Privacy Policy

1. Introduction

Effective Date: January 1, 2026

This Privacy Policy ("Policy") describes how paso77 ("we", "us", "our", or "paso77") collects, uses, stores, protects, and discloses personal information from users ("you", "your", or "User") of our website, mobile applications, and related services (collectively, the "Platform").

At paso77, we are committed to protecting your privacy and handling your personal information with the highest standards of security and confidentiality. We understand that trust is fundamental to our relationship with users, and this Policy explains our data practices in clear, transparent language.

By accessing or using paso77, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with this Policy, you must immediately discontinue use of the Platform.

2. Information We Collect

paso77 collects several categories of personal information to operate the Platform, process transactions, verify identity, prevent fraud, and comply with legal obligations.

2.1 Information You Provide Directly

When you register an account or use our services, you voluntarily provide the following information:

• Account Registration Data: Full legal name, date of birth, gender, residential address, email address, mobile phone number, username, and password.
• Identity Verification (KYC) Documents: Government-issued identification (Indonesian National Identity Card / KTP), proof of address (utility bills, bank statements), selfie verification photos, and bank account information.
• Financial Information: Bank account details, e-wallet account information, deposit and withdrawal transaction history, betting activity, and Account balances.
• Communications: Customer support inquiries, chat transcripts, emails, and any other correspondence you send to paso77.
• Preferences: Language preferences, notification settings, game preferences, and marketing communication opt-ins/opt-outs.

2.2 Information Collected Automatically

When you access paso77, we automatically collect certain technical information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information.
• Usage Data: IP address, geographic location (country, city based on IP), login/logout timestamps, pages viewed, games played, bets placed, time spent on Platform, navigation paths, and referring URLs.
• Cookies & Similar Technologies: Session cookies, persistent cookies, web beacons, pixel tags, and local storage objects. See Section 8 for detailed cookie information.
• Transaction Logs: Complete records of all deposits, withdrawals, bets, wins, losses, bonuses claimed, and account balance changes.

2.3 Information from Third Parties

We may receive information about you from:

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) confirm transaction details and account ownership.
• Identity Verification Services: Third-party KYC and anti-fraud services verify the authenticity of submitted documents.
• Game Providers: Slot, casino, and sports betting providers share game outcome data and RTP statistics.
• Affiliates & Marketing Partners: If you were referred to paso77 by an affiliate, we may receive referral information.

3. How We Use Your Information

paso77 uses your personal information for the following legitimate business purposes:

3.1 Account Management & Service Delivery

• Create, maintain, and manage your user Account
• Process deposits, withdrawals, and internal fund transfers
• Enable you to place bets on sports events, casino games, togel, sabung ayam, and other gaming products
• Calculate and credit winnings, bonuses, and promotional offers
• Provide customer support and respond to inquiries
• Send transactional notifications (deposit confirmations, withdrawal updates, bet settlements)

3.2 Legal Compliance & Fraud Prevention

• Verify your identity and age (21+ requirement) through KYC processes
• Comply with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations
• Detect and prevent fraudulent activity, collusion, bonus abuse, and multiple accounts
• Respond to legal requests from government authorities and law enforcement
• Enforce our Terms and Conditions and Responsible Gaming policies
• Maintain audit trails and transaction records as required by law

3.3 Platform Improvement & Analytics

• Analyze Platform usage patterns to improve user experience
• Test new features, games, and services
• Optimize Platform performance, speed, and security
• Conduct market research and understand player preferences
• Generate aggregated, anonymized statistics (no individual identification)

3.4 Marketing & Communications (With Your Consent)

• Send promotional offers, bonuses, and special event notifications
• Provide personalized game recommendations based on play history
• Deliver targeted advertising on the Platform (never sold to external advertisers)
• Send newsletters and updates about paso77 services

Opt-Out: You may opt out of marketing communications at any time by adjusting your Account settings, clicking "unsubscribe" in emails, or contacting customer support. Transactional emails (deposit confirmations, withdrawal updates) cannot be disabled.

4. Data Sharing and Disclosure

paso77 does not sell your personal information to third parties. We share your data only in the following limited circumstances:

4.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf:

• Payment Processors: Banks and e-wallet providers process deposits and withdrawals. They receive only transaction details necessary to complete payments.
• KYC & Verification Services: Identity verification companies confirm document authenticity and check sanctions lists.
• Cloud Hosting Providers: Secure servers store Platform data with encryption and access controls.
• Customer Support Tools: Live chat and ticketing systems help us respond to your inquiries.
• Analytics Providers: Tools like Google Analytics (anonymized) help us understand Platform usage.

All service providers are contractually bound to protect your data, use it only for specified purposes, and comply with data protection laws.

4.2 Legal Obligations

We may disclose your information to government authorities, regulators, or law enforcement if required by law or if we believe in good faith that disclosure is necessary to:

• Comply with legal processes (court orders, subpoenas, warrants)
• Respond to claims that content violates third-party rights
• Protect paso77's legal rights and property
• Prevent fraud, money laundering, or other illegal activity
• Protect the safety and security of users and the public

4.3 Business Transfers

If paso77 undergoes a merger, acquisition, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity as part of the business transaction. You will be notified via email and Platform notice of any ownership change.

4.4 With Your Consent

We may share your information with third parties if you provide explicit consent for a specific purpose (e.g., participating in a partner promotion).

5. Data Security Measures

paso77 employs industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Encryption

• 256-bit SSL/TLS Encryption: All data transmitted between your device and paso77 servers is encrypted using bank-grade SSL certificates.
• Encrypted Storage: Sensitive data (passwords, financial information, KYC documents) is encrypted at rest in our databases.
• Password Hashing: User passwords are hashed using bcrypt algorithms and never stored in plain text.

5.2 Access Controls

• Role-based access control (RBAC) limits employee access to personal data based on job function
• Two-factor authentication (2FA) for employee accounts accessing sensitive systems
• Regular access audits and logging of all data access events
• Immediate revocation of access for terminated employees

5.3 Infrastructure Security

• Firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS)
• Regular security audits and penetration testing by independent firms
• Automated malware scanning and vulnerability patching
• Distributed Denial of Service (DDoS) protection
• Secure, redundant data backup systems with disaster recovery plans

5.4 User Responsibility

While paso77 implements robust security, you also play a role in protecting your Account:

• Use a strong, unique password (minimum 8 characters, mix of letters/numbers/symbols)
• Enable two-factor authentication (2FA) if offered
• Never share your login credentials with anyone
• Log out of your Account when using shared or public devices
• Immediately report suspicious Account activity to customer support

No Absolute Security: Despite our best efforts, no method of electronic transmission or storage is 100% secure. paso77 cannot guarantee absolute security but commits to promptly notifying affected users in the event of a data breach.

6. Data Retention

paso77 retains your personal information only as long as necessary to fulfill the purposes outlined in this Policy and comply with legal obligations.

6.1 Active Account Data

While your Account is active, we retain all personal information, transaction history, and betting records to provide services and comply with regulations.

6.2 Closed Account Data

When you close your Account, paso77 retains:

• Financial Records: Deposit, withdrawal, and betting transaction records for 7 years to comply with Indonesian financial record-keeping laws and tax regulations.
• KYC Documents: Identity verification documents for 5 years after account closure to comply with AML/CTF regulations.
• Account Information: Basic account details (name, email, registration date) for 3 years to prevent duplicate accounts and fraud.

6.3 Legal Hold

If your Account is involved in an investigation, legal dispute, or fraud case, data retention periods may be extended until the matter is resolved.

6.4 Deletion Requests

You may request deletion of your personal information (see Section 7). However, we may be legally required to retain certain data beyond your request. We will inform you if we cannot delete specific information due to legal obligations.

7. Your Privacy Rights

Under Indonesian data protection regulations and international privacy standards, 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 paso77 holds about you. Log in to your Account dashboard to view your profile, transaction history, and betting records. For a comprehensive data export, contact customer support.

7.2 Right to Correction

If your personal information is inaccurate or incomplete, you can update it directly in your Account settings or contact customer support. Changes to sensitive information (name, date of birth) may require document verification.

7.3 Right to Deletion

You may request deletion of your personal information by contacting customer support. Note that we may be legally required to retain certain data (financial records, KYC documents) for regulatory compliance. We will inform you of any retention requirements.

7.4 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format (e.g., CSV, JSON). Contact customer support to request a data export.

7.5 Right to Object

You may object to certain types of data processing:

• Marketing Communications: Opt out of promotional emails and notifications in Account settings.
• Analytics & Cookies: Adjust browser settings or use our cookie preference tool (see Section 8).
• Automated Decision-Making: Request human review if you believe an automated system (e.g., fraud detection) made an incorrect decision about your Account.

7.6 Right to Withdraw Consent

If we process your data based on your consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

7.7 Right to Lodge a Complaint

If you believe paso77 has violated your privacy rights, you may file a complaint with the Indonesian data protection authority or contact customer support to resolve the issue directly.

7.8 Exercising Your Rights

To exercise any of these rights, contact us at [email protected] or via Live Chat. We will respond within 30 days. We may request identity verification before processing your request to prevent unauthorized access.

8. Cookies and Tracking Technologies

paso77 uses cookies, web beacons, and similar technologies to enhance your experience, analyze Platform usage, and provide personalized content.

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit websites. They help websites remember your preferences, keep you logged in, and understand how you use the site.

8.2 Types of Cookies We Use

• Essential Cookies: Required for Platform functionality (login sessions, security, transaction processing). These cannot be disabled without affecting core services.
• Performance Cookies: Collect anonymous usage data (pages viewed, time spent, error messages) to improve Platform performance.
• Functional Cookies: Remember your preferences (language, currency, game favorites) for a personalized experience.
• Advertising Cookies: Deliver targeted promotional content on the Platform based on your betting activity. We do not share this data with external advertisers.

8.3 Third-Party Cookies

Some cookies are set by third-party service providers (payment processors, analytics tools). These providers have their own privacy policies governing cookie use.

8.4 Managing Cookies

You can control cookies through your browser settings:

• Block All Cookies: Most browsers allow you to refuse all cookies. Note that this may impair Platform functionality.
• Delete Cookies: Clear existing cookies from your browser. This will log you out and reset preferences.
• Cookie Preferences: Use paso77's cookie preference tool in Account settings to selectively enable/disable non-essential cookies.

9. Children's Privacy

paso77 strictly prohibits use by individuals under 21 years of age. We do not knowingly collect personal information from minors.

If we discover that a user is under 21, we will immediately:

• Suspend the Account
• Delete all personal information from our systems
• Refund deposited funds to the original payment source
• Void all bets and winnings

If you believe a minor has registered an Account, please contact us immediately at [email protected]. Parents and guardians are responsible for monitoring children's internet use and preventing underage access to gambling platforms.

10. Changes to This Privacy Policy

paso77 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform features. Material changes will be communicated through:

• Email notification to your registered email address
• Prominent notice on the Platform homepage
• In-app notification upon next login

The "Effective Date" at the top of this Policy indicates the last revision. Your continued use of paso77 after changes become effective constitutes acceptance of the updated Policy. We encourage you to review this Policy periodically.

If we make significant changes that materially reduce your privacy rights, we will seek your explicit consent before applying the new Policy to your existing data.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how paso77 handles your personal information, please contact us:

• Email: [email protected]
• Live Chat: Available 24/7 via the Platform
• WhatsApp: Contact customer support for the current WhatsApp number

We aim to respond to all privacy inquiries within 30 days. For urgent matters, please use Live Chat for the fastest response.