At raf99, we handle your personal data with the same care and integrity we bring to every aspect of the platform. This Privacy Policy explains exactly what information we collect, why we collect it, how it is used, and what rights you have over your data as a raf99 member.
Six core principles guide every decision we make about member data — from collection through to deletion.
raf99 collects only the personal data that is strictly necessary to operate the platform, verify your identity, process transactions, and comply with applicable anti-money-laundering obligations. We do not collect data speculatively or in excess of operational need.
All data transmitted between your device and raf99's servers is protected by TLS 1.3 encryption. Sensitive data — including identity documents, payment details, and authentication credentials — is stored using AES-256 encryption at rest on access-controlled infrastructure.
raf99 does not sell, rent, or trade your personal data to third-party marketers, data brokers, or advertising networks. Data sharing with third parties is limited strictly to service providers who need access to operate the platform on our behalf, under binding contractual data-protection terms.
You have the right to request a full copy of the personal data raf99 holds about you at any time. Requests are fulfilled within 30 days of receipt. We will not charge you a fee for a standard data access request unless the request is manifestly unfounded or excessive.
If any personal data raf99 holds about you is inaccurate or incomplete, you may request correction at any time via the account dashboard or by contacting support. Subject to legal retention obligations, you may also request deletion of your personal data upon account closure.
In the unlikely event of a data security breach that is likely to result in a risk to your rights or freedoms, raf99 will notify affected members without undue delay and will take all reasonable steps to contain the breach, assess its scope, and prevent recurrence.
Important notice: This Privacy Policy applies to all personal data processed by raf99 in connection with your use of the platform at https://raf99.app. By creating a raf99 account or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.
raf99 ("the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of all individuals who interact with the raf99 platform, including registered members, prospective members who browse the site without creating an account, and former members whose accounts have been closed.
This Privacy Policy describes:
This Privacy Policy should be read alongside raf99's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of a conflict between this Privacy Policy and any other document, this Privacy Policy governs with respect to personal data matters.
raf99 is the data controller in respect of all personal data processed in connection with the operation of the platform and the provision of its services to members primarily based in Indonesia. As data controller, raf99 determines the purposes and means of the processing of personal data and is accountable for ensuring that processing is carried out lawfully, fairly, and transparently.
For all privacy-related queries, data subject access requests, or complaints, members and prospective members may contact raf99's designated data privacy contact point at: [email protected] (plain text — not a clickable link), with the subject line "Privacy — [your username or registered email]".
The table below summarises the main categories of personal data raf99 collects and the context in which each category is obtained:
| Data Category | Specific Data Points | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, gender, nationality, national identity card (KTP) number and images | KYC verification (mandatory before first withdrawal) |
| Contact Data | Email address, Indonesian mobile telephone number, WhatsApp number (optional) | Account registration; profile updates |
| Account Credentials | Username, hashed password, two-factor authentication settings | Account registration; security updates |
| Financial Data | Bank account name and number (BCA, BRI, BNI, Mandiri, CIMB Niaga), e-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja), deposit and withdrawal transaction records | Deposit/withdrawal processing; AML compliance |
| Gaming Activity Data | Betting history, game session logs, wager amounts, win/loss records, bonus usage, game preferences | Continuously during platform use |
| Technical Data | IP address, device fingerprint, browser type and version, operating system, screen resolution, time zone (WIB/WITA/WIT), referring URL | Each platform session (automated) |
| Communications Data | Live chat transcripts, support email correspondence, voluntary feedback submissions | Customer support interactions |
| Responsible Gaming Data | Self-exclusion records, deposit limits, cooling-off period activations, session time reminders | When responsible gaming tools are activated by the member |
raf99 does not collect sensitive personal data (also known as special category data) such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data beyond what is strictly required for KYC age and identity verification purposes.
The majority of personal data raf99 holds is provided directly by you: when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or interact with responsible gaming tools. You are under no obligation to provide this data, but without it raf99 cannot provide the platform services.
When you access or use the raf99 platform, certain technical and behavioural data is collected automatically by raf99's server infrastructure and analytics systems. This includes your IP address, device identifiers, browser and operating system details, session timestamps, pages visited, and in-game activity. This data is used for security monitoring, fraud prevention, platform performance optimisation, and regulatory compliance.
raf99 may receive limited personal data about you from third-party service providers in the following circumstances:
raf99 processes personal data only where a valid legal basis exists. The following legal bases apply to raf99's data processing activities:
raf99 uses the personal data it collects for the following specific purposes:
raf99 will not use your personal data for automated decision-making that produces significant legal effects on you without providing an opportunity for human review, except where such processing is required by law or necessary for fraud prevention.
raf99 shares personal data with carefully selected third-party service providers who process data on raf99's behalf under binding data processing agreements. These include: KYC verification providers, payment processing partners, game studios, cloud infrastructure providers, customer support platform vendors, and fraud-detection technology providers. All service providers are contractually obligated to process data only on raf99's instructions, to maintain appropriate security standards, and to delete or return data upon termination of the service relationship.
raf99 may disclose personal data to regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, a valid court order, or a legitimate law enforcement request. raf99 will endeavour to notify affected members of such disclosures where legally permitted to do so.
In the event of a merger, acquisition, restructuring, or sale of all or part of raf99's business, member personal data may be transferred to the acquiring entity as part of the transaction. raf99 will notify affected members of any such transfer and the acquiring entity will be bound by the terms of this Privacy Policy with respect to pre-transfer data.
raf99 does not sell, lease, rent, or otherwise commercially exploit member personal data to third parties. This includes advertising networks, data brokers, and marketing aggregators.
raf99 uses cookies and similar tracking technologies on the platform. The following categories of cookies are used:
You may manage non-essential cookie preferences via the cookie settings panel accessible at any time from the platform footer. Withdrawing cookie consent does not affect the lawfulness of any prior processing.
raf99 does not use third-party advertising or retargeting cookies. You will not be tracked across other websites for the purpose of serving raf99 advertisements.
raf99 retains personal data only for as long as is necessary for the purposes for which it was collected, subject to applicable legal retention obligations. The following retention periods apply:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account and Identity Data | Duration of account + 5 years post-closure | AML / KYC legal obligation |
| Financial Transaction Records | 7 years from transaction date | Financial record-keeping legal obligation |
| Gaming Activity Logs | 5 years from session date | Licensing and dispute resolution |
| Customer Support Transcripts | 3 years from interaction date | Dispute resolution; legitimate interests |
| Self-Exclusion Records | Indefinitely (never deleted) | Responsible gaming — legal obligation |
| Marketing Consent Records | Until consent is withdrawn + 2 years | Consent compliance |
| Technical / Log Data | 12 months from collection | Security and fraud prevention |
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be associated with an identifiable individual.
raf99 operates infrastructure hosted in multiple jurisdictions to ensure platform availability and performance for members across Indonesia, including those accessing from Jakarta, Surabaya, Medan, Bandung, Bali, Semarang, Makassar, and other major cities. This means that personal data may be transferred to and processed in countries outside Indonesia.
Where personal data is transferred internationally, raf99 ensures that appropriate safeguards are in place, including:
Members may request further information about international transfer safeguards by contacting raf99 support at the contact details provided in Section 16 of this Privacy Policy.
As a raf99 member, you have the following rights in respect of your personal data. These rights may be exercised at any time by contacting raf99 support as described in Section 16.
Request a copy of all personal data raf99 holds about you. Fulfilled within 30 days.
Request correction of any inaccurate or incomplete personal data we hold.
Request deletion of your personal data, subject to legal retention obligations.
Request that we limit the use of your data while a complaint or dispute is being resolved.
Receive your data in a structured, machine-readable format to transfer to another service.
Object to processing based on legitimate interests, including direct marketing profiling.
raf99 will respond to all valid privacy rights requests within 30 calendar days. In complex cases, this period may be extended by a further 60 days, and you will be notified of the extension and the reason for it within the initial 30-day window.
The raf99 platform is strictly intended for adults aged 21 and above. raf99 does not knowingly collect or process personal data relating to persons under the age of 21. If raf99 discovers that personal data has been collected from a person under the age of 21, that data will be deleted immediately and the associated account will be permanently closed.
If you are a parent or guardian and believe that your child has created a raf99 account or provided personal data to the platform, please contact raf99 support immediately at the contact details provided in Section 16. raf99 will investigate and take prompt remedial action.
raf99 implements a comprehensive set of technical and organisational security measures to protect member personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:
While raf99 takes all reasonable measures to protect your data, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. Members are reminded of their responsibility to maintain the confidentiality of their own account credentials.
The raf99 platform may contain references or links to third-party game studios, payment providers, and sports data sources. These third-party services have their own privacy policies and raf99 takes no responsibility for their data practices. When you interact with a third-party service — for example, when a live casino game is streamed from an Evolution Gaming server — you are also subject to that provider's privacy terms, which are separate from this Privacy Policy.
raf99 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, platform features, or applicable legal requirements. The effective date of the current version is displayed at the top of this document. When material changes are made, raf99 will notify registered members by email to their registered address at least 7 days before the changes take effect. Continued use of the platform after the effective date of any amendment constitutes acceptance of the revised Privacy Policy.
Members who do not accept a material change to this Privacy Policy may close their account before the effective date and request deletion of their data (subject to legal retention obligations) by contacting raf99 support.
For all privacy-related queries, data subject rights requests, or concerns about raf99's data practices, please contact us using the following details:
raf99 aims to respond to all privacy-related queries within 5 business days (WIB). Formal data subject access requests will be acknowledged within 3 business days and fulfilled within 30 calendar days from receipt of a valid request.
If you are dissatisfied with raf99's response to a privacy concern, you have the right to escalate the matter to raf99's licensing authority's dispute resolution channel. Details of the applicable escalation process are provided upon request.
Support response times: 2–5 minutes via live chat during peak WIB hours · Up to 24 hours via email off-peak.
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