Privacy Policy

This Privacy Policy ("Policy") applies to all personal data collected and processed by raf99 ("we", "us", "the Company") in connection with the raf99 platform accessible at raf99.cam ("Platform"), including all associated services, betting products, casino games, payment processing, and customer support interactions.

By registering an account on raf99, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, please do not register an account or use the Platform.

This Policy should be read alongside our Terms & Conditions, which govern the overall use of the Platform.

1Definitions

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly — including name, email address, phone number, national identification number, IP address, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "Data Controller" means raf99, the entity that determines the purposes and means of processing your Personal Data.
• "Player" or "you" means any natural person who registers an account on, or interacts with, the raf99 Platform.
• "KYC" means Know Your Customer — the identity verification process applied to Player accounts before withdrawals are processed or when required for compliance purposes.
• "Cookies" means small text files stored on your device by a web browser when you visit the Platform.
• "Third-Party Service Providers" means companies engaged by raf99 to provide specific services such as payment processing, fraud detection, analytics, and customer support infrastructure.

2Data We Collect

raf99 collects only the data necessary to deliver, secure, and continuously improve the Platform experience for Indonesian players. The categories of Personal Data we collect are as follows:

2.1 Registration Data

• Full legal name (as it appears on your KTP or passport)
• Date of birth
• Email address
• Indonesian mobile phone number
• Residential address in Indonesia
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Copy of national ID (KTP — Kartu Tanda Penduduk), passport, or SIM (driving licence)
• Proof of residential address (utility bill, bank statement)
• Selfie photograph for liveness verification, where required

2.3 Financial Data

• Bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, or other accepted Indonesian banks
• E-wallet account identifiers for OVO, DANA, and GoPay
• Transaction history, deposit and withdrawal records
• Betting and wagering activity logs

2.4 Technical and Usage Data

• IP address and approximate geolocation
• Browser type, operating system, and device identifiers
• Session timestamps, page visit logs, and clickstream data
• Game and betting session records

2.5 Communications Data

• Content of live chat transcripts, email correspondence, and support tickets submitted to raf99
• Records of promotional communications you have opted into or out of

3How We Collect Data

raf99 collects Personal Data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotion.
• Automatically — through Cookies, server logs, and analytics tools when you access or browse the Platform.
• From third-party partners — including payment processors (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay) and fraud prevention services, where such data is necessary to verify transactions or protect the security of your account.

4Purpose of Processing

raf99 processes your Personal Data for the following specific purposes:

5Legal Basis for Processing

5.1 Contractual Necessity. Processing your Registration Data, Financial Data, and KYC Data is necessary to fulfill our obligations under the raf99 Terms & Conditions — specifically to create and manage your account, process transactions, and deliver the services you have contracted with us.

5.2 Legitimate Interests. We process Technical and Usage Data to maintain platform security, detect fraud, and improve service quality. These activities reflect our legitimate interests in operating a safe and reliable platform for all registered Players.

5.3 Consent. Where we process your data for marketing or promotional communications, we do so on the basis of your explicit consent obtained at registration or subsequently. You may withdraw this consent at any time by contacting our support team.

5.4 Legal Obligation. raf99 may process and disclose your Personal Data where required to do so by a competent legal authority, court order, or binding regulatory direction.

6Data Sharing

raf99 does not sell, rent, or trade your Personal Data to any third party for their own commercial purposes. We may share your data only in the following limited circumstances:

• Payment Processors: Your bank account or e-wallet details are shared with the relevant payment provider (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, or other accepted channels) solely to execute your requested transaction.
• KYC and Fraud Prevention Services: Identity verification data may be shared with specialist third-party KYC or fraud detection providers to validate your identity and protect your account.
• Technology Infrastructure Partners: Hosting, analytics, and customer support platform providers may access certain technical or communications data in the course of delivering their services to raf99. All such providers are bound by confidentiality obligations and may not use your data for their own purposes.
• Legal and Regulatory Authorities: Where required by law, court order, or applicable regulatory obligation, raf99 may disclose Personal Data to the relevant authority.

6.1 All Third-Party Service Providers engaged by raf99 are subject to contractual data protection obligations consistent with this Policy.

7Data Retention

7.1 raf99 retains your Personal Data for as long as your account remains active and for a minimum period of five (5) years after account closure, in accordance with our obligations regarding financial record-keeping, fraud prevention, and dispute resolution.

7.2 KYC documentation is retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.

7.3 Communications Data (live chat transcripts, support ticket records) is retained for a minimum of two (2) years.

7.4 Technical and Usage Data retained for analytics purposes is anonymized where possible after twelve (12) months.

7.5 When retention periods expire, Personal Data is securely deleted or anonymized so that it can no longer be linked to an individual Player.

8Cookies & Tracking Technologies

8.1 raf99 uses Cookies and similar tracking technologies to operate and improve the Platform. Cookies allow us to recognize returning users, maintain session state, analyze traffic patterns, and deliver relevant content.

Types of Cookies used on raf99:

• Strictly Necessary Cookies: Essential for core Platform functionality, including maintaining your login session and processing transactions. These cannot be disabled.
• Performance and Analytics Cookies: Collect anonymized data about how Players interact with the Platform — pages visited, session durations, error rates — to help us improve service quality.
• Functional Cookies: Remember your preferences, such as language settings and display configurations, to deliver a more personalized experience.
• Targeting and Marketing Cookies: Used, with your consent, to deliver relevant promotional content based on your browsing behavior on the Platform. You may opt out of these at any time.

8.2 You can manage or disable non-essential Cookies through your browser settings. Note that disabling certain Cookies may affect the functionality of the Platform.

9Security Measures

9.1 raf99 applies industry-standard technical and organizational measures to protect your Personal Data against unauthorized access, loss, alteration, or disclosure. These measures include:

• Bank-grade SSL (TLS 1.2 or higher) encryption for all data in transit between your device and our servers
• Encryption of sensitive data fields (passwords, financial account details) at rest
• Strict role-based access controls, limiting Personal Data access to authorized personnel on a need-to-know basis
• 24/7 transaction monitoring and automated fraud detection systems
• Regular security audits and vulnerability assessments

9.2 Despite these measures, no internet transmission or electronic storage system is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, raf99 will notify affected Players as required.

9.3 You are responsible for maintaining the confidentiality of your account password. raf99 recommends using a strong, unique password and enabling any available two-factor authentication features.

10Your Rights

As a registered Player and data subject, you hold the following rights in relation to your Personal Data held by raf99:

• Right of Access: You may request a copy of the Personal Data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restriction: You may request that we restrict the processing of your data in certain circumstances, such as while a dispute is being resolved.
• Right to Data Portability: You may request that we provide your data in a structured, machine-readable format for transfer to another service provider.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing. We will cease such processing unless we can demonstrate compelling legitimate grounds.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our support team at [email protected]. We will respond to all requests within a reasonable timeframe and in accordance with applicable data protection requirements.

11Minors

11.1 The raf99 Platform is strictly for adults aged 21 and over. We do not knowingly collect Personal Data from persons under the age of 21.

11.2 If we discover that Personal Data has been collected from a minor, we will immediately close the associated account and delete all related data. If you believe a minor has accessed the Platform, please contact our support team immediately.

11.3 We apply age verification checks during the registration process and as part of KYC procedures. These checks are a mandatory safeguard and not an optional step.

12Third-Party Links

12.1 The Platform does not contain links to third-party websites. If raf99 ever links to external resources in a future update, this Policy will be updated accordingly.

12.2 raf99 is not responsible for the privacy practices of any third-party services or platforms you may independently access, including the websites of payment providers such as BCA, BRI, or OVO.

13Amendments to This Policy

13.1 raf99 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. Material changes will be communicated to registered Players by email or a prominent notice on the Platform prior to the changes taking effect.

13.2 The most current version of this Policy is always available at raf99.cam/privacy-policy. The "Last Updated" date at the top of the page indicates when the most recent revision was made.

13.3 Your continued use of the Platform following notification of changes constitutes your acceptance of the revised Policy.

14Contact Us

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the way raf99 handles your Personal Data, please contact our Data Protection team:

Email: [email protected]

14.2 Our support team includes native Indonesian-speaking agents available 24 hours a day, 7 days a week. For data protection inquiries, responses are typically provided within 3 business days.

14.3 All formal data subject rights requests should be submitted in writing to the email address above with the subject line "Data Rights Request" and a brief description of your request. We may ask for identity verification before actioning the request.