sip33 Privacy Policy

sip33 ("we", "us", "our") operates the online gaming platform accessible at https://sip33.lat. This Privacy Policy describes how sip33 collects, uses, stores, protects, and in certain limited circumstances shares the personal data of individuals who visit or register on our platform (each a "Member" or "you").

Privacy at sip33 is not an afterthought. We design our data practices from the ground up to be proportionate, transparent, and consistent with the trust our members place in us. This policy applies to all personal data processed in connection with your use of sip33, regardless of whether you access the platform from Jakarta, Surabaya, Bali, Medan, or anywhere else in Indonesia.

By registering an account or continuing to use the sip33 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein. If you do not agree with any part of this policy, you must discontinue use of the platform and may request account closure at any time.

This Privacy Policy should be read alongside sip33's Terms & Conditions and Responsible Gaming policy, both of which form part of the overall agreement between you and sip33.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, either directly (e.g., full name, national ID number) or indirectly (e.g., device fingerprint combined with location data).
• "Processing" means any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, erasure, and destruction.
• "Data Controller" means sip33, the entity that determines the purposes and means of processing personal data collected through the sip33 platform.
• "Data Processor" means any third party that processes personal data on behalf of sip33 under a written data processing agreement (e.g., payment providers, KYC verification services).
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data for a stated purpose.
• "KYC Data" means identity and address verification documents submitted by a Member as part of the Know Your Customer process, including copies of government-issued IDs and proof of address.
• "Cookies" means small text files placed on your device by the sip33 platform to support platform functionality, analytics, and personalisation.

sip33 collects the following categories of personal data from Members and platform visitors:

sip33 collects personal data through the following channels:

• Directly from you: When you complete the account registration form, submit KYC documents, initiate a deposit or withdrawal, contact the support team, or update your account preferences.
• Automatically: When you visit or interact with the sip33 platform, our servers and analytics tools automatically record Technical Data including your IP address, device identifiers, and session activity. This data is collected via server logs and first-party cookies.
• From payment providers: When you deposit or withdraw funds using BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, or ShopeePay, the relevant payment provider shares transaction confirmation data with sip33 to allow us to credit or debit your account balance accurately.
• From KYC verification partners: Where sip33 uses a third-party identity verification service to cross-check submitted KYC documents, that service may return a verification result (pass/fail) along with extracted data fields to sip33's systems.
• From fraud prevention services: sip33 may receive risk signals from third-party fraud detection providers that help identify irregular account behaviour, which we may combine with data already held about a Member.

sip33 processes your personal data for the following specific purposes:

1. Account creation and management: To register your account, verify your identity, maintain your account settings, and enable you to access the sip33 platform.
2. Transaction processing: To process deposits and withdrawals in IDR via your chosen local bank or e-wallet, record transaction history, and resolve any payment disputes.
3. Legal and regulatory compliance: To fulfil our KYC, anti-money-laundering (AML), and record-keeping obligations under our international gaming licence, and to cooperate with lawful requests from regulatory authorities.
4. Platform security and fraud prevention: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, money laundering, and any other prohibited conduct described in our Terms & Conditions.
5. Responsible gaming: To monitor gaming patterns and intervene where there are signs of problem gambling behaviour, including enforcement of self-exclusion orders and deposit limits requested by Members.
6. Customer support: To respond to your enquiries, resolve disputes, and maintain records of communications for quality and training purposes.
7. Platform improvement: To analyse aggregated, anonymised usage data to understand how Members interact with the platform, identify technical issues, and improve user experience.
8. Marketing communications: Where you have given explicit consent, to send you promotional offers, tournament announcements, bonus alerts, and seasonal campaigns by email, SMS, or WhatsApp. You may withdraw this consent at any time.

sip33 does not process your personal data for any purpose not listed above without providing prior notice and, where required by applicable law, obtaining your consent.

sip33 relies on the following legal bases when processing your personal data:

• Contractual necessity: Processing required to perform our contract with you — including operating your account, processing transactions, and providing access to games — is based on the contract formed when you accept these terms.
• Legal obligation: Processing required to comply with applicable laws, including KYC verification, AML record-keeping, and responses to lawful regulatory requests, is carried out on the basis of legal obligation.
• Legitimate interests: Processing for fraud prevention, platform security, and aggregated analytics is based on sip33's legitimate interest in operating a secure and compliant gaming platform, provided that interest is not overridden by your fundamental rights.
• Consent: Processing for marketing communications and certain non-essential cookies is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

sip33 does not sell, rent, or trade your personal data. We share data only in the following limited and controlled circumstances:

• Payment processors: We share necessary transaction data with BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, and other payment infrastructure providers to process your deposits and withdrawals. Each provider is subject to its own data protection obligations.
• KYC and identity verification services: We share document images and personal details with licensed third-party KYC providers solely for the purpose of verifying your identity and age. These providers act as data processors under contractual terms that restrict their use of your data.
• Fraud prevention and risk services: We may share technical and behavioural data with specialist fraud prevention services to protect the platform and its members from financial crime and account abuse.
• Game software providers: Providers such as Pragmatic Play, Evolution Gaming, PG Soft, and Spribe may receive anonymised session identifiers to facilitate game delivery and resolve round disputes. These providers do not receive your name, contact details, or financial data.
• Regulatory and law enforcement authorities: Where required by applicable law or by our licensing authority, sip33 will disclose personal data to the relevant authority. We will notify you of such disclosure where we are legally permitted to do so.
• Professional advisers: Lawyers, auditors, and compliance consultants who advise sip33 may have access to personal data on a strictly need-to-know basis, subject to binding confidentiality obligations.

sip33 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods driven by regulatory obligations:

• Account and KYC data: Retained for a minimum of 5 years following account closure, as required by anti-money-laundering regulations applicable to our gaming licence.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction for audit and compliance purposes.
• Gaming activity logs: Retained for a minimum of 3 years to support dispute resolution and regulatory reporting.
• Support communications: Retained for a minimum of 2 years from the date of the last communication in a support thread.
• Marketing preferences: Retained for the lifetime of your account and for 12 months following account closure, to ensure we honour any opt-out instructions received prior to closure.

Upon expiry of the applicable retention period, sip33 will securely delete or anonymise your personal data. Anonymised, aggregated data that cannot be used to identify any individual may be retained indefinitely for statistical and analytical purposes.

sip33 employs a layered security architecture to protect personal data against unauthorised access, disclosure, alteration, and destruction. Our technical and organisational measures include:

• TLS 256-bit encryption for all data transmitted between your browser or app and the sip33 servers.
• Hashing and salting of all account passwords — sip33 staff cannot view or recover your password in plaintext.
• Access controls limiting personal data access to sip33 personnel and authorised processors who have a documented need to process that data.
• Regular penetration testing and independent security audits of sip33 infrastructure.
• Multi-factor authentication options available to all Members, strongly recommended for account access.
• Incident response procedures, including prompt notification of affected Members and regulators in the event of a data breach that poses a risk to individual rights.

While sip33 takes all reasonable measures to protect your data, no system connected to the internet can guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying sip33 promptly if you suspect any unauthorised access to your account.

sip33 uses first-party cookies and similar tracking technologies to support platform functionality and improve your experience. We do not use third-party advertising cookies or cross-site tracking technologies.

The categories of cookies we use are as follows:

• Strictly necessary cookies: These are required for the platform to function and cannot be disabled. They include session authentication cookies that keep you logged in securely and cookies that remember your language and display preferences.
• Analytics cookies: These help us understand how Members navigate the platform — for example, which game categories are most popular and where Members encounter friction. Analytics data is aggregated and anonymised. These cookies are set only with your consent.
• Functional cookies: These remember your preferences (such as previously selected payment method or preferred game lobby layout) to personalise your experience. Set only with your consent.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling strictly necessary cookies will impair the functionality of the sip33 platform, including the ability to stay logged in to your account.

As a Member of sip33, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us at the details provided in Section 15.

• Right of access: You may request a copy of the personal data sip33 holds about you, along with information about how it is processed.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct or supplement it.
• Right to erasure: Subject to our retention obligations (see Section 8), you may request that sip33 delete your personal data. Where a legal obligation requires us to retain certain data, we will inform you of this and delete what we are able to.
• Right to restrict processing: You may request that sip33 limit the way we use your data in certain circumstances — for example, while a rectification request is being assessed.
• Right to data portability: Where processing is based on your consent or on contractual necessity and carried out by automated means, you may request that we provide your personal data in a structured, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without penalty. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Right to object: You may object to processing based on legitimate interests at any time. sip33 will assess whether our legitimate interests override your rights and respond accordingly.

sip33 will respond to all rights requests within 30 calendar days of receipt. Where a request is complex or we receive a high volume of requests, we may extend this period by a further 30 days, with notice to you.

The sip33 platform is strictly for adults aged 21 and over. sip33 does not knowingly collect personal data from individuals under the age of 21. If we discover or are notified that a Minor has registered an account or provided personal data to sip33, we will immediately suspend the account, delete all associated personal data to the extent not required for regulatory purposes, and return any deposited funds to the verified payment source.

If you are a parent or guardian and have reason to believe that a person under 21 has provided personal data to sip33, please contact our support team immediately at [email protected] so that we can investigate and take appropriate action.

sip33 operates as an internationally licensed platform. Some of the Data Processors we engage — including certain KYC verification providers and platform infrastructure partners — may be located outside Indonesia. Where personal data is transferred to a country that does not provide a level of data protection equivalent to that offered within Indonesia, sip33 implements appropriate safeguards, which may include:

• Standard contractual clauses requiring the recipient to protect the data to an equivalent standard.
• Verification that the recipient operates under a recognised international privacy framework or is subject to equivalent regulatory oversight.
• Data minimisation — ensuring that only the minimum data necessary for the specific processing task is transferred internationally.

By using the sip33 platform, you acknowledge that your data may be processed in jurisdictions outside Indonesia as described above, subject to the safeguards outlined herein.

sip33 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, platform features, or applicable legal requirements. When material changes are made, we will update the "Last Updated" date at the top of this page and, where the changes are significant, notify active Members via their registered email address or through a platform notification.

Your continued use of the sip33 platform after any revision to this Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you must discontinue use of the platform and may request account closure by contacting our support team.

We encourage you to review this Privacy Policy periodically. The current version is always accessible at https://sip33.lat/privacy-policy.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a concern about how sip33 handles your personal data, please contact us through any of the following channels:

• Email: [email protected] (plain text — not a clickable link)
• WhatsApp: +62 811 9999 3300 (plain text — not a clickable link)
• Live Chat: Available 24/7 through the sip33 platform — log in to your account to open the support widget.

Our support team, which includes native Indonesian-speaking agents, is available around the clock, every day of the year including Indonesian public holidays such as Idul Fitri, Idul Adha, and Independence Day. We aim to acknowledge all privacy-related enquiries within 24 hours and provide a substantive response within the statutory 30-day window.

For matters related to responsible gaming — including self-exclusion, deposit limits, or cooling-off requests — please visit our dedicated Responsible Gaming page.