Privacy Policy

1. Introduction

This Privacy Policy applies to all personal information collected by lumi77 ("we," "us," or "our") through our website at https://lumi77.cam, mobile applications, and related services (collectively, the "Platform"). We are committed to transparency in our data handling practices and compliance with applicable data protection laws.

This policy explains what personal information we collect, why we collect it, how we use it, who we share it with, and the choices and rights available to you regarding your personal information. We encourage you to read this policy carefully to understand our practices. If you have questions or concerns about this policy or our data handling practices, please contact us at [email protected].

2. Information We Collect

We collect several types of information from and about users of our Platform to provide, maintain, and improve our services:

2.1 Information You Provide Directly

• Account Registration Information: When you create an account, we collect your full legal name, date of birth, email address, phone number, residential address, and chosen username and password.
• Identity Verification (KYC) Information: To comply with legal and regulatory requirements, we collect government-issued identification documents (Indonesian National ID/KTP, passport, or driver's license), proof of address documents (utility bills or bank statements), and selfie photos for identity confirmation.
• Payment Information: We collect bank account details (account number, bank name, account holder name) for deposits and withdrawals, e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history records.
• Communication Information: When you contact customer support via email, live chat, or phone, we collect the contents of your communications, support tickets, and any documents or screenshots you provide.
• Survey and Feedback Information: If you participate in surveys, promotions, or provide feedback, we collect your responses and opinions.

2.2 Information Collected Automatically

• Gaming Activity Data: We automatically record your gameplay history including games played, bets placed, wins and losses, bonus usage, and session duration.
• Technical Information: We collect IP address, device type and model, operating system and version, browser type and version, screen resolution, and device identifiers.
• Log Data: Our servers automatically log information including access times, pages viewed, time spent on pages, referring websites, and error reports or crash data.
• Location Data: We collect general location information derived from your IP address to ensure compliance with geographic restrictions and to detect fraudulent activity.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing behavior and preferences. See Section 9 for more details.

2.3 Information from Third Parties

• Payment Processors: We receive transaction confirmation and processing information from third-party payment providers like BCA, BRI, BNI, Mandiri, and e-wallet operators.
• Identity Verification Services: We may use third-party identity verification services to confirm your identity and detect fraudulent documents.
• Game Providers: We receive gameplay data from our game provider partners including Pragmatic Play, Evolution Gaming, Microgaming, and NetEnt.
• Fraud Prevention Services: We use third-party fraud detection and prevention services that provide risk scores and alerts based on your activity patterns.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Service Provision and Account Management

• Creating and maintaining your lumi77 account
• Verifying your identity and age to comply with legal requirements
• Processing deposits, withdrawals, and other financial transactions
• Providing access to casino games and sports betting markets
• Recording and tracking your gameplay history and account balance
• Managing bonuses, promotions, and loyalty rewards
• Responding to your customer support inquiries and resolving issues

3.2 Legal Compliance and Security

• Complying with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Preventing fraud, unauthorized access, and illegal activities
• Detecting and investigating suspicious account activity or policy violations
• Enforcing our Terms & Conditions and other policies
• Responding to legal requests, court orders, or regulatory inquiries
• Maintaining records as required by applicable laws and regulations

3.3 Service Improvement and Personalization

• Analyzing usage patterns to improve our Platform and user experience
• Personalizing game recommendations based on your preferences and history
• Conducting research and analytics to understand user behavior
• Testing new features and functionality
• Optimizing website performance and troubleshooting technical issues

3.4 Marketing and Communications

• Sending promotional emails about new games, bonuses, and special offers (with your consent)
• Providing important account notifications and security alerts
• Sending transactional communications about your deposits, withdrawals, and gameplay
• Conducting customer satisfaction surveys and requesting feedback

4. Legal Basis for Processing

Under applicable data protection laws, we must have a legal basis to process your personal information. We rely on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you when you register an account and use our services as outlined in our Terms & Conditions.
• Legal Obligation: Processing is necessary to comply with legal and regulatory requirements such as KYC, AML, age verification, 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 personal information, particularly for marketing communications. You may withdraw consent at any time.

5. Data Sharing and Disclosure

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

5.1 Service Providers

We share information with trusted third-party service providers who perform services on our behalf, including:

• Payment Processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals.
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, and other licensed game developers to deliver gaming content.
• Identity Verification Services: Third-party KYC providers to verify your identity and detect fraudulent documents.
• Cloud Hosting Services: Secure cloud infrastructure providers to store data and host our Platform.
• Customer Support Tools: Live chat software and customer relationship management (CRM) systems to manage support inquiries.
• Analytics Providers: Services that help us analyze usage patterns and improve our Platform.

All service providers are contractually obligated to protect your information and use it only for the specific purposes for which it was disclosed.

5.2 Legal and Regulatory Authorities

We may disclose your information to law enforcement, regulatory bodies, courts, or government agencies when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with legal obligations, court orders, or regulatory requests
• Investigate and prevent fraud, money laundering, or other illegal activities
• Enforce our Terms & Conditions or other policies
• Protect the rights, property, or safety of lumi77, our users, or the public

5.3 Business Transfers

If lumi77 is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your personal information may be transferred to the successor entity. We will notify you via email or prominent notice on our Platform before your information is transferred and becomes subject to a different privacy policy.

5.4 With Your Consent

We may share your information with third parties for purposes not described in this policy when we have obtained your explicit consent to do so.

6. Data Security Measures

We implement industry-leading security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data transmitted between your device and our servers is protected using 256-bit SSL/TLS encryption, the same technology used by major financial institutions.
• Secure Storage: Personal information is stored on secure servers with restricted access, protected by firewalls and intrusion detection systems.
• Access Controls: We implement strict role-based access controls, ensuring that only authorized personnel can access personal information on a need-to-know basis.
• Password Protection: We use industry-standard hashing algorithms to store passwords securely. We never store passwords in plain text.
• Regular Security Audits: Our systems undergo regular security assessments, vulnerability scans, and penetration testing by independent security firms.
• Employee Training: All employees with access to personal information receive regular training on data protection and security best practices.
• Payment Security: We do not store complete credit card or bank account numbers on our servers. Payment processing is handled by PCI DSS-compliant third-party processors.

While we strive to protect your personal information using reasonable security measures, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us if you suspect unauthorized access to your account.

7. Data Retention

We retain 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:

• Active Accounts: Personal information for active accounts is retained for the duration of your relationship with lumi77 and as long as your account remains open.
• Closed Accounts: After account closure, we retain certain information for up to 7 years to comply with legal obligations such as tax reporting, AML regulations, and to resolve disputes or enforce agreements.
• Marketing Communications: If you unsubscribe from marketing emails, we retain your email address on a suppression list to ensure we honor your opt-out request.
• Transaction Records: Financial transaction records are retained for 7 years in accordance with standard accounting and tax requirements.
• KYC Documents: Identity verification documents are retained for the period required by applicable AML and KYC regulations, typically 5-7 years after account closure.

When personal information is no longer needed, we securely delete or anonymize it so that it can no longer be associated with you.

8. Your Privacy Rights

Depending on your location and applicable laws, you may have the following rights regarding your personal information:

• Right of Access: You can request a copy of the personal information we hold about you.
• Right to Rectification: You can request that we correct inaccurate or incomplete personal information.
• Right to Erasure ("Right to be Forgotten"): You can request deletion of your personal information, subject to legal retention requirements.
• Right to Restrict Processing: You can request that we limit how we use your personal information in certain circumstances.
• Right to Data Portability: You can request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Right to Object: You can object to processing of your personal information for direct marketing purposes or based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: You have the right to file a complaint with a data protection authority if you believe we have violated your privacy rights.

To exercise any of these rights, please contact us at [email protected] with the subject line "Privacy Rights Request." We will respond to your request within 30 days. We may request additional information to verify your identity before processing your request.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our Platform. Cookies are small text files stored on your device that help us remember your preferences and improve functionality.

Types of Cookies We Use:

• Essential Cookies: Necessary for the Platform to function properly, such as keeping you logged in and maintaining session security. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, username, and game favorites.
• Analytics Cookies: Help us understand how users interact with our Platform by collecting anonymous usage statistics.
• Marketing Cookies: Track your activity across websites to deliver personalized advertisements and measure campaign effectiveness.

You can manage cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of our Platform. Most browsers allow you to refuse all cookies or accept only certain types of cookies.

10. International Data Transfers

lumi77 operates internationally and may transfer your personal information to countries outside Indonesia, including countries that may have different data protection standards. When we transfer data internationally, we implement appropriate safeguards to ensure your information remains protected in accordance with this Privacy Policy and applicable laws, including:

• Using Standard Contractual Clauses approved by relevant data protection authorities
• Ensuring recipients are certified under recognized data protection frameworks
• Implementing technical and organizational security measures during transfer and storage

By using our Platform, you acknowledge and consent to the transfer of your personal information outside Indonesia where necessary to provide our services.

11. Children's Privacy

lumi77 is strictly an adults-only service. You must be at least 21 years of age or the legal age of majority in your jurisdiction, whichever is greater, to create an account or use our Platform. We do not knowingly collect personal information from individuals under 21 years of age.

If we discover that we have inadvertently collected personal information from a minor, we will immediately delete such information from our systems and permanently close the associated account. If you believe a minor has provided personal information to lumi77, please contact us immediately at [email protected] so we can take appropriate action.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting the updated policy on this page with a new "Last Updated" date
• Sending an email notification to the email address registered to your account
• Displaying a prominent notice on our Platform homepage

Your continued use of the Platform after the effective date of the revised policy constitutes your acceptance of the updated terms. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. If you do not agree with any changes, you may close your account by contacting customer support.

13. Contact Information

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

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Privacy Rights Request"
• Live Chat: Available 24/7 through the lumi77 website
• Response Time: We aim to respond to all privacy inquiries within 30 days

For data protection complaints or concerns that cannot be resolved through our customer support channels, you may contact the relevant data protection authority in your jurisdiction.