Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by koi99 through our website, mobile applications, customer support channels, and any other digital platforms we operate. This policy should be read in conjunction with our Terms & Conditions, which govern your use of koi99 services.

koi99 operates as an online gaming platform serving users in Indonesia and other jurisdictions where online gaming is legally permitted. We collect and process personal information in accordance with applicable data protection laws and international best practices for privacy and security.

For the purposes of this Privacy Policy, "personal information" or "personal data" means any information relating to an identified or identifiable individual, including but not limited to names, identification numbers, contact details, financial information, location data, and online identifiers.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a koi99 account, use our services, or contact customer support, you may provide the following types of information:

• Account Registration Information: Full legal name, date of birth, email address, phone number, residential address, username, and password.
• Identity Verification Documents: Government-issued identification (Indonesian KTP, passport, or driver's license), proof of address documents (utility bills, bank statements), and selfie photographs for facial verification.
• Financial Information: Bank account details (account number, bank name, account holder name), e-wallet account information, payment card details (for processors we integrate with), transaction history, deposit and withdrawal records.
• Communication Records: Contents of emails, live chat transcripts, support tickets, feedback forms, and any other correspondence with koi99 staff.
• Responsible Gaming Information: Self-imposed deposit limits, self-exclusion preferences, session time limits, and reality check settings.

2.2 Information Collected Automatically

When you access koi99 services, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, advertising ID), and mobile network information.
• Log Data: IP address, access times and dates, pages viewed, clickstream data, referring and exit pages, search terms used, and time spent on pages.
• Location Data: Approximate geographic location based on IP address. We do not collect precise GPS location unless you explicitly grant permission.
• Gaming Activity: Games played, bet amounts and frequencies, win/loss records, bonus usage, gameplay patterns, session durations, and account balance history.
• Cookies and Similar Technologies: We use cookies, web beacons, pixel tags, and similar tracking technologies to remember your preferences, authenticate your sessions, analyze site usage, and deliver personalized content. For more details, see Section 9 (Cookies Policy).

2.3 Information from Third Parties

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

• Payment Processors: Transaction confirmation data, fraud screening results, and payment method validation from banks and e-wallet providers including BCA, BRI, BNI, Mandiri, OVO, DANA, and GoPay.
• Game Providers: Gameplay data, game outcomes, and technical performance metrics from third-party game studios whose content appears on koi99.
• Identity Verification Services: Verification results and risk assessment scores from third-party KYC and AML (anti-money laundering) service providers.
• Marketing Partners: Attribution data and campaign performance metrics from advertising networks, provided you reached koi99 through a marketing campaign.

3. How We Use Your Information

koi99 uses your personal information for the following purposes:

3.1 Service Delivery and Account Management

• Creating and maintaining your koi99 account.
• Processing deposits, withdrawals, and other financial transactions.
• Enabling you to place bets, play games, and access all platform features.
• Managing bonuses, promotions, and VIP rewards programs.
• Providing customer support and responding to your inquiries.
• Implementing responsible gaming tools including deposit limits, self-exclusion, and session timers.

3.2 Legal and Regulatory Compliance

• Verifying your identity and age to ensure compliance with twenty-one-plus age restrictions.
• Complying with Know Your Customer (KYC) and anti-money laundering (AML) regulations.
• Detecting and preventing fraud, abuse, money laundering, and other illegal activities.
• Investigating suspected violations of our Terms & Conditions.
• Responding to legal process, court orders, or government requests.
• Maintaining audit logs and transaction records as required by gaming regulations.

3.3 Platform Improvement and Personalization

• Analyzing user behavior to improve website navigation, game selection, and user interface design.
• Personalizing your experience by recommending games, promotions, and features based on your preferences and activity history.
• Conducting research and statistical analysis to understand user demographics and gaming trends.
• Testing new features, functionality, and game content.
• Optimizing platform performance, loading speeds, and mobile responsiveness.

3.4 Marketing and Communications

• Sending promotional emails about new games, bonuses, tournaments, and special offers (only with your consent).
• Delivering transactional emails including account confirmations, deposit receipts, withdrawal notifications, and security alerts.
• Notifying you of important changes to our Terms & Conditions, Privacy Policy, or platform functionality.
• Conducting customer satisfaction surveys and feedback requests.

You may opt out of marketing communications at any time by clicking the unsubscribe link in emails or adjusting your notification preferences in account settings. Transactional and service-related communications cannot be disabled as they are essential for account security and regulatory compliance.

4. Legal Basis for Processing (GDPR Compliance)

Where applicable, koi99 processes personal information under the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you (providing gaming services, processing transactions, managing your account).
• Legal Obligation: Processing is required to comply with laws and regulations (age verification, KYC/AML compliance, tax reporting).
• Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, platform security, service improvement), provided these interests do not override your fundamental rights and freedoms.
• Consent: Where we rely on consent (marketing communications, optional data collection), you may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

5. How We Share Your Information

koi99 does not sell or rent your personal information to third parties for their marketing purposes. We share personal information only in the following limited circumstances:

5.1 Service Providers and Business Partners

• Payment Processors: Banks, e-wallet providers, and payment gateways that facilitate deposits and withdrawals including BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and international payment processors.
• Game Providers: Third-party game studios whose content is integrated into the koi99 platform (e.g., Pragmatic Play, Evolution Gaming, Microgaming, NetEnt).
• Cloud Hosting Providers: Technology companies that provide server infrastructure, data storage, and content delivery network services.
• Identity Verification Services: Specialized firms that perform KYC checks, document authentication, and fraud screening.
• Customer Support Tools: Live chat platforms, ticketing systems, and CRM software providers that help us deliver customer service.
• Analytics Providers: Services that help us understand user behavior and platform performance through aggregated, anonymized data analysis.

All service providers are contractually bound to process personal information only as instructed by koi99 and to maintain appropriate security measures. Service providers may not use your information for their own purposes.

5.2 Legal and Regulatory Disclosure

We may disclose personal information when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with court orders, subpoenas, or other legal processes.
• Respond to requests from government authorities or regulatory bodies.
• Enforce our Terms & Conditions and investigate potential violations.
• Protect the rights, property, or safety of koi99, our users, or the public.
• Detect, prevent, or investigate fraud, security breaches, or illegal activities.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. We will notify you via email or prominent notice on the platform before your information is transferred and becomes subject to a different privacy policy.

6. Data Security Measures

koi99 implements robust technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

• Encryption: All data transmitted between your device and koi99 servers is protected by 256-bit SSL/TLS encryption. Sensitive data stored in our databases is encrypted at rest.
• Access Controls: Personal information is accessible only to authorized employees and service providers who need it to perform their duties. Access is granted on a need-to-know basis and protected by multi-factor authentication.
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, and regular vulnerability scanning.
• Security Audits: We conduct regular security assessments and penetration testing performed by independent third-party security firms.
• Employee Training: All koi99 staff receive training on data protection principles, security best practices, and handling of personal information.
• Incident Response: We maintain a documented incident response plan to detect, contain, and remediate security breaches promptly.

Despite our security measures, no system is entirely immune to attack. In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and relevant authorities as required by law.

7. Data Retention

koi99 retains 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. Retention periods vary based on data type:

Data Category	Retention Period
Account Registration Data	Duration of account plus 7 years after closure
Transaction Records	7 years from transaction date (regulatory requirement)
Identity Verification Documents	7 years from account closure (AML compliance)
Communication Records	3 years from last communication
Marketing Consent Records	Duration of consent plus 3 years
Log Data and Analytics	Anonymized after 12 months, deleted after 2 years

After retention periods expire, personal information is securely deleted or anonymized so that it can no longer identify you. Anonymized data may be retained indefinitely for statistical analysis and research purposes.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right of Access: You may request a copy of the personal information we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal information.
• Right to Erasure: You may request deletion of your personal information, subject to legal retention obligations.
• Right to Restriction: You may request that we limit processing of your personal information in certain circumstances.
• Right to Data Portability: You may request a copy of your personal information in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with "Privacy Rights Request" in the subject line. We will respond to your request within thirty days. Please note that identity verification may be required before we can process certain requests.

If you are not satisfied with how we handle your personal information, you have the right to lodge a complaint with your local data protection authority.

9. Cookies Policy

koi99 uses cookies and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize you on return visits.

9.1 Types of Cookies We Use

• Essential Cookies: Required for platform functionality including authentication, security, session management, and load balancing. These cookies cannot be disabled.
• Performance Cookies: Collect anonymized data about how users interact with koi99, including page views, navigation patterns, and error messages. Used to improve platform performance.
• Functionality Cookies: Remember your preferences such as language selection, time zone, and customized settings.
• Marketing Cookies: Track your activity across websites to deliver targeted advertising and measure campaign effectiveness. These cookies require your consent.

9.2 Managing Cookie Preferences

You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. However, blocking essential cookies will prevent you from using koi99 services. To manage marketing cookies, adjust your preferences in the cookie consent banner or account settings.

10. International Data Transfers

koi99 operates primarily within Indonesia. However, some of our service providers and technology infrastructure are located outside Indonesia. When we transfer personal information internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by data protection authorities.
• Adequacy decisions recognizing equivalent data protection standards in the destination country.
• Binding corporate rules for transfers within multinational organizations.

Where personal information is transferred to countries without adequate data protection laws, we take additional measures to ensure your information remains protected to the same standard as within Indonesia.

11. Children's Privacy

koi99 services are strictly for individuals aged twenty-one years and older. We do not knowingly collect personal information from anyone under the age of twenty-one. If we become aware that we have collected personal information from a minor, we will take immediate steps to delete that information and close the associated account. Parents or guardians who believe their child has provided personal information to koi99 should contact us immediately at [email protected].

12. Changes to This Privacy Policy

koi99 may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. Material changes will be communicated via email or prominent notice on the platform at least thirty days before taking effect. The "Last Updated" date at the top of this policy indicates when it was most recently revised. Your continued use of koi99 services after changes become effective constitutes acceptance of the revised Privacy Policy.

13. Contact Information

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

Data Protection Officer
Email: [email protected]
Subject Line: Privacy Policy Inquiry

For general customer support inquiries, use our 24/7 live chat available on the koi99 platform. Our support team is fluent in both English and Bahasa Indonesia.