services available on the Platform.
• Transaction processing: To facilitate deposits and withdrawals through your nominated Indonesian bank account or e-wallet, and to maintain an accurate record of your transaction history.
• KYC and age verification: To confirm that you are at least 21 years of age and to comply with applicable anti-money-laundering (AML) and know-your-customer (KYC) obligations.
• Responsible gaming: To monitor betting patterns, identify potential indicators of problem gambling, enforce any self-imposed limits or exclusions you have set, and proactively reach out where we have a duty of care concern.
• Customer support: To respond to your inquiries, resolve disputes, and maintain records of communications for quality assurance and training purposes.
• Fraud prevention and platform security: To detect, investigate, and prevent fraudulent transactions, account takeovers, multi-accounting, and other prohibited conduct as defined in our Terms & Conditions.
• Legal and regulatory compliance: To fulfill obligations imposed by applicable financial crime legislation, data protection regulations, and any lawful requests from competent authorities.
• Marketing and promotions: Where you have given consent, to send you information about cill99 offers, seasonal promotions (such as those tied to Idul Fitri or Ramadhan), and platform updates. You may withdraw this consent at any time.
• Platform improvement: To analyze aggregated usage data and improve the design, performance, and content of the cill99 Platform on an ongoing basis.

6 Legal Basis for Processing

cill99 relies on the following legal bases when processing your Personal Data:

• Contractual necessity: Processing required to enter into and perform the contract with you — specifically the registration, account management, and transaction processing activities described in Section 5.
• Legal obligation: Processing required to comply with AML, KYC, and other applicable regulatory obligations, including age verification and transaction record-keeping.
• Legitimate interests: Processing conducted to pursue cill99's legitimate business interests — such as fraud detection, platform security, and platform improvement — where those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for marketing communications and non-essential Cookies, where your explicit prior consent has been obtained. You may withdraw consent at any time by contacting [email protected] or using the opt-out mechanism provided in each marketing communication.

7 Data Sharing & Disclosure

cill99 does not sell, rent, or trade your Personal Data. We share your data only in the circumstances described below, and only to the extent strictly necessary for each purpose:

• Payment service providers: Banks and e-wallet operators (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja) receive the transaction data necessary to process your deposits and withdrawals. These entities act as independent data controllers under their own privacy policies.
• Identity verification providers: Third-party KYC service providers receive the identity documents and data you submit during the verification process, solely for the purpose of confirming your identity and age.
• Game content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive limited session and wagering data necessary to deliver their game content within the Platform.
• Fraud detection and risk management platforms: Aggregated or anonymized behavioral and technical data may be shared with fraud prevention services to protect the Platform and its players.
• Legal and regulatory authorities: cill99 will disclose Personal Data to law enforcement agencies, regulatory bodies, or courts where required by a valid legal obligation, court order, or official regulatory request.
• Corporate transactions: In the event of a merger, acquisition, restructuring, or sale of all or part of cill99's business, Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

8 International Data Transfers

cill99 operates internationally, and your Personal Data may be transferred to, stored in, or processed in countries outside of Indonesia. These countries may have data protection laws that differ from those applicable in Indonesia.

Where such transfers occur, cill99 ensures that appropriate safeguards are in place to protect your Personal Data, including:

• Transfers to countries that have been assessed as providing an adequate level of data protection by relevant international standards.
• The use of standard contractual clauses or equivalent transfer mechanisms with Data Processors located in countries without an adequacy determination.
• Binding internal policies that require all group entities and contracted processors to handle your data in accordance with the standards set out in this Privacy Policy.

By using the cill99 Platform, you acknowledge and consent to these international data transfers where they are necessary for the delivery of our Services.

9 Data Retention

cill99 retains your Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following retention periods apply as a general guide:

• Account and identity data: Retained for the duration of your account and for a minimum of five years following account closure, in compliance with AML record-keeping requirements.
• Transaction data: Retained for a minimum of five years from the date of each transaction to satisfy financial record-keeping obligations.
• KYC documentation: Retained for a minimum of five years following account closure or the completion of the relevant KYC review, whichever is later.
• Support communications: Retained for two years from the date of the most recent interaction, unless a dispute is active — in which case records are retained until the dispute is fully resolved.
• Technical and behavioral data (logs): Retained for up to twelve months in identifiable form, after which they are aggregated or anonymized for analytical purposes.
• Marketing preference data: Retained until you withdraw consent or request deletion, subject to the minimum retention periods above.

At the end of the applicable retention period, Personal Data is securely deleted or anonymized in accordance with cill99's internal data disposal procedures.

10 Cookies & Tracking Technologies

cill99 uses Cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary Cookies: Required for the Platform to function correctly — including session management, login state, and security tokens. These Cookies cannot be disabled without impairing core Platform functionality.
• Performance and analytics Cookies: Used to collect aggregated data on how players interact with the Platform — such as pages visited, session duration, and error events — to help us improve the Platform's performance and usability.
• Functional Cookies: Used to remember your preferences — such as your preferred language, display settings, and notification preferences — to provide a more personalized experience on subsequent visits.
• Marketing Cookies: Used, with your consent, to deliver relevant promotional content within the Platform. These Cookies track interactions with cill99's own promotional materials only; cill99 does not deploy third-party advertising network Cookies.

You can manage your Cookie preferences at any time through your browser settings. Please note that disabling certain Cookies may affect the functionality of the Platform. Clearing all Cookies will log you out of your active session.

11 Your Privacy Rights

Subject to applicable law and certain conditions, you hold the following rights in relation to your Personal Data held by cill99:

• Right of Access: You may request a copy of the Personal Data cill99 holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any Personal Data that is inaccurate, incomplete, or out of date.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to cill99's legal retention obligations.
• Right to Restriction of Processing: You may request that cill99 restrict the processing of your Personal Data in certain circumstances — for example, while the accuracy of data is being verified following a rectification request.
• Right to Data Portability: Where processing is based on your consent or on a contract, you may request that cill99 provide your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, cill99 will cease that processing immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please submit a written request to [email protected] (plain text — not a clickable link). cill99 will respond within 30 calendar days of receiving a valid, verifiable request. We may need to verify your identity before processing certain requests.

12 Children's Privacy

The cill99 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or retain Personal Data from any person under the age of 21.

If cill99 discovers or is notified that an account belongs to a person under 21 years of age, the account will be immediately closed, all funds will be forfeited, and all associated Personal Data will be deleted to the extent permitted by our legal retention obligations.

If you are a parent or guardian and have reason to believe that a minor has registered on the cill99 Platform, please contact us immediately at [email protected] (plain text — not a clickable link) so that we can investigate and take appropriate action without delay.

13 Security Measures

cill99 implements a comprehensive range of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, alteration, or disclosure:

• Transport Layer Security (TLS): All data in transit between your device and cill99's servers is encrypted using current TLS standards.
• Data encryption at rest: Sensitive Personal Data — including identity documents and financial account details — is encrypted when stored on cill99's infrastructure.
• Access controls: Access to Personal Data within cill99's systems is restricted to authorized personnel on a strict need-to-know basis, enforced through role-based access control and multi-factor authentication.
• Intrusion detection and monitoring: cill99's infrastructure is continuously monitored for anomalous activity. Automated alerts trigger immediate investigation of potential security incidents.
• Regular security assessments: cill99 conducts periodic security reviews and penetration testing to identify and remediate vulnerabilities before they can be exploited.

While cill99 takes all reasonable precautions to secure your data, no system can guarantee absolute security. In the unlikely event of a data breach that affects your rights and freedoms, cill99 will notify affected Players promptly in accordance with applicable obligations.

14 Third-Party Links

The cill99 Platform does not contain links to third-party websites as a matter of general design policy. However, in the event that any third-party content, game provider interface, or payment gateway redirect is accessed via the Platform, please be aware that:

• cill99 has no control over the content, privacy practices, or data handling of third-party websites or applications.
• This Privacy Policy applies solely to the cill99 Platform. It does not govern the privacy practices of third parties, including payment service providers, game studios, or identity verification services, which operate under their own respective privacy policies.
• cill99 encourages Players to review the privacy policies of any third-party service they interact with in connection with their use of the Platform.

15 Amendments to This Policy

cill99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. The following process governs all amendments:

• Material changes — those that meaningfully affect your rights or how your data is processed — will be communicated to you via a notification displayed upon login or via the email address registered to your account, with a minimum of 14 days' notice before the amended Policy takes effect.
• Non-material changes (such as typographical corrections or clarifications that do not alter your substantive rights) may take effect immediately upon publication on the Platform.
• The "Last Updated" date at the top of this page reflects the date on which the current version of the Privacy Policy was published.
• Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. If you do not agree to the updated terms, you should cease using the Platform and request account closure prior to the effective date.

16 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or to cill99's data practices, please contact our privacy team through the following official channel:

• Email: [email protected] (plain text — not a clickable link)
• Response Time: cill99 aims to acknowledge all privacy-related inquiries within 72 hours and to provide a substantive response within 30 calendar days (WIB, UTC+7).
• Support Hours: 24 hours a day, 7 days a week, including Indonesian public holidays such as Idul Fitri and Nyepi.

If you are not satisfied with cill99's response to your privacy inquiry or complaint, you may have the right to escalate your concern to a relevant data protection supervisory authority in the jurisdiction applicable to your situation.