cun99 Privacy Policy

This Privacy Policy governs the collection, use, storage, and disclosure of personal data by cun99 in connection with the operation of the online gaming platform accessible at cun99.one. It applies to:

• All registered Players with an active cun99 Account, regardless of whether they are currently logged in.
• Visitors who browse cun99.one without registering, to the extent that technical data (such as cookies and server logs) is automatically collected during their visit.
• Individuals who contact cun99 support via live chat or email, to the extent that communication data is retained.

This policy applies specifically to data collected and processed by cun99 in connection with its services targeting players in Indonesia and does not extend to any third-party websites, platforms, or services that may be accessible via links on our platform.

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

cun99 collects personal data through several channels depending on how you interact with the platform. The categories of data we collect are described below.

3.1 Data You Provide Directly

• Registration data: Full name, date of birth, email address, mobile number, and the city or province of residence (e.g., Jakarta, Surabaya, Bandung, Bali, Medan).
• KYC documents: Copies of government-issued photo identification such as a national identity card (KTP) or passport, submitted to verify your identity and confirm that you meet the 21+ age requirement.
• Payment information: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja) associated with your transactions. cun99 does not store full card numbers or banking credentials — payment data is handled by our regulated payment processors.
• Support communications: Messages, complaints, and documentation you submit when contacting the cun99 support team via live chat or email.

3.2 Data Collected Automatically

• Technical data: IP address, browser type and version, operating system, device type, screen resolution, and referring URL.
• Session data: Pages visited, time spent on each page, links clicked, game sessions initiated, and navigation paths through the platform.
• Transaction logs: Records of all deposits, withdrawals, bonus credits, wagers placed, and game results associated with your Account. These records are retained for financial audit and responsible gaming purposes.
• Cookie data: Information gathered via session cookies, persistent cookies, and similar tracking technologies as described in Clause 7.

cun99 processes personal data on the following legal grounds:

cun99 uses the personal data we collect solely for the purposes described below. We do not use your data in ways that are incompatible with these stated purposes without first seeking your consent.

• Account management: Creating, maintaining, and securing your cun99 Account, including authentication and access control.
• Transaction processing: Executing deposit and withdrawal requests via your nominated local bank or e-wallet, and maintaining accurate financial records.
• Identity verification: Confirming your identity and age during KYC checks to ensure compliance with the 21+ eligibility requirement and to prevent fraud.
• Customer support: Responding to queries, complaints, and disputes submitted via live chat or email to [email protected].
• Platform security: Detecting unauthorized access, investigating suspicious activity, and enforcing the prohibitions set out in the cun99 Terms & Conditions.
• Responsible gaming: Monitoring betting patterns to identify signs of problem gambling and applying self-exclusion or deposit limits requested by Players.
• Service improvement: Analyzing aggregated, anonymized usage data to improve platform performance, game selection, and user experience.
• Marketing communications: Where you have opted in, sending promotional offers, bonus notifications, and platform updates relevant to your activity. You may unsubscribe at any time.
• Legal compliance: Retaining records and disclosing information as required by applicable law, court order, or the direction of a competent regulatory authority.

cun99 does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate contractual safeguards:

• Payment processors: Banks and e-wallet providers (including BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja) receive the minimum transaction data necessary to execute your deposit or withdrawal request.
• Identity verification providers: Third-party KYC service providers that assist cun99 in verifying the authenticity of identity documents and confirming that Players meet the 21+ eligibility threshold.
• Fraud prevention services: Specialized providers that cross-reference transaction patterns and device fingerprints against known fraud databases to protect the platform and its Players.
• Game studios: Licensed game providers such as Pragmatic Play, Evolution Gaming, Spribe, and Pocket Games Soft receive the minimum session data required to deliver their game content and settle game results.
• Platform infrastructure providers: Cloud hosting, content delivery, and cybersecurity vendors that process data on cun99's behalf under binding data processing agreements.
• Legal and regulatory authorities: Competent law enforcement agencies or regulatory bodies when cun99 is legally compelled to disclose data or when disclosure is necessary to prevent fraud or protect the safety of Players.

cun99 uses cookies and similar client-side technologies to support the operation, security, and performance of the platform. The cookies we deploy fall into the following categories:

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent you from logging in to your cun99 Account. Analytics cookies can be disabled without affecting core platform access.

cun99 retains personal data for the periods set out below, after which data is securely deleted or irreversibly anonymized:

• Active Account data: Retained for the lifetime of your Account and for a period of 5 years following Account closure, to satisfy financial record-keeping and fraud investigation obligations.
• KYC documents: Retained for a minimum of 5 years from the date of submission, in line with standard anti-money laundering record-keeping expectations.
• Transaction records: Retained for 5 years from the date of each transaction to support financial audits and dispute resolution.
• Support communications: Retained for 2 years from the date of the last interaction, unless the communication relates to an open dispute or legal matter, in which case retention continues until the matter is resolved.
• Marketing consent records: Retained for the duration of your Account and for 3 years after Account closure to demonstrate compliance with consent obligations.
• Anonymous analytics data: May be retained indefinitely in aggregated, non-identifiable form for platform improvement purposes.

cun99 implements a layered security architecture to protect personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• Encryption in transit: All communication between your browser and cun99 servers is encrypted using TLS 1.2 or higher with 256-bit SSL certificates.
• Encryption at rest: Sensitive data stored in cun99 databases — including KYC documents and payment identifiers — is encrypted using AES-256 or equivalent standards.
• Access controls: Personal data is accessible only to authorized cun99 personnel who require it for a specific, documented business purpose. Access is controlled via role-based permissions and logged for audit purposes.
• Intrusion detection: cun99 operates continuous network monitoring and automated intrusion detection systems to identify and respond to security threats in real time.
• Penetration testing: The cun99 platform undergoes periodic security assessments by qualified third-party security professionals.
• Incident response: In the event of a confirmed data breach that poses a material risk to Players, cun99 will notify affected Players and relevant authorities without undue delay.

As a cun99 Player, you hold the following rights over your personal data. To exercise any of these rights, contact cun99 via the channels described in Clause 15. We will respond to verified requests within 30 calendar days.

To submit a data rights request, contact cun99 support via live chat or email as described in Clause 15. You will be asked to verify your identity before your request is processed to prevent unauthorized access to another person's data.

cun99 strictly prohibits the use of its platform by individuals under 21 years of age. cun99 does not knowingly collect personal data from anyone under 21. If you are a parent or guardian and believe that a minor has registered on cun99 using false age information, please contact us immediately via [email protected] so that the Account can be closed and all associated data deleted without delay.

Age verification is a mandatory component of the cun99 KYC process. No withdrawal will be processed until cun99 has confirmed through documentary evidence that the Account holder meets the 21+ eligibility requirement. Players who submitted false age information at registration will have their Accounts permanently closed and all winnings voided in accordance with the Terms & Conditions.

cun99 operates infrastructure that may involve the transfer and storage of personal data on servers located outside Indonesia. Where such transfers occur, cun99 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections applied within Indonesia. Safeguards may include:

• Binding contractual clauses in data processing agreements with service providers that obligate them to protect personal data to the standard required by this Privacy Policy.
• Use of service providers that maintain recognized international security certifications (such as ISO 27001) and undergo regular independent security audits.
• Transfer only of the minimum data necessary for the specific processing purpose, with strict access controls applied at the destination.

The cun99 platform integrates content and services from third-party game studios, including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. When you launch a game from one of these providers, the game content is delivered directly by that studio's servers. The studio's own privacy practices apply to any data collected during gameplay at the studio level.

cun99 is not responsible for the privacy practices of third-party game studios or any other external service. We encourage you to review the privacy policies of any third-party provider whose services you use via the cun99 platform. cun99 does not include external links to unrelated websites and assumes no liability for the content or data practices of sites not operated by cun99.

cun99 may update this Privacy Policy periodically to reflect changes in our data practices, applicable law, or platform features. When material changes are made, cun99 will notify registered Players via in-platform notification or email at least 7 days before the changes take effect. The "Last Updated" date at the top of this page will be revised with each amendment.

We encourage you to review this Privacy Policy periodically. Continued use of the cun99 platform after the effective date of any amendment constitutes acceptance of the updated policy. If you do not agree to the updated policy, you should discontinue use of the platform and request Account closure in accordance with the process described in Clause 10.

For any privacy-related queries, data rights requests, or concerns about how cun99 handles your personal data, please reach out through the following channels:

• Live Chat: Available 24/7 on the cun99 platform — recommended for time-sensitive privacy concerns, including suspected unauthorized Account access.
• Email: [email protected] — for formal data rights requests (access, rectification, erasure, portability). Please include your registered name and Account username so we can verify your identity efficiently. Allow up to 30 calendar days for a substantive response.

cun99 takes privacy complaints seriously. If you submit a complaint and are not satisfied with our response within 30 days, you have the right to escalate your concern through applicable legal channels in your jurisdiction.