Privacy Policy — cog77 Data Commitment

The following terms have the meanings assigned to them for the purposes of this Privacy Policy:

• "Personal Data" means any information that identifies or could reasonably be used to identify you as a natural person, either on its own or in combination with other data.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Platform" means the cog77 website accessible at https://cog77.app, all associated pages, and any related mobile interfaces or applications.
• "Player" / "You" means any individual who registers for or uses an account on the Platform.
• "Data Controller" means cog77, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of cog77, subject to our instructions and data protection obligations.
• "KYC" means Know Your Customer — the identity verification process used to confirm a Player's eligibility and prevent fraud or money laundering.
• "Cookie" means a small text file placed on your device by the Platform to enable certain functionality and collect usage data.

cog77 acts as the Data Controller for all Personal Data collected through the Platform. As Data Controller, cog77 is responsible for determining what data is collected, for what purpose, and for how long it is retained. cog77 is also responsible for ensuring that any Data Processors engaged on its behalf comply with equivalent data protection standards.

For all data protection enquiries, requests to exercise your rights, or formal complaints, please contact us using the details set out in Clause 15 of this policy.

cog77 collects Personal Data through several distinct channels. The categories of data collected, and the context in which each is gathered, are set out in the table below:

cog77 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data for identification purposes, or health data, except where a Player voluntarily discloses such information in the context of a responsible gaming self-assessment or support request.

cog77 processes your Personal Data on one or more of the following legal bases, depending on the specific activity:

• Contractual necessity: Processing required to create and manage your account, process deposits and withdrawals, settle bets, and deliver the platform services described in the Terms & Conditions.
• Legal obligation: Processing required to comply with anti-money laundering regulations, KYC obligations, fraud prevention requirements, and any applicable regulatory directives.
• Legitimate interests: Processing carried out to protect the security and integrity of the platform, prevent bonus abuse, analyze platform performance, and improve user experience — provided these interests are not overridden by your fundamental privacy rights.
• Consent: Processing for optional marketing communications, where you have explicitly opted in. You may withdraw your consent at any time by contacting support or updating your account preferences.

cog77 uses the Personal Data described in Clause 3 for the following specific purposes:

• Account creation and management: To register your account, verify your identity, and maintain accurate records of your profile and preferences.
• Payment processing: To facilitate IDR deposits via local Indonesian banks and e-wallets, process withdrawals to your nominated account, and maintain accurate financial records.
• KYC and compliance: To verify your identity and age (21+ requirement), confirm your country of residence as Indonesia, and satisfy our anti-fraud and anti-money laundering obligations.
• Customer support: To respond to your enquiries, resolve disputes, and maintain a record of your support interactions for quality assurance purposes.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, apply deposit limits, and refer players to appropriate support resources where necessary.
• Platform security: To detect, investigate, and prevent unauthorized account access, fraudulent transactions, bonus abuse, and other prohibited conduct described in the Terms & Conditions.
• Service improvement: To analyze aggregated, anonymized usage data and identify opportunities to enhance the platform experience for Indonesian players.
• Marketing communications: To send you promotional offers, bonus notifications, and updates about new games or features — only where you have consented, and only to the extent permitted by applicable law.

cog77 does not use automated decision-making or profiling in a manner that produces legal or similarly significant effects on you, except where required to fulfill our KYC or fraud prevention obligations, in which case you have the right to request human review of any automated decision.

cog77 does not sell your Personal Data. We may share your data with the following categories of third parties, strictly for the purposes described in this policy:

• Payment processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the financial data necessary to execute your deposit and withdrawal instructions.
• KYC and identity verification providers: Specialist third-party services that assist us in verifying your identity documents and confirming your age and address.
• Game studio providers: Providers such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive your session and account-tier data as necessary to deliver their games within the platform.
• Fraud prevention and security services: Third parties that help us detect and prevent unauthorized access, collusion, and financial crime.
• Cloud infrastructure providers: Hosting and data storage providers operating under data processing agreements that bind them to the same data protection standards we apply.
• Regulatory and law enforcement bodies: Where cog77 is required by law, court order, or regulatory instruction to disclose your data, we will comply with such requirements and, where legally permissible, notify you of the disclosure.

All third parties with whom cog77 shares Personal Data are required to process that data lawfully, in accordance with our instructions, and subject to contractual confidentiality and data protection obligations.

cog77 uses cookies and similar tracking technologies to enable core platform functionality, remember your session preferences, and collect anonymized usage statistics. The types of cookies we use are as follows:

• Strictly necessary cookies: Essential to the operation of the platform. These cookies enable login session management, security token validation, and basic navigation. They cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language settings and display options to provide a more personalized experience on return visits.
• Analytics cookies: Collect anonymized data about how players navigate the platform — which pages are visited most frequently, where users exit the funnel, and how long sessions last. This data is used in aggregate form only and cannot be linked back to individual players.
• Security cookies: Used to detect and prevent fraudulent sessions, bot activity, and unauthorized access attempts.

You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to log in and use the platform. cog77 does not use third-party advertising cookies or cross-site tracking pixels.

cog77 retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable regulatory and legal obligations. The following retention periods apply as a general guide:

At the end of the applicable retention period, Personal Data is either securely deleted from our systems or anonymized such that it can no longer be linked to any identifiable individual. Anonymized aggregate data may be retained indefinitely for statistical and analytical purposes.

cog77 implements a layered set of technical and organizational security measures designed to protect your Personal Data against unauthorized access, loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and our servers — any data you send to cog77 is encrypted in transit.
• Encryption at rest for sensitive stored data, including KYC documents and financial records.
• Role-based access controls ensuring that only authorized personnel with a legitimate operational need can access Personal Data.
• Multi-factor authentication requirements for internal system access by cog77 staff.
• Regular security assessments, including vulnerability scanning and penetration testing of the platform infrastructure.
• Incident response procedures that enable us to detect, contain, and notify affected players of any data breach within the timeframes required by applicable law.

While cog77 takes all reasonable precautions to protect your data, no internet-based system can guarantee absolute security. You are responsible for maintaining the security of your own login credentials. If you suspect unauthorized access to your cog77 account, contact our support team via live chat immediately.

As a player whose Personal Data is processed by cog77, you have the following rights with respect to that data:

• Right of access: You may request a copy of the Personal Data cog77 holds about you, along with information about how it is being used.
• Right to rectification: If any Personal Data we hold about you is inaccurate or incomplete, you may request that it be corrected or updated.
• Right to erasure: Subject to our legal retention obligations (see Clause 8), you may request the deletion of your Personal Data. We will comply unless retention is required by law or is necessary to resolve an outstanding dispute.
• Right to restriction of processing: You may ask us to limit how we use your data while a correction request or objection is being assessed.
• Right to data portability: You may request a machine-readable copy of the Personal Data you have provided to cog77, in a format that allows you to transfer it to another service provider.
• Right to object: You may object to processing based on legitimate interests, particularly in relation to marketing communications. Where you object to marketing, we will stop processing your data for that purpose immediately.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, contact cog77 customer support via live chat or email (see Clause 15). We will acknowledge your request within 72 hours and aim to fulfill it within 30 calendar days. In cases of complexity or high volume, we may extend this period by a further 30 days, in which case we will notify you accordingly.

cog77 will not charge a fee for handling data rights requests made in good faith. If requests are manifestly unfounded, excessive, or repetitive, we reserve the right to charge a reasonable administrative fee or decline the request, with written reasons provided.

cog77 is an adults-only platform. Access to and use of the Platform is strictly restricted to individuals who are at least 21 years of age. We do not knowingly collect Personal Data from individuals under the age of 21.

Where cog77 has reasonable grounds to believe that a Player is under 21, the account will be immediately suspended and any associated balance frozen pending investigation. KYC documentation will be requested to confirm the Player's age. If underage use is confirmed, the account will be permanently closed and all funds handled in accordance with applicable law.

If you are a parent or guardian and believe that a minor has registered on cog77, please contact our support team immediately via the channels set out in Clause 15 so that we can take prompt action.

The cog77 platform integrates with third-party service providers — including game studios, payment processors, and security providers — to deliver the full range of services available to players. While these integrations are carefully selected and governed by data processing agreements, cog77 is not responsible for the independent privacy practices of those third parties.

The cog77 Platform does not contain links to external third-party websites. However, game studios that power our casino and slot content (such as Evolution Gaming, Pragmatic Play, Microgaming, Spribe, NetEnt, and Pocket Games Soft) operate their own technical infrastructure and may process certain session-level data in accordance with their own privacy policies. We recommend reviewing the privacy documentation of any third-party provider you interact with through the platform.

cog77 operates a platform that serves Indonesian players and processes data through infrastructure that may be located outside Indonesia. Where Personal Data is transferred internationally, cog77 ensures that such transfers are subject to appropriate safeguards, including:

• Data processing agreements with receiving parties that incorporate standard contractual clauses or equivalent protections;
• Technical security measures, including encryption, that apply regardless of the data's physical location;
• Assessments of the legal framework in the destination jurisdiction to confirm that your rights will be adequately protected.

If you would like further information about the safeguards applied to any specific international transfer of your data, please contact us using the details in Clause 15.

cog77 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform features. Where amendments are material — meaning they affect your rights or our core obligations in a significant way — we will provide at least seven (7) days' advance notice via the registered email address associated with your account, or via a prominent banner on the Platform.

The effective date at the top of this policy will always reflect the date of the most recent revision. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised policy. If you do not accept the revised terms, you should stop using the Platform and request account closure before the effective date.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by cog77, please contact our support team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly on the Platform — this is the fastest route to our data protection team.
• Email: [email protected] (plain text — not a clickable link; please copy manually into your email client). Include "Privacy Request" in the subject line to ensure prompt routing.
• Operating Hours: 24/7 — primary coverage in WIB (UTC+7), with agents also available across WITA (UTC+8) and WIT (UTC+9) time zones.

If you are not satisfied with our response to a data rights request or complaint, you have the right to escalate the matter to a recognized independent data protection authority or dispute resolution body. cog77 will provide details of the appropriate authority upon request.