city99 Privacy Policy

1. Introduction

This Privacy Policy applies to all users of the city99 platform accessible at https://city99.click and describes our practices regarding the collection, use, disclosure, and protection of personal information. city99 operates as an international online gaming platform serving Indonesian players with sports betting, live casino games, slot machines, and lottery entertainment.

By creating an account, accessing our website, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with this policy, you must not use city99 services.

city99 complies with applicable international data protection laws and regulations, including standards equivalent to the General Data Protection Regulation (GDPR) where applicable to our operations. We are committed to maintaining the confidentiality, integrity, and availability of your personal data.

2. Information We Collect

2.1 Personal Information You Provide

When you register for a city99 account, we collect personal information that you voluntarily provide, including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification number (KTP number for Indonesian citizens)
• Contact Information: Email address, phone number, residential address, and postal code
• Financial Information: Bank account details for Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata), e-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history, and payment preferences
• Verification Documents: Copies of your Indonesian National ID (KTP), selfie photographs for identity verification, proof of address documents, and bank statements if requested for enhanced KYC procedures
• Account Credentials: Username, password (stored in encrypted form), security questions and answers, and two-factor authentication settings

2.2 Information Automatically Collected

When you access and use city99 services, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information
• Connection Information: IP address, geographic location (country, region, city based on IP), internet service provider, and connection type
• Usage Data: Pages visited, games played, bets placed, betting patterns, session duration, clickstream data, referral source, and interaction with customer support
• Transaction Data: Deposit amounts, withdrawal requests, bonus claims, wagering activity, win/loss records, and account balance changes
• Communication Records: Live chat transcripts, email correspondence, support tickets, and phone call recordings (where legally permitted and disclosed)

2.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment processors and financial institutions processing your deposits and withdrawals
• Identity verification services conducting KYC checks
• Fraud prevention and security service providers
• Game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe) providing gameplay data
• Marketing partners and affiliate platforms (if you were referred to city99)

3. How We Use Your Information

city99 processes your personal information for the following legitimate business purposes:

3.1 Account Management and Service Delivery

• Creating and maintaining your user account
• Verifying your identity and eligibility to use our services (KYC compliance)
• Processing deposits, withdrawals, and other financial transactions
• Providing access to sports betting, casino games, slots, and lottery products
• Calculating and crediting bonuses, promotions, and loyalty rewards
• Settling bets and game outcomes according to published rules
• Maintaining accurate transaction records and account history

3.2 Legal and Regulatory Compliance

• Complying with international gaming license requirements and regulations
• Preventing money laundering and terrorist financing (AML/CTF compliance)
• Enforcing age restrictions (minimum 21 years) and preventing underage gambling
• Responding to legal requests, court orders, and regulatory investigations
• Maintaining records required by gaming authorities and financial regulators
• Reporting suspicious transactions to relevant authorities when legally required

3.3 Security and Fraud Prevention

• Detecting and preventing fraudulent transactions, account takeovers, and identity theft
• Monitoring for unusual betting patterns, collusion, and bonus abuse
• Protecting the integrity of our games and betting markets
• Investigating disputes, chargebacks, and violations of our Terms and Conditions
• Blocking access from restricted jurisdictions and sanctioned individuals
• Maintaining security logs and audit trails for forensic investigation

3.4 Customer Support and Communication

• Responding to your inquiries, support requests, and complaints
• Sending transactional communications (deposit confirmations, withdrawal status updates, bonus notifications)
• Providing technical assistance and troubleshooting platform issues
• Notifying you of account-related matters (security alerts, verification requests, limit changes)
• Conducting customer satisfaction surveys and gathering feedback

3.5 Marketing and Personalization (With Your Consent)

• Sending promotional emails about new games, special offers, and exclusive bonuses
• Displaying personalized game recommendations based on your preferences
• Offering targeted promotions relevant to your betting interests (sports, casino, lottery)
• Inviting you to VIP programs and exclusive events for high-value players
• Conducting market research to improve our products and services

Note: You can opt out of marketing communications at any time by clicking "unsubscribe" in our emails or adjusting your communication preferences in your account settings.

3.6 Responsible Gaming and Player Protection

• Monitoring your activity for signs of problem gambling behavior
• Enforcing deposit limits, loss limits, and session time restrictions you have set
• Processing self-exclusion and cooling-off period requests
• Providing access to responsible gaming tools and support resources
• Intervening proactively when we detect potentially harmful gambling patterns

4. Information Sharing and Disclosure

city99 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information in the following limited circumstances:

4.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who assist us in operating our platform:

• Payment Processors: To process deposits via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and other payment methods
• Game Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe share gameplay data necessary to deliver casino games and slots
• KYC Verification Services: Third-party identity verification providers validate your KTP and conduct anti-fraud checks
• Customer Support Tools: Live chat platforms, ticketing systems, and CRM software providers
• Cloud Hosting Providers: Servers storing encrypted user data and transaction records
• Security and Fraud Prevention Vendors: Tools detecting fraudulent transactions and preventing cyberattacks

All service providers are contractually required to maintain confidentiality, use data only for specified purposes, and implement appropriate security measures.

4.2 Legal Obligations and Enforcement

We may disclose your information when required by law or when we believe disclosure is necessary to:

• Comply with court orders, subpoenas, or legal processes
• Respond to requests from gaming regulators, licensing authorities, or law enforcement agencies
• Enforce our Terms and Conditions or investigate violations
• Protect the rights, property, or safety of city99, our users, or the public
• Prevent fraud, money laundering, or other illegal activities
• Comply with anti-money laundering (AML) reporting requirements

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on our website before your information becomes subject to a different privacy policy.

4.4 With Your Consent

We may share your information with third parties when you have given explicit consent, such as when you authorize us to share your gaming activity with social media platforms or participate in third-party promotions.

5. Data Security Measures

city99 implements industry-leading security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Technical Security Controls

• 256-bit SSL Encryption: All data transmitted between your device and our servers is encrypted using TLS/SSL protocols
• Encrypted Data Storage: Personal information and financial data are encrypted at rest using AES-256 encryption
• Secure Password Storage: Passwords are hashed using bcrypt with salt, making them unreadable even to city99 staff
• Firewalls and Intrusion Detection: Multi-layer firewall protection and real-time threat monitoring
• DDoS Protection: Distributed denial-of-service mitigation to ensure platform availability
• Regular Security Audits: Penetration testing and vulnerability assessments conducted by independent security firms

5.2 Organizational Security Measures

• Access Controls: Role-based access restrictions ensure only authorized personnel can access sensitive data
• Employee Training: Staff undergo regular security awareness and data protection training
• Background Checks: All employees with access to personal data undergo background verification
• Confidentiality Agreements: Staff and contractors sign non-disclosure agreements
• Incident Response Plan: Documented procedures for responding to data breaches or security incidents
• Regular Backups: Encrypted backups stored in geographically distributed data centers

6. Data Retention

city99 retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy and comply with legal obligations:

Data Category	Retention Period	Legal Basis
Account Information	Duration of account + 7 years after closure	Gaming regulations, tax law, AML requirements
KYC Documents	7 years after account closure	Anti-money laundering regulations
Transaction Records	7 years from date of transaction	Financial regulations, tax compliance
Betting History	7 years from date of bet	Gaming license requirements, dispute resolution
Communication Logs	3 years from date of communication	Customer service quality, dispute resolution
Marketing Consent	Until withdrawn or account closure	Consent-based processing
Session Logs (IP, device)	90 days	Security monitoring, fraud prevention

After the retention period expires, personal information is securely deleted or anonymized such that it can no longer identify you. Anonymized data may be retained indefinitely for statistical analysis and business intelligence purposes.

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request a copy of the personal information city99 holds about you. We will provide this information in a structured, commonly used, and machine-readable format within 30 days of your request.

7.2 Right to Rectification

You can update inaccurate or incomplete personal information through your account settings or by contacting customer support. We will verify and update your records within 7 business days.

7.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal information if you close your account and withdraw consent for data processing. However, we must retain certain data for the periods specified in Section 6 to comply with legal obligations.

7.4 Right to Object

You can object to processing of your personal information for marketing purposes at any time by opting out of promotional communications. You may also object to processing based on legitimate interests by contacting us with your specific concerns.

7.5 Right to Data Portability

You have the right to receive your personal information in a portable format and transmit it to another service provider where technically feasible.

7.6 Right to Withdraw Consent

Where we process your information based on consent (e.g., marketing communications), you can withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, contact our Data Protection Officer at [email protected] with "Privacy Rights Request" in the subject line. We will respond within 30 days.

8. Cookies and Tracking Technologies

city99 uses cookies and similar tracking technologies to enhance your user experience and analyze platform usage:

8.1 Types of Cookies We Use

• Essential Cookies: Required for basic platform functionality (login sessions, shopping cart, security features)
• Performance Cookies: Collect anonymous usage statistics to improve website performance
• Functional Cookies: Remember your preferences (language, currency, display settings)
• Targeting Cookies: Track your activity to deliver personalized content and advertisements

You can control cookie preferences through your browser settings. However, disabling certain cookies may limit your ability to use some features of the city99 platform.

9. International Data Transfers

city99 operates internationally and may transfer your personal information to servers located outside Indonesia. When we transfer data internationally, we ensure adequate protection through:

• Standard contractual clauses approved by relevant data protection authorities
• Transfers to countries recognized as providing adequate data protection
• Binding corporate rules for intra-group transfers
• Your explicit consent where required by law

10. Changes to This Privacy Policy

city99 reserves the right to update this Privacy Policy to reflect changes in our practices, legal requirements, or business operations. We will notify you of material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending email notification to your registered email address
• Displaying a prominent notice on the platform homepage

Your continued use of city99 services after changes take effect constitutes acceptance of the updated Privacy Policy.

11. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

• Email: [email protected] (Subject: Privacy Inquiry)
• Live Chat: Available 24/7 through your account dashboard
• WhatsApp Support: Available 08:00-24:00 WIB daily

We will acknowledge your inquiry within 48 hours and provide a substantive response within 30 days.