Privacy Policy

1. Introduction

This Privacy Policy explains how luna77 ("we," "us," "our," or the "Company") collects, uses, discloses, stores, and protects personal information obtained from users ("you," "your," or "Player") of our online gaming platform, website, mobile applications, and related services (collectively, the "Services").

luna77 operates the website https://luna77.cam and is committed to safeguarding the privacy and personal data of all users in accordance with applicable Indonesian data protection laws and international best practices.

By creating an account on luna77, accessing our website, or using any of our Services, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree with any aspect of this Privacy Policy, please do not use our Services.

2. Information We Collect

luna77 collects several categories of personal information to provide, maintain, protect, and improve our Services. The types of data we collect include:

2.1 Account Registration Information

When you create a luna77 account, we collect the following mandatory information:

• Personal Identifiers: Full legal name (as it appears on your Indonesian KTP or passport), date of birth, gender
• Contact Information: Email address, phone number (including country code), residential address (street, city, province, postal code)
• Account Credentials: Username, password (stored in encrypted form), security questions and answers
• Demographic Data: Citizenship, country of residence, preferred language

2.2 Identity Verification (KYC) Documents

To comply with Indonesian anti-money laundering regulations and age verification requirements, we collect:

• Government-issued identification documents (Indonesian KTP, driver's license, or passport)
• Proof of address documents (utility bills, bank statements, government correspondence)
• Proof of payment method ownership (bank account statements, e-wallet screenshots showing name and account number)
• Selfie photographs holding your identification document (for biometric verification)

2.3 Financial and Transaction Data

When you deposit funds, place bets, or request withdrawals, we collect:

• Payment method details (bank account numbers for BCA, BRI, BNI, Mandiri; e-wallet account identifiers for OVO, DANA, GoPay, ShopeePay)
• Transaction history (deposit amounts, withdrawal amounts, timestamps, transaction IDs)
• Betting and gaming history (wagers placed, game types, outcomes, winnings, losses)
• Bonus and promotion usage data (claimed bonuses, wagering progress, reward redemptions)

2.4 Technical and Usage Data

We automatically collect technical information when you access luna77:

• Device information (device type, operating system, browser type and version, screen resolution)
• IP address and approximate geolocation (to verify Indonesian residency and comply with jurisdictional restrictions)
• Session data (login times, logout times, session duration, pages visited)
• Cookies and tracking technologies (see Section 8 for details)
• Gameplay data (game choices, betting patterns, time spent on platform, feature usage)

2.5 Communications Data

When you contact luna77 customer support or respond to surveys, we collect:

• Communication content (live chat transcripts, email correspondence, phone call recordings with your consent)
• Feedback and survey responses
• Complaint details and resolution records

2.6 Marketing and Preference Data

If you opt in to marketing communications, we collect:

• Communication preferences (email, SMS, push notification settings)
• Marketing engagement data (email open rates, link clicks, promotion redemptions)
• Favorite game types and betting interests (to personalize offers)

3. How We Use Your Information

luna77 uses the collected personal information for the following legitimate business purposes:

3.1 Service Provision and Account Management

• Creating and maintaining your luna77 account
• Processing deposits, withdrawals, and bet settlements
• Providing access to casino games, sports betting markets (including bandar bola football betting, togel lottery, slot gacor slots), and live dealer tables
• Delivering customer support services in Indonesian (24/7 in WIB timezone)
• Managing VIP tier progression (Bronze through Black Diamond) and loyalty rewards

3.2 Legal Compliance and Fraud Prevention

• Verifying your identity and age (21+ requirement enforcement)
• Complying with Indonesian anti-money laundering (AML) and Know Your Customer (KYC) regulations
• Detecting and preventing fraudulent activity, duplicate accounts, and bonus abuse
• Investigating suspected rule violations and Terms of Service breaches
• Responding to legal requests from Indonesian government authorities

3.3 Platform Security and Technical Operations

• Protecting luna77's systems from cyber attacks, unauthorized access, and data breaches
• Monitoring platform performance, uptime, and technical issues
• Conducting system maintenance and software updates
• Analyzing usage patterns to optimize user experience

3.4 Marketing and Personalization (with your consent)

• Sending promotional offers, bonus announcements, and exclusive VIP rewards (email, SMS, push notifications)
• Personalizing game recommendations based on your betting history
• Informing you about new features, sports events (BRI Liga 1, EPL, Champions League), and seasonal promotions (Idul Fitri, Ramadhan, Independence Day)
• Conducting market research and customer satisfaction surveys

3.5 Responsible Gaming Support

• Monitoring player behavior for signs of problem gambling
• Enforcing self-exclusion requests and deposit limits
• Providing access to responsible gaming tools and resources
• Facilitating contact with professional gambling support organizations

4. Information Sharing and Disclosure

luna77 does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your data in the following limited circumstances:

4.1 Service Providers and Business Partners

We share necessary information with trusted third-party service providers who assist in operating luna77:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay, ShopeePay) to process deposits and withdrawals
• Game Suppliers: Casino and slot game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) for game delivery and bet settlement
• Identity Verification Services: KYC verification providers for document authentication and age verification
• Customer Support Platform: Live chat software and ticketing systems (data encrypted in transit and at rest)
• Cloud Infrastructure: Secure data center providers for hosting and storage (ISO 27001 certified facilities)

All service providers are bound by strict confidentiality agreements and are permitted to use your data only for the specific purposes we authorize.

4.2 Legal and Regulatory Requirements

We may disclose your information to comply with legal obligations:

• In response to valid subpoenas, court orders, or legal processes from Indonesian authorities
• To report suspicious transaction activity to financial intelligence units (as required by AML laws)
• To enforce our Terms and Conditions and protect luna77's legal rights
• To protect the safety, security, and integrity of our platform and users

4.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. You will be notified via email and prominent website notice before your data is transferred and becomes subject to a different Privacy Policy.

4.4 With Your Consent

We may share your information with third parties when you provide explicit consent, such as when participating in joint promotions with partner brands or when you authorize us to share data with a specific organization.

5. Data Retention

luna77 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

5.1 Active Account Data

While your luna77 account remains active, we retain all account information, transaction history, and gameplay data to provide ongoing service and comply with regulatory requirements.

5.2 Closed Account Data

After you close your account (voluntarily or due to Terms violation):

• Financial Records: Retained for a minimum of 7 years to comply with Indonesian financial and tax record-keeping laws
• KYC Documents: Retained for 7 years post-account closure for anti-money laundering compliance
• Betting History: Retained for 5 years for dispute resolution and regulatory audit purposes
• Marketing Data: Deleted within 90 days of account closure unless you remain opted in to communications
• Technical Logs: Retained for 12 months for security monitoring and fraud investigation

5.3 Legal Hold

If your account is subject to an active investigation, legal dispute, or regulatory inquiry, we will retain relevant data until the matter is fully resolved, even if it exceeds the standard retention periods.

6. Data Security Measures

luna77 employs industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

6.1 Encryption

• SSL/TLS Encryption: All data transmitted between your device and luna77 servers is protected by 256-bit SSL encryption (the same standard used by banks)
• Database Encryption: Sensitive data fields (passwords, payment details, identification documents) are encrypted at rest using AES-256 encryption
• Password Hashing: User passwords are hashed using bcrypt algorithm with salt, making them unreadable even to luna77 staff

6.2 Access Controls

• Role-based access control (RBAC) ensures only authorized employees can access personal data on a need-to-know basis
• Multi-factor authentication (MFA) required for all staff accessing sensitive systems
• Regular access audits and automatic session timeouts

6.3 Infrastructure Security

• Data centers are ISO 27001 certified with 24/7 physical security and environmental controls
• Firewall protection, intrusion detection systems (IDS), and real-time threat monitoring
• Regular penetration testing and security audits conducted by independent third parties
• Daily encrypted backups stored in geographically separate locations

6.4 Employee Training

All luna77 employees undergo mandatory data protection and security awareness training upon hiring and annually thereafter. Staff members sign confidentiality agreements prohibiting unauthorized use or disclosure of player data.

7. Your Privacy Rights

Under applicable Indonesian data protection laws, you have the following rights regarding your personal information:

7.1 Right to Access

You may request a copy of the personal data luna77 holds about you. Log in to your account and navigate to Account Settings > Privacy Center > Data Export to download your data, or contact [email protected] to request a comprehensive data report.

7.2 Right to Rectification

If your personal information is inaccurate or incomplete, you can update it directly through your Account Settings or contact our support team for assistance. Please note that certain information (such as date of birth and legal name) may require KYC re-verification if changed.

7.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data by closing your account. However, we are legally required to retain certain financial and KYC records for regulatory compliance periods (see Section 5). After these periods expire, your data will be permanently deleted.

7.4 Right to Restrict Processing

You may request that we limit how we use your personal data in certain circumstances, such as when you contest data accuracy or object to processing. Contact [email protected] with your request and reason.

7.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format (CSV or JSON) and transmit it to another service provider.

7.6 Right to Object

You may object to processing of your personal data for marketing purposes at any time by:

• Clicking the "Unsubscribe" link in promotional emails
• Adjusting notification preferences in Account Settings > Notifications
• Contacting [email protected] with your opt-out request

7.7 Right to Withdraw Consent

Where we rely on your consent to process personal data (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact our Data Protection team at [email protected] with the subject line "Privacy Rights Request". We will respond to your request within 30 days and may request additional identification to verify your identity before processing certain requests.

8. Cookies and Tracking Technologies

luna77 uses cookies and similar tracking technologies to enhance user experience, analyze platform usage, and deliver personalized content.

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help the website remember your preferences, login status, and browsing behavior.

8.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for login authentication, session management, and security features. These cannot be disabled.
• Functional Cookies: Remember your language preference, display settings, and account preferences.
• Performance Cookies: Collect anonymous usage statistics (pages visited, session duration, error messages) to improve platform performance.
• Marketing Cookies: Track your interaction with promotional offers to personalize bonus recommendations (only used with your consent).

8.3 Managing Cookies

You can control cookie settings through your browser preferences. However, disabling certain cookies may limit your ability to use luna77 features. Most browsers allow you to:

• View and delete cookies
• Block third-party cookies
• Block cookies from specific websites
• Delete all cookies when closing the browser

9. Third-Party Links and Services

luna77 may contain links to third-party websites, payment processors, or game providers. We are not responsible for the privacy practices or content of these external sites. This Privacy Policy applies only to information collected by luna77. We encourage you to review the privacy policies of any third-party services you interact with.

10. Children's Privacy

luna77 Services are strictly intended for adults aged 21 years or older. We do not knowingly collect personal information from individuals under 21. If we discover that we have inadvertently collected data from a minor, we will immediately delete the account and all associated information.

If you are a parent or guardian and believe your child has provided personal information to luna77, please contact us immediately at [email protected].

11. International Data Transfers

While luna77 is operated for Indonesian residents, some of our service providers (such as cloud infrastructure and game studios) may be located outside Indonesia. When we transfer your data internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by data protection authorities
• Service providers certified under recognized data protection frameworks
• Encryption of data in transit and at rest

12. Changes to This Privacy Policy

luna77 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated via:

• Email notification to your registered email address
• Prominent notice on the luna77 homepage and login screen
• Updated "Last Updated" date at the top of this policy

Your continued use of luna77 Services after any Privacy Policy update constitutes your acceptance of the revised terms. If you do not agree with the changes, please cease using our Services and contact us to close your account.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or luna77's data practices, please contact our Data Protection team:

• Email: [email protected] (Subject: Privacy Inquiry)
• Customer Support: Available 24/7 via live chat in Indonesian (WIB timezone)
• Mailing Address: luna77 Data Protection Officer, Jakarta, Indonesia
• Response Time: We aim to respond to all privacy inquiries within 48 hours (business days)

Acknowledgment: By using luna77 Services, you confirm that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.