Privacy Policy

1 Definitions

For the purposes of this Privacy Policy, the following terms shall carry the meanings assigned below:

Term	Meaning
"Platform"	The ls999 website at https://ls999.club, including all pages, services, and features operated under the ls999 brand.
"Personal Data"	Any information relating to an identified or identifiable natural person — including name, date of birth, email address, phone number, payment details, device identifiers, and IP address.
"Processing"	Any operation performed on Personal Data — including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
"Member"	Any individual who has registered a verified Account on the ls999 Platform.
"Controller"	ls999, the entity that determines the purposes and means by which Personal Data is processed on the Platform.
"Third-Party Processor"	Any external service provider engaged by ls999 to process Personal Data on ls999's behalf — including payment gateways, KYC verification services, and fraud detection providers.
"KYC"	Know Your Customer — the identity and age verification process required before a Member may process withdrawals or access higher account tiers.

2 Scope & Application

This Privacy Policy applies to all Personal Data collected and processed by ls999 in connection with your use of the Platform. It covers:

Data collected when you register an Account, complete KYC verification, or update your profile.
Data collected during deposits, withdrawals, and all financial transactions on the Platform — including payments via BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja, and USDT.
Data collected through your gameplay activity — including bet history, game sessions, and bonus redemptions.
Technical and device data collected automatically when you access the Platform.
Communications data generated when you contact our support team via live chat, email, or WhatsApp.

This Policy does not apply to third-party websites, apps, or services that may be linked from the Platform. ls999 is not responsible for the privacy practices of any external entity.

ls999 primarily serves Members based in Indonesia — particularly in Jakarta, Surabaya, Bandung, Medan, Bali, Semarang, Yogyakarta, and other major cities. While this Policy is written in English, ls999's Indonesian-speaking support team is available 24/7 to assist Members with any data-related queries.

3 Data We Collect

3.1 Registration & Identity Data

When you create a Member Account, ls999 collects:

Full legal name (as it appears on your government-issued ID)
Date of birth (to verify you are 21 years of age or older)
Email address
Mobile phone number
Residential address (city, province, postal code)
Preferred username and encrypted password hash

3.2 KYC & Verification Documents

Prior to processing withdrawals, ls999 may require the following verification materials:

A copy or photograph of a government-issued identity document — National ID (KTP), passport, or driver's licence (SIM)
A selfie or live video capture for facial match verification
Proof of residential address (utility bill, bank statement, or official correspondence dated within the last 90 days)
Proof of ownership of the payment method used for deposits (e.g., screenshot of BCA, BRI, or OVO account showing the Member's name)

3.3 Financial & Transaction Data

Bank account numbers, e-wallet account identifiers, and USDT wallet addresses associated with your Account
Deposit and withdrawal amounts, timestamps, and confirmation references
Transaction history and running balance records
Currency denomination (IDR or USDT equivalent)

3.4 Gameplay & Betting Data

Bet history — including stakes, odds, markets selected, and outcomes — across all product verticals (Sportsbook, Slots, Live Casino, Crash Game, Esports Betting)
Session start and end times, session durations, and active-play intervals
Bonus redemptions, wagering progress, and promotion participation records
Togel (Indonesia's traditional numbers lottery) draw entries and result records where applicable

3.5 Technical & Device Data

IP address and approximate geolocation (city-level, derived from IP)
Device type, operating system, browser type and version
Screen resolution and device language settings
Session cookies, local storage tokens, and authentication tokens
Referring URL (the web address from which you arrived at ls999)

3.6 Communications Data

Records of live chat conversations with the ls999 support team
Email correspondence sent to or received from [email protected]
WhatsApp message logs where you have contacted us at +62 811 9999 000
Feedback, complaint, and dispute records

4 How We Collect Data

ls999 collects Personal Data through the following mechanisms:

Directly from you: When you complete the registration form, submit KYC documents, initiate a payment, contact support, or respond to a survey or promotion.
Automatically via the Platform: Through server logs, session cookies, analytics scripts, and device fingerprinting technologies that activate when you load any page on ls999.
From Third-Party Processors: Identity verification and fraud-screening partners may return enriched data profiles linked to the documents you submit during KYC (e.g., identity confirmation status, politically exposed person checks).
From Payment Partners: Payment processors including local Indonesian banks and e-wallet platforms may share transaction confirmation data, reference numbers, and account-ownership verification signals with ls999.
From Game Providers: Studio partners such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft may share anonymised game-round outcome data required for accurate bet settlement.

5 Purpose & Legal Basis for Processing

ls999 processes Personal Data only for specific, documented purposes. The table below maps each processing purpose to its corresponding legal basis:

Purpose	Data Categories Used	Legal Basis
Account registration & authentication	Identity, contact, credentials	Contract performance
Age & identity verification (KYC)	Identity documents, facial data	Legal obligation / Contract
Processing deposits & withdrawals	Financial, transaction	Contract performance
Fraud detection & anti-money-laundering	All categories	Legal obligation / Legitimate interest
Customer support & dispute resolution	Communications, transaction, identity	Contract performance / Legitimate interest
Platform security & abuse prevention	Technical, device, gameplay	Legitimate interest
Responsible gaming monitoring	Gameplay, behavioral patterns	Legal obligation / Legitimate interest
Personalisation & UX improvement	Technical, gameplay, preferences	Legitimate interest / Consent
Promotional communications (email/WhatsApp)	Contact, preferences	Consent (opt-in required)
Legal compliance & audit records	All categories	Legal obligation

Marketing communications: ls999 will only send you promotional emails, SMS, or WhatsApp messages if you have explicitly opted in during registration or via your Account notification settings. You may withdraw consent at any time by updating your preferences in Account Settings or by contacting support.

6 Data Sharing & Disclosure

6.1 Third-Party Processors

ls999 engages carefully vetted Third-Party Processors to assist in delivering the Platform's services. These processors may access Personal Data solely to perform their contracted function and are bound by strict data processing agreements that prohibit any secondary use of your information. Current processor categories include:

Payment processors: Local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, Bank Danamon) and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja) for transaction processing and fund routing.
KYC & identity verification services: Third-party identity verification providers that perform document authentication, liveness checks, and politically exposed person (PEP) screening.
Game studios: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive the minimum session data required to operate their RNG-certified game engines.
Cloud infrastructure: ls999 utilises enterprise-grade cloud hosting infrastructure with data encrypted at rest and in transit.
Analytics & fraud detection: Aggregated, anonymised behavioral data may be shared with fraud-detection vendors to identify suspicious activity patterns.

6.2 Legal Disclosures

ls999 may disclose Personal Data to governmental, regulatory, or law enforcement bodies without prior notice to the Member where such disclosure is required by applicable law, court order, or licensing authority mandate. In all such cases, ls999 will disclose only the minimum amount of data necessary to satisfy the legal requirement and will document the disclosure in its compliance records.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of ls999's assets, Personal Data held on the Platform may be transferred to the acquiring entity as part of that transaction. In such circumstances, ls999 will notify registered Members via email at least 30 days prior to any change in data controller, and Members will retain the right to request deletion of their data before the transfer takes effect.

What we will never do: ls999 will never sell, rent, or trade your Personal Data to advertising networks, data brokers, or any entity whose primary purpose is commercial profiling or direct marketing. This commitment is unconditional and not subject to override by any commercial arrangement.

7 Data Retention

ls999 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention schedule applies:

Data Category	Retention Period	Reason
Account registration data	Duration of Account + 5 years post-closure	AML/KYC regulatory compliance
KYC identity documents	5 years from date of verification	Legal obligation
Transaction records	7 years from transaction date	Financial audit requirements
Gameplay & bet history	3 years from session date	Dispute resolution / Responsible gaming
Support communications	3 years from last interaction	Dispute resolution / Quality assurance
Technical / session logs	12 months from collection	Security monitoring
Marketing preferences	Until consent is withdrawn	Consent-based processing
Self-exclusion records	Permanent	Responsible gaming obligation

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Anonymised, aggregated data that cannot be linked back to any individual may be retained indefinitely for statistical and product development purposes.

8 Security Measures

ls999 implements a layered, defence-in-depth approach to data security that reflects the sensitivity of the financial and identity data we hold. Our security framework includes the following controls:

Encryption in transit: All data exchanged between your browser or app and ls999's servers is encrypted using TLS 1.3. Older, insecure protocol versions (TLS 1.0, TLS 1.1, SSLv3) are disabled across all endpoints.
Encryption at rest: Sensitive Personal Data — including KYC documents, payment account identifiers, and password hashes — is encrypted at rest using AES-256.
Access controls: Internal access to Personal Data is governed by role-based access controls (RBAC). Staff members can access only the data required for their specific function. All privileged-access actions are logged and reviewed.
Two-factor authentication (2FA): ls999 strongly recommends enabling 2FA on your Member Account. Internal staff systems require mandatory 2FA on all administrative panels.
Penetration testing: ls999's infrastructure undergoes regular security assessments by independent third-party security professionals to identify and remediate vulnerabilities before they can be exploited.
Incident response: ls999 maintains a documented data breach response procedure. In the event of a breach that poses a material risk to Members, ls999 will notify affected Members within 72 hours of becoming aware of the incident, detailing the nature of the breach, data categories affected, and remediation steps taken.

Provably Fair & Secure: While ls999 cannot guarantee that any system is perfectly immune to attack, we commit to applying industry-leading security practices and to acting swiftly and transparently in the unlikely event of any security incident.

9 Cookies & Tracking Technologies

ls999 uses cookies and similar tracking technologies to ensure the Platform functions correctly, to keep you securely logged in, and to understand how Members interact with the site so we can continuously improve it.

9.1 Types of Cookies Used

Cookie Type	Purpose	Consent Required?
Strictly Necessary	Session authentication, CSRF protection, load balancing, and basic Platform functionality. Without these cookies the Platform cannot function.	No — essential to service
Functional	Remembering your language preferences, display settings, and last-used payment method to personalise your experience.	No — legitimate interest
Analytics	Aggregate, anonymised usage data — page views, session durations, navigation paths — used to improve Platform design and performance.	Yes — opt-in
Security & Fraud Detection	Device fingerprinting and behavioral anomaly signals used to detect bot activity, multiple-account fraud, and unauthorised login attempts.	No — legitimate interest

9.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block, delete, or receive notifications about cookies. Please note that disabling Strictly Necessary cookies will prevent you from logging in to or using the ls999 Platform. Disabling Security cookies may limit our ability to protect your Account from fraud.

10 Your Rights Over Your Personal Data

As a Member of ls999, you hold the following rights with respect to your Personal Data. To exercise any of these rights, contact our support team via live chat or at [email protected]. ls999 will respond to all verifiable rights requests within 30 calendar days.

Right of Access Request a copy of all Personal Data ls999 holds about you, including the categories of data, purposes of processing, and any third parties with whom it has been shared.

Right of Rectification Request correction of any inaccurate or incomplete Personal Data in your Account. Many fields can be updated directly in your Account profile; others require support verification.

Right to Erasure Request deletion of your Personal Data where it is no longer necessary for the purpose it was collected, subject to legal retention obligations that may require us to retain certain records.

Right to Restrict Processing Request that ls999 suspends active processing of your data — for example, while a dispute is under investigation — without requiring full deletion.

Right to Data Portability Request an export of your Personal Data in a structured, machine-readable format (JSON or CSV) that you can transfer to another service provider.

Right to Object Object to processing carried out on the basis of legitimate interest — particularly direct marketing communications — with immediate effect upon objection.

ls999 may need to verify your identity before processing a rights request. This is a necessary security measure to ensure we do not disclose or delete data belonging to someone else. We will never charge a fee for handling a rights request unless the request is manifestly unfounded or excessive.

11 Minors & Age Restriction

The ls999 Platform is strictly for adults aged 21 years and above. ls999 does not knowingly collect Personal Data from individuals under the age of 21. The Platform's registration flow includes a mandatory date-of-birth declaration, and age is independently verified during the KYC process before any withdrawal is permitted.

If ls999 discovers that it has inadvertently collected Personal Data from a person under 21, it will immediately suspend the associated Account, delete the collected data in accordance with applicable law, and return any deposited funds through the original payment method.

If you are a parent or guardian and believe that a minor in your care has registered on the ls999 Platform, please contact us immediately at [email protected]. We will investigate and take prompt action, including permanent closure of the Account and deletion of all associated data.

12 International Data Transfers

ls999 primarily processes and stores Member data within data centre infrastructure serving the Asia-Pacific region to minimise latency for Indonesian users. In limited circumstances — for example, where a KYC verification partner or fraud detection vendor is based outside Indonesia — Personal Data may be transferred internationally.

Whenever Personal Data is transferred outside Indonesia, ls999 ensures that appropriate safeguards are in place, including:

Executing data processing agreements with the receiving entity that include legally binding obligations to protect the data to a standard equivalent to this Policy.
Requiring the receiving entity to implement technical security measures at least as stringent as those described in Section 8 of this Policy.
Limiting transferred data to the minimum necessary for the processor's contracted function.

By using the ls999 Platform, you acknowledge that your Personal Data may be transferred internationally in the circumstances described above, subject to the safeguards outlined herein.

13 Amendments to This Policy

ls999 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. When we make material changes — such as introducing a new category of data collection, a new sharing arrangement, or a change in retention periods — we will:

Post the updated Policy on this page with a revised "Last updated" date at the top.
Send registered Members an email notification at least 14 calendar days before the changes take effect, clearly summarising what has changed and why.
Display a prominent on-Platform notice during the notice period.

Your continued use of the Platform after the effective date of any amended Policy constitutes your acceptance of the revised terms. If you do not accept the updated Policy, you must cease using the Platform and may request Account closure and data deletion in accordance with Section 10.

14 Contact Us — Data Queries & Rights Requests

For all privacy-related enquiries, rights requests, or data complaints, please contact the ls999 Data Team through any of the following channels. We commit to acknowledging your enquiry within 48 hours and resolving it within 30 calendar days:

24/7 Live Chat: Available directly on the Platform — the fastest channel for urgent data concerns.
Email: [email protected] — please include "Privacy Request" in the subject line to ensure prompt routing to our data team.
WhatsApp: +62 811 9999 000 — Indonesian-speaking agents available around the clock.

When submitting a rights request, please provide your registered email address, the nature of your request, and sufficient information to verify your identity. ls999 will never charge a fee for processing a legitimate data rights request.

This Privacy Policy was last reviewed and updated on 1 January 2026. All prior versions of this Policy are superseded in their entirety by this document.

256-Bit Encryption

No Data Selling

Your Data, Your Rights

Crypto Privacy