Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by boba99 through our website at https://boba99.cam, mobile applications, customer service channels, and any other platforms where boba99 services are offered. By accessing or using boba99 services, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.

If you do not agree with our privacy practices, please do not use boba99 services. This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of boba99 services.

Data Controller: boba99 acts as the data controller for all personal information collected through our services. We determine the purposes and means of processing your personal data.

2. Information We Collect

boba99 collects various types of personal information to provide, maintain, and improve our services. The information we collect falls into several categories:

2.1 Information You Provide Directly

When you register for a boba99 account or use our services, you provide us with the following information:

• Account Registration Information: Full name as shown on your Indonesian national identity card (KTP), date of birth, email address, mobile phone number, residential address, username, and password.
• Identity Verification Documents: Copies or photographs of your KTP (Kartu Tanda Penduduk), proof of address documents (utility bills, bank statements), and any additional identification documents required for KYC (Know Your Customer) compliance.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account information (OVO, DANA, GoPay account numbers), payment transaction histories, deposit and withdrawal records.
• Communication Data: Information you provide when contacting customer support, including live chat transcripts, email correspondence, WhatsApp messages, and feedback forms.
• Marketing Preferences: Your communication preferences and consent for receiving promotional materials.

2.2 Information Collected Automatically

When you access and use boba99 services, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, unique device identifiers, mobile network information.
• Usage Data: Pages visited, features used, games played, betting history, session duration, click patterns, navigation paths through the website.
• Technical Data: IP address, login timestamps, geographic location (derived from IP address), referring/exit pages, date/time stamps.
• Gameplay Data: Bets placed, games played, wager amounts, win/loss records, bonus usage, game preferences, playing patterns.
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies to enhance user experience and analyze site usage.

2.3 Information from Third Parties

We may receive information about you from third-party sources:

• Payment Processors: Transaction verification data from Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay).
• Identity Verification Services: Verification results from third-party KYC service providers who confirm the authenticity of submitted documents.
• Game Providers: Gaming activity data from our partners including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and other integrated providers.
• Fraud Prevention Services: Risk assessment data from specialized fraud detection and prevention partners.

3. How We Use Your Information

boba99 uses your personal information for the following legitimate purposes:

3.1 Service Provision and Account Management

• Creating, maintaining, and securing your boba99 account.
• Processing your deposits, withdrawals, and financial transactions.
• Providing access to gaming products, sports betting markets, casino games, and live dealer experiences.
• Verifying your identity, age (21+ requirement), and eligibility to use our services.
• Maintaining accurate records of your gaming activity and transaction history.
• Processing bonus claims, promotions, and loyalty rewards.

3.2 Customer Support and Communication

• Responding to your inquiries, requests, and support tickets.
• Providing customer service in Indonesian through live chat, email, and WhatsApp.
• Sending important account notifications, security alerts, and service updates.
• Communicating changes to our terms, policies, or service features.

3.3 Security and Fraud Prevention

• Detecting, preventing, and investigating fraudulent transactions, unauthorized access, and suspicious activities.
• Monitoring for multiple accounts, collusion, bonus abuse, and other prohibited activities.
• Protecting against money laundering, terrorist financing, and other financial crimes.
• Ensuring compliance with Indonesian gaming regulations and international AML/KYC standards.
• Conducting security audits and risk assessments.

3.4 Service Improvement and Analytics

• Analyzing user behavior, preferences, and gameplay patterns to improve our services.
• Conducting market research and statistical analysis to understand Indonesian player preferences.
• Testing new features, games, and platform enhancements.
• Optimizing website performance, mobile responsiveness, and user experience.
• Generating aggregated, anonymized reports for business intelligence purposes.

3.5 Marketing and Promotional Communications

• Sending promotional offers, bonus opportunities, and special event notifications (only with your consent).
• Personalizing marketing messages based on your gaming preferences and activity.
• Conducting promotional campaigns related to BRI Liga 1, Champions League, EPL, and other major sporting events.

Note: You can opt out of marketing communications at any time through your account settings or by contacting customer support. Opting out of marketing does not affect essential service communications.

3.6 Legal and Regulatory Compliance

• Complying with Indonesian laws, regulations, and legal obligations.
• Responding to lawful requests from government authorities, law enforcement, or courts.
• Enforcing our Terms & Conditions and protecting our legal rights.
• Resolving disputes, investigating complaints, and handling legal proceedings.

4. How We Share Your Information

boba99 does not sell, rent, or trade your personal information to third parties for their marketing purposes. We only share your data in the following limited circumstances:

4.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who assist in operating our platform:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP) and e-wallet providers (OVO, DANA, GoPay) to process deposits and withdrawals.
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, and other gaming partners to deliver casino games and betting markets.
• KYC Verification Services: Identity verification specialists who confirm the authenticity of submitted documents.
• Cloud Infrastructure Providers: Hosting and data storage services that maintain our servers and databases.
• Customer Support Tools: Live chat platforms, helpdesk systems, and communication tools used by our support team.
• Fraud Prevention Services: Security and fraud detection specialists who help protect against unauthorized activities.

All third-party service providers are contractually bound to handle your data securely and only for the specific purposes we authorize. They cannot use your personal information for their own purposes.

4.2 Legal Requirements and Law Enforcement

We may disclose your information to government authorities, regulators, or law enforcement when:

• Required by Indonesian law, regulation, or legal process (court orders, subpoenas).
• Necessary to protect our legal rights, property, or safety, or those of our users or the public.
• Requested by law enforcement in connection with criminal investigations.
• Required for compliance with anti-money laundering (AML) or counter-terrorism financing (CTF) obligations.

4.3 Business Transfers

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 of any such change in ownership or control of your personal information.

5. Data Security and Protection

boba99 implements comprehensive technical, physical, and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Technical Security Measures

• 256-bit SSL Encryption: All data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS protocols, the same encryption used by major Indonesian banks.
• Secure Data Storage: Personal information is stored on encrypted servers in secure data centers with restricted physical access.
• Firewall Protection: Multi-layered firewall systems protect our infrastructure from external threats and unauthorized access attempts.
• Regular Security Audits: Third-party security experts conduct periodic penetration testing and vulnerability assessments.
• Intrusion Detection: Automated monitoring systems detect and respond to suspicious activities in real-time.

5.2 Access Controls and Authentication

• Strong password requirements with minimum complexity standards.
• Role-based access controls ensuring staff can only access data necessary for their job functions.
• Regular review and revocation of access privileges for former employees and contractors.
• Two-factor authentication options available for enhanced account security.

5.3 Staff Training and Policies

• All boba99 employees and contractors undergo data protection and security training.
• Strict confidentiality agreements bind all staff members.
• Clear internal policies govern data handling, access, and incident response procedures.

Important: While we implement robust security measures, no system is completely immune to security breaches. You play a crucial role in protecting your account by keeping your login credentials confidential, using strong passwords, and never sharing your account with others. If you suspect unauthorized access to your account, contact our support team immediately.

6. Data Retention

boba99 retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Data Type	Retention Period	Reason for Retention
Account Information	Duration of account + 5 years	Regulatory compliance, dispute resolution
Transaction Records	7 years from transaction date	Financial regulations, tax requirements
KYC Documents	5 years after account closure	AML/KYC compliance obligations
Gameplay History	3 years from last activity	Dispute resolution, fraud investigation
Support Communications	2 years from last communication	Customer service quality, dispute resolution
Marketing Consent	Until consent withdrawn	Marketing communications

After the applicable retention period expires, we securely delete or anonymize your personal information. Anonymized data (data that can no longer identify you) may be retained indefinitely for statistical and analytical purposes.

7. Your Privacy Rights

As a boba99 user, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request a copy of the personal information we hold about you. You can access most of your account information directly through your boba99 account dashboard. For additional information, contact our customer support team.

7.2 Right to Rectification

If your personal information is inaccurate or incomplete, you have the right to request corrections. You can update most information directly in your account settings. For changes to verified information (name, date of birth), contact customer support with supporting documentation.

7.3 Right to Erasure

You may request deletion of your personal data under certain circumstances. However, we may need to retain certain information to comply with legal obligations, resolve disputes, or enforce our Terms & Conditions. Account closure requests can be submitted through customer support.

7.4 Right to Restrict Processing

You can request that we temporarily limit how we use your data in specific situations, such as during dispute resolution or when contesting data accuracy.

7.5 Right to Object

You have the right to object to processing of your personal data for marketing purposes. You can opt out of marketing communications through your account settings or by contacting customer support.

7.6 Right to Data Portability

You can request a copy of your personal data in a commonly used, machine-readable format for transfer to another service provider where technically feasible.

To exercise any of these rights, contact our Data Protection Officer via email at [email protected] (displayed as plain text for reference only) or through live chat customer support. We will respond to requests within 30 days.

8. Cookies and Tracking Technologies

boba99 uses cookies, web beacons, and similar technologies to enhance user experience, analyze site usage, and deliver personalized content. Cookies are small text files stored on your device when you visit our website.

8.1 Types of Cookies We Use

• Essential Cookies: Required for basic website functionality, account login, and security. These cannot be disabled without affecting site operation.
• Performance Cookies: Collect anonymous data about how visitors use our site, helping us improve performance and user experience.
• Functional Cookies: Remember your preferences (language settings, username) to provide a more personalized experience.
• Targeting Cookies: Track your browsing activity to deliver relevant advertisements and promotional offers based on your interests.

You can control cookie preferences through your browser settings. Note that disabling certain cookies may affect website functionality and your ability to access some features.

9. Third-Party Links and Services

Our website may contain links to third-party websites, including game providers, payment processors, and social media platforms. This Privacy Policy applies only to boba99 services. We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any external sites you visit.

10. Children's Privacy

boba99 services are strictly intended for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete such information and close the associated account.

Parents or guardians who believe their child has provided personal information to boba99 should contact us immediately so we can take appropriate action.

11. International Data Transfers

boba99 primarily serves the Indonesian market and stores data within secure facilities. However, some service providers and partners may be located outside Indonesia. When we transfer personal data internationally, we ensure appropriate safeguards are in place, such as standard contractual clauses and data protection agreements, to maintain the security and confidentiality of your information.

12. Changes to This Privacy Policy

boba99 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will:

• Update the "Last Updated" date at the top of this document.
• Notify you via email or through a prominent notice on our website.
• Request your consent where required by applicable law.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Continued use of boba99 services after changes take effect constitutes acceptance of the updated Privacy Policy.

13. Contact Information and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

Email: [email protected] (Note: Email address displayed as plain text for reference only)

Customer Support: Available 24/7 via live chat within your boba99 account dashboard

Data Protection Inquiries: For specific privacy rights requests or data protection concerns, please clearly mark your communication as "Privacy Request" for priority handling.

We are committed to resolving privacy-related concerns promptly and transparently. Our customer support team will escalate your inquiry to our Data Protection Officer, who will respond within 30 days.

14. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of Indonesia. Any disputes arising from this Privacy Policy or our data handling practices shall be subject to the exclusive jurisdiction of the competent courts of Indonesia.