Privacy Policy — ice77

The following terms are used throughout this Policy with the meanings set out below:

• "Personal Data" — any information that identifies or can be used to identify a living individual, either alone or in combination with other data.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, deletion, or transfer.
• "Controller" — ice77, the entity that determines the purposes and means of processing your personal data.
• "Data Subject" — you, the individual whose personal data is being processed.
• "KYC Data" — identity and address verification documents submitted during the Know Your Customer process (e.g., Indonesian KTP, passport, utility bill, selfie).
• "Transaction Data" — records of deposits, withdrawals, bets placed, games played, and other financial or gaming activity on the platform.
• "Third Party" — any entity other than ice77 and the Player, including payment processors, game studios, and compliance service providers.

This Policy applies to all personal data collected by ice77 in connection with the operation of the ice77 platform. It covers data collected through:

• The ice77 website at https://ice77.cam and any associated subdomains or mobile-optimised interfaces.
• The account registration and KYC verification process.
• Deposits, withdrawals, and gameplay activity on the platform.
• Customer support interactions via live chat or email.
• Cookies, session tracking, and analytics tools operating on the platform.

This Policy does not apply to external websites, payment processors, or game studio platforms that may be linked from or embedded within ice77. Those third parties operate under their own privacy policies, and ice77 is not responsible for their data practices.

ice77 collects the following categories of personal data. We collect only the minimum data necessary for the specific purpose identified, in line with the data-minimisation principle:

ice77 collects personal data through the following channels:

• Direct collection: Information you voluntarily provide during account registration, KYC document upload, customer support interactions, or any communication with ice77.
• Automated collection: Technical and usage data collected automatically through cookies, server logs, and analytics tools when you interact with the platform.
• Third-party sources: Identity verification data from licensed KYC screening services; fraud and AML risk signals from compliance data providers; geolocation data from IP intelligence services.
• Payment processors: Confirmation data and transaction status updates from BCA, BRI, BNI, Mandiri, and Indonesian e-wallet processors (OVO, DANA, GoPay, ShopeePay, LinkAja).

ice77 processes your personal data exclusively for the following identified purposes:

1. Account creation and management — registering your account, authenticating logins, maintaining your account wallet, and communicating account-related information.
2. Identity verification (KYC/AML) — confirming your identity, age (minimum 21 years), and address to comply with our licensing authority's anti-money laundering and counter-terrorism financing obligations.
3. Payment processing — facilitating deposits to and withdrawals from your ice77 account via Indonesian bank and e-wallet channels.
4. Fraud prevention and security — detecting, investigating, and preventing fraudulent activity, account takeover attempts, bonus abuse, and other security threats.
5. Responsible gaming — monitoring gameplay patterns to identify potential problem gambling indicators and administering self-exclusion, deposit limit, and session-time tools.
6. Customer support — responding to your queries, resolving disputes, and maintaining records of support interactions for quality assurance and regulatory purposes.
7. Legal and regulatory compliance — meeting obligations imposed by ice77's licensing authority, including record-keeping, reporting, and audit requirements.
8. Platform improvement — analysing aggregated usage data to improve the platform's performance, game selection, and user experience.

ice77 processes personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to perform the contract between ice77 and the Player (i.e., to operate your account, process deposits and withdrawals, and provide gaming services).
• Legal obligation: Processing required to comply with ice77's obligations under its international gaming licence, including KYC, AML screening, and regulatory record-keeping.
• Legitimate interests: Processing necessary for ice77's legitimate interests in fraud prevention, platform security, and product improvement, provided those interests are not overridden by your fundamental rights.
• Consent: Processing based on your explicit, freely given consent, where required — for example, for optional marketing communications. Consent may be withdrawn at any time by contacting support.

ice77 does not sell, rent, or trade your personal data. We share personal data with third parties only where strictly necessary, under binding data-processing agreements, and in the following limited circumstances:

• Payment processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) — to process deposit and withdrawal transactions. These providers receive only the data necessary to execute a specific transaction.
• KYC and identity verification services: Licensed third-party providers that screen identity documents and cross-reference against global watchlists. These providers act as data processors under ice77's instruction.
• Game studio providers: Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive a session token and minimal game-launch data to deliver their content. They do not receive your full identity or financial profile.
• Technology and infrastructure providers: Cloud hosting, CDN, and cybersecurity providers who process data solely to provide contracted infrastructure services to ice77, under strict data-processing terms.
• Regulatory and law enforcement authorities: ice77 may disclose personal data to its licensing authority, financial intelligence units, or law enforcement agencies where required by law or court order.

ice77 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to the following retention schedules:

• KYC and identity documents: Retained for a minimum of 5 years after account closure, in accordance with anti-money laundering record-keeping obligations imposed by our licensing authority.
• Transaction records (deposits, withdrawals, bets): Retained for a minimum of 5 years from the date of each transaction.
• Account profile data (email, contact details): Retained for the duration of the account relationship plus 5 years following closure.
• Customer support communications: Retained for 3 years from the date of the interaction, unless the interaction relates to an open dispute or regulatory matter.
• Technical and usage data (logs, IP records): Retained for 12 months from the date of collection, then anonymised or deleted.
• Cookies and session data: Retention periods vary by cookie type — see the Cookies clause below for details.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Players may request early deletion of certain data categories where ice77 is not legally required to retain it — see the Your Rights clause.

ice77 implements a comprehensive set of technical and organisational security controls to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Key measures include:

• Encryption at rest: All databases containing personal and financial data are encrypted using AES-256 symmetric encryption.
• Encryption in transit: All data transmitted between your browser and the ice77 platform is protected by TLS 1.3 (Transport Layer Security). Our SSL certificate is maintained at all times and is verifiable via the padlock icon in your browser.
• Access controls: Access to personal data within ice77 is restricted on a strict need-to-know basis. Staff access is governed by role-based permissions, multi-factor authentication (MFA), and activity audit logs.
• Penetration testing: ice77 engages independent third-party security firms to conduct regular penetration testing and vulnerability assessments of its platform and infrastructure.
• Incident response: ice77 maintains a documented data breach response procedure. In the event of a breach that is likely to result in a high risk to Player rights, affected individuals will be notified without undue delay.
• Staff training: All ice77 employees with access to personal data receive mandatory data protection training on joining and annually thereafter.

ice77 uses cookies and similar tracking technologies to operate the platform, maintain session security, and analyse usage patterns. The following cookie categories are used:

• Essential / Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens, security tokens, and geolocation compliance checks. These cookies cannot be disabled without rendering the platform unusable.
• Functional Cookies: Remember your preferences, such as language settings, preferred view options, and responsible gaming tool configurations.
• Analytics Cookies: Aggregate, anonymised data on how players interact with the platform, used solely by ice77 to improve product performance. These cookies do not track individual identities.
• Security Cookies: Detect anomalous behaviour, bot activity, and potential account takeover attempts. These cookies are essential for platform integrity.

ice77 does not use advertising or retargeting cookies and does not permit third-party advertising networks to place cookies on the platform.

As a data subject, you hold the following rights with respect to your personal data held by ice77. To exercise any of these rights, contact our support team at the email address listed in the Contact clause below. ice77 will respond to all valid data rights requests within 30 days.

ice77 does not knowingly collect personal data from individuals under the age of 21. The platform is strictly restricted to adults aged 21 and over. All accounts are subject to mandatory KYC age verification, and any account found to belong to a person under 21 will be immediately closed and all associated data deleted, except where retention is required for fraud or safeguarding purposes.

If you believe a person under 21 has registered an account on ice77, please notify us immediately at the contact details provided in this Policy. We will investigate and take appropriate action within 24 hours.

ice77's servers and infrastructure may be located in jurisdictions outside Indonesia. Where personal data is transferred internationally, ice77 ensures that appropriate safeguards are in place, including:

• Standard contractual clauses (SCCs) approved by relevant data protection authorities, incorporated into agreements with all data processors who receive personal data.
• Data transfer only to jurisdictions that provide an adequate level of data protection, or where supplementary measures are applied to ensure equivalent protection.
• Binding corporate rules or equivalent instruments where data is shared within ice77's affiliated group of companies.

By using the ice77 platform, you acknowledge and consent to the transfer of your personal data to servers and processors located outside Indonesia, subject to the safeguards described above.

ice77 may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or regulatory requirements. When material changes are made, we will notify registered players by email to the address on file, and post a prominent notice on the platform, at least 7 days before the updated Policy takes effect.

Your continued use of the ice77 platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not accept the updated Policy, you must cease using the platform and may request account closure. The version number and last-updated date at the top of this document indicate the current revision.

For all privacy-related enquiries, data rights requests, or concerns about how ice77 handles your personal data, please contact us through the following channel. ice77 does not accept privacy enquiries by telephone; please use email to ensure a documented record of your request.