Privacy Policy

1. Introduction

roma77 is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you use our online gaming platform accessible at roma77.cam, including our website, mobile applications, and related services (collectively, the "Platform").

By creating an account and using roma77 services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with any part of this policy, please do not use our Platform.

This Privacy Policy should be read in conjunction with our Terms and Conditions, which govern your use of roma77 services.

2. Data Controller

roma77 acts as the data controller for the personal information processed through our Platform. This means we determine the purposes and means of processing your personal data and are responsible for ensuring compliance with applicable data protection laws.

For questions or concerns about how your data is handled, you may contact our Data Protection Officer at the contact information provided in Section 14 of this policy.

3. Information We Collect

roma77 collects various types of information to provide, maintain, and improve our services. The categories of information we collect include:

3.1 Information You Provide Directly

When you register an account, you voluntarily provide the following personal information:

• Identity Information: Full legal name, date of birth, gender, nationality
• Contact Information: Email address, mobile phone number, residential address
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet information (OVO, DANA, GoPay account identifiers)
• Verification Documents: Government-issued identification such as KTP (Kartu Tanda Penduduk), passport, driver's license, proof of address (utility bills, bank statements)
• Transaction Information: Deposit and withdrawal history, payment methods used, transaction amounts and timestamps
• Communications: Messages, emails, and chat transcripts when you contact customer support

3.2 Information Collected Automatically

When you access and use the roma77 Platform, we automatically collect certain technical and usage information:

• Device Information: IP address, device type, operating system, browser type and version, device identifiers
• Usage Data: Pages visited, features accessed, time spent on pages, click patterns, navigation paths
• Gaming Activity: Bets placed, games played, wager amounts, winnings and losses, game session duration
• Location Information: General geographic location derived from IP address to ensure compliance with jurisdictional restrictions
• Cookies and Tracking Data: Information collected through cookies, web beacons, and similar technologies (see Section 10)

3.3 Information from Third Parties

In certain circumstances, we may receive information about you from third-party sources:

• Payment Providers: Transaction confirmation and verification data from banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay)
• Verification Services: Identity verification results from third-party KYC (Know Your Customer) service providers
• Fraud Prevention Services: Risk assessment data from fraud detection partners
• Marketing Partners: Information about how you discovered roma77 if you clicked on an affiliate or partner link

4. How We Use Your Information

roma77 uses the personal information we collect for the following purposes:

4.1 Account Management

• Create, maintain, and manage your player account
• Verify your identity and age to comply with legal requirements
• Authenticate your login credentials and secure your account
• Process account settings changes and preferences

4.2 Transaction Processing

• Process deposits and fund your account balance
• Execute withdrawal requests and transfer funds to your bank or e-wallet
• Maintain transaction records for accounting and regulatory compliance
• Detect and prevent fraudulent transactions

4.3 Service Delivery

• Provide access to casino games, live dealer tables, sports betting, and other gaming products
• Process bets, calculate winnings, and credit payouts
• Apply bonuses, promotions, and loyalty rewards
• Customize your gaming experience based on preferences and activity

4.4 Customer Support

• Respond to inquiries, complaints, and support requests
• Troubleshoot technical issues and resolve disputes
• Investigate account problems and verify reported issues
• Maintain records of support interactions for quality assurance

4.5 Communication

• Send transactional notifications (deposit confirmations, withdrawal status, account changes)
• Deliver promotional offers, bonus announcements, and marketing communications (with your consent)
• Provide important service updates and policy changes
• Send responsible gaming reminders and self-limit notifications

4.6 Compliance and Security

• Comply with legal obligations including anti-money laundering (AML) regulations, responsible gaming laws, and data protection requirements
• Prevent fraud, money laundering, collusion, and other prohibited activities
• Enforce our Terms and Conditions and detect violations
• Protect the security and integrity of the Platform
• Respond to legal requests, court orders, and regulatory inquiries

4.7 Analytics and Improvement

• Analyze usage patterns to improve Platform functionality and user experience
• Monitor game performance, identify technical issues, and optimize loading times
• Develop new features, games, and services based on player preferences
• Conduct market research and understand player demographics

5. Legal Basis for Processing

roma77 processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations to you, including providing gaming services, processing transactions, and managing your account.
• Legal Obligation: Processing is required to comply with applicable laws and regulations such as age verification, anti-money laundering requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security, service improvement, and direct marketing, provided these interests do not override your fundamental rights and freedoms.
• Consent: Where required by law, we obtain your explicit consent before processing certain types of data, such as marketing communications and cookies. You may withdraw consent at any time.

6. Data Sharing and Third Parties

roma77 does not sell your personal information to third parties. However, we may share your data with the following categories of recipients for the purposes described in this policy:

6.1 Service Providers

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

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) to process deposits and withdrawals
• Game Providers: Casino and live dealer game suppliers who deliver gaming content on the Platform
• Identity Verification Services: KYC providers that verify your identity documents and conduct age verification checks
• Fraud Prevention Partners: Services that assess transaction risk and detect fraudulent activity
• Cloud Hosting Providers: Infrastructure partners that host our Platform and store data securely
• Customer Support Tools: Live chat, email, and ticketing systems used by our support team
• Analytics Services: Tools that help us understand Platform usage and performance

All service providers are contractually bound to protect your data and use it only for the specific purposes we authorize.

6.2 Legal and Regulatory Authorities

We may disclose your information to government agencies, regulators, law enforcement, and courts when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, court orders, or regulatory requests
• Enforce our Terms and Conditions
• Protect the rights, property, or safety of roma77, our users, or the public
• Detect, prevent, or investigate fraud, security breaches, or illegal activities

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity as part of the business transition. We will notify you of any such change in ownership or control of your data.

6.4 Affiliates and Partners

With your consent, we may share limited information with marketing partners and affiliates for promotional purposes. You can opt out of such sharing at any time by adjusting your communication preferences in your account settings.

7. Data Security

roma77 takes data security seriously and implements a comprehensive set of technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction.

7.1 Technical Safeguards

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS protocols. Sensitive data stored in our databases is encrypted at rest.
• Firewalls and Intrusion Detection: Our network infrastructure is protected by firewalls, intrusion detection systems, and continuous security monitoring.
• Secure Authentication: We employ strong password requirements and offer two-factor authentication (2FA) to prevent unauthorized account access.
• Access Controls: Access to personal data is restricted to authorized personnel on a need-to-know basis and is logged for audit purposes.

7.2 Organizational Safeguards

• Employee Training: Our staff receive regular training on data protection principles and secure data handling practices.
• Confidentiality Agreements: All employees and contractors with access to personal data sign confidentiality agreements.
• Security Audits: We conduct regular security assessments, vulnerability scans, and penetration testing to identify and address potential risks.
• Incident Response: We maintain an incident response plan to quickly detect, investigate, and mitigate data breaches.

7.3 Your Responsibilities

While we implement robust security measures, you also play a critical role in protecting your account:

• Choose a strong, unique password and do not share it with anyone
• Enable two-factor authentication on your account
• Log out of your account when using shared or public devices
• Report any suspicious activity or unauthorized access immediately to customer support

8. Data Retention

roma77 retains your personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, regulatory, and business requirements.

8.1 Active Accounts

While your account is active, we retain all account information, transaction history, gaming activity, and communications necessary to provide services and support.

8.2 Closed Accounts

After you close your account, we retain certain information for legal and regulatory compliance purposes, including:

• Identity verification documents: 5 years from account closure (required for anti-money laundering compliance)
• Transaction records: 7 years from account closure (required for financial reporting and tax compliance)
• Responsible gaming records: 5 years from account closure (required for regulatory oversight)
• Customer support records: 3 years from account closure (for dispute resolution and quality assurance)

8.3 Inactive Accounts

If your account remains inactive (no login or gaming activity) for 12 consecutive months, we may contact you to confirm whether you wish to keep your account open. After 24 months of inactivity, we may close your account and retain data according to the closed account retention schedule.

8.4 Deletion of Data

Once the applicable retention period expires, we securely delete or anonymize your personal information so that it can no longer be associated with you.

9. Your Privacy Rights

As a roma77 user, you have the following privacy rights regarding your personal information:

9.1 Right of Access

You have the right to request a copy of the personal information we hold about you. You can access most of your data directly through your account dashboard or by contacting customer support.

9.2 Right to Rectification

You have the right to correct inaccurate or incomplete personal information. You can update your contact details, address, and communication preferences through your account settings.

9.3 Right to Erasure

You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes it was collected, or when you withdraw consent. Note that we may be required to retain certain information for legal compliance even after a deletion request.

9.4 Right to Restrict Processing

You have the right to request that we limit how we use your personal data in certain situations, such as when you contest the accuracy of the data or object to our processing.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.

9.6 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from marketing communications at any time by clicking the unsubscribe link in emails or adjusting your account preferences.

9.7 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.

9.8 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection Officer using the contact information in Section 14. We will respond to your request within 30 days. Verification of your identity may be required to process certain requests.

10. Cookies and Tracking Technologies

roma77 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content.

10.1 What Are Cookies

Cookies are small text files stored on your device that allow us to recognize your browser and remember certain information about your visit.

10.2 Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function properly. These cookies enable core features such as login authentication, session management, and security.
• Performance Cookies: Collect information about how you use the Platform, such as pages visited and errors encountered. This data helps us improve site performance.
• Functional Cookies: Remember your preferences and choices (language, currency, display settings) to provide a personalized experience.
• Marketing Cookies: Track your browsing activity to deliver targeted advertisements and measure the effectiveness of marketing campaigns.

10.3 Managing Cookies

You can control cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. However, disabling certain cookies may limit your ability to use some features of the Platform. Essential cookies cannot be disabled as they are required for the Platform to function.

11. International Data Transfers

roma77 operates an international platform and may transfer your personal data to servers and service providers located outside Indonesia. When we transfer data internationally, we ensure appropriate safeguards are in place to protect your information in accordance with data protection standards.

These safeguards may include:

• Contractual agreements with data processors requiring them to protect your data
• Ensuring the receiving country has adequate data protection laws
• Implementing technical security measures to protect data in transit and at rest

12. Protection of Minors

roma77 services are strictly intended for individuals who are at least 21 years of age. We do not knowingly collect or solicit personal information from anyone under 21. If we become aware that we have collected personal data from a minor without proper verification, we will take immediate steps to delete that information and close the account.

If you believe a minor has provided personal information to roma77, please contact us immediately at the contact information provided in Section 14.

13. Changes to This Policy

roma77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated to you via email, platform notification, or by posting a prominent notice on our website.

The "Last Updated" date at the top of this policy indicates when the most recent changes were made. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

Your continued use of roma77 services following any changes to this Privacy Policy constitutes your acceptance of those changes.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how roma77 handles your personal information, please contact us:

Data Protection Officer
Email: [email protected] (displayed as plain text)
Subject Line: Privacy Inquiry

You may also contact us through the following channels:

• Live Chat: Available 24/7 through the Platform
• WhatsApp: Available daily 08:00-23:00 WIB

We aim to respond to all privacy-related inquiries within 30 days.