Privacy Policy

1. Information We Collect

hugo77 collects several types of information to provide, maintain, and improve our services. The categories of data we collect include:

1.1 Personal Identification Information

When you create an account with hugo77, we collect the following personal information:

• Full Legal Name: As shown on your Indonesian national identity card (KTP) or other government-issued ID
• Date of Birth: To verify you meet the minimum age requirement of 21 years
• Email Address: For account communications, password recovery, and promotional offers (with your consent)
• Phone Number: For account verification, security notifications, and customer support
• Residential Address: City, province, postal code, and full street address in Indonesia
• Indonesian Identification Number (NIK): From your KTP for identity verification and KYC compliance
• Copies of Identity Documents: Photos or scans of your KTP, selfie with ID, and proof of address for KYC verification

1.2 Financial Information

To process deposits and withdrawals, we collect:

• Bank Account Details: Account holder name, bank name (BCA, BRI, BNI, Mandiri, etc.), account number, and branch information
• E-Wallet Information: Registered phone number or account identifier for OVO, DANA, GoPay, or ShopeePay
• Transaction History: Records of deposits, withdrawals, bets placed, winnings, bonuses claimed, and account balances
• Payment Verification Data: Screenshots or transaction IDs provided by you to confirm deposit or withdrawal requests

Note: hugo77 does not directly store credit card numbers or full bank account credentials. Payment processing is handled through secure, PCI-DSS compliant third-party processors. We retain only the information necessary to identify your payment method for future transactions.

1.3 Account and Gaming Activity

We automatically collect information about your use of hugo77's platform, including:

• Login Activity: Date, time, IP address, and device type for each login to your account
• Betting History: All bets placed, including sport/game type, stake amount, odds, outcomes, and timestamps
• Bonus Usage: Bonuses claimed, wagering progress, bonus expiry dates, and compliance with bonus terms
• Game Interactions: Games played, session duration, win/loss statistics, and gameplay patterns
• Communication History: Records of customer support interactions via live chat, email, WhatsApp, and Telegram

1.4 Technical and Device Information

When you access hugo77, we automatically collect technical data:

• IP Address: To verify geographic location and detect suspicious activity
• Device Information: Type of device (desktop, mobile, tablet), operating system, browser type and version
• Cookies and Tracking Technologies: Session cookies, persistent cookies, and web beacons (see Section 6 for details)
• Referral Source: How you arrived at hugo77 (e.g., direct visit, search engine, affiliate link)
• Page Views and Navigation: Pages visited, time spent on pages, and clickstream data

1.5 Information from Third Parties

In limited circumstances, we may receive information about you from external sources:

• Fraud Prevention Services: Data from third-party fraud detection and prevention providers to identify and prevent fraudulent activity
• Payment Processors: Transaction confirmation and payment status updates from banks and e-wallet providers
• Affiliate Partners: If you arrived at hugo77 through an affiliate link, we may receive your referral information (but not your personal details)
• Public Records: Information from publicly available sources to verify identity during KYC checks if discrepancies arise

2. How We Use Your Information

hugo77 uses the information we collect for specific, legitimate business purposes. Your data is processed to:

2.1 Provide and Improve Our Services

• Account Management: Create and maintain your hugo77 account, authenticate your identity, and provide access to our platform
• Transaction Processing: Execute deposits, withdrawals, and internal transfers between your account and payment methods
• Game Operation: Facilitate sports betting, casino games, and other gambling products; calculate odds, settle bets, and distribute winnings
• Bonus Administration: Track bonus eligibility, apply wagering requirements, and credit promotional offers to your account
• Platform Improvement: Analyze usage patterns to enhance user experience, fix bugs, and develop new features

2.2 Compliance and Security

• KYC and Age Verification: Verify you are at least 21 years old and confirm your identity to prevent underage gambling and fraud
• Anti-Money Laundering (AML): Monitor transactions for suspicious patterns that may indicate money laundering or terrorist financing
• Fraud Prevention: Detect and prevent multi-accounting, bonus abuse, collusion, arbitrage betting, and other prohibited activities
• Legal Obligations: Comply with applicable laws, regulations, and licensing requirements in our operating jurisdiction
• Dispute Resolution: Investigate and resolve disputes between hugo77 and users or between users themselves

2.3 Communication and Marketing

• Transactional Emails: Send account-related notifications such as successful deposits, withdrawal confirmations, bonus credits, and security alerts
• Customer Support: Respond to your inquiries via live chat, email, WhatsApp, or Telegram
• Promotional Communications: With your explicit consent, send marketing emails about new promotions, bonuses, tournaments, and product updates. You can opt out of marketing communications at any time.
• Responsible Gaming Messages: Send reminders about deposit limits, session durations, and self-exclusion options if we detect patterns suggesting problem gambling

2.4 Analytics and Research

• Performance Metrics: Measure platform performance, uptime, and transaction success rates
• User Behavior Analysis: Understand how users interact with hugo77 to optimize navigation, game offerings, and promotional strategies
• Market Research: Conduct aggregated, anonymized research on gambling trends in Indonesia and player preferences (no individual identification)

3. Legal Basis for Processing Your Data

hugo77 processes your personal information based on the following legal grounds:

3.1 Contractual Necessity

Processing is necessary to perform our contract with you (the Terms & Conditions you agreed to when registering). This includes account creation, transaction processing, game provision, and customer support.

3.2 Legal Obligations

Processing is required to comply with legal and regulatory obligations, including KYC verification, AML monitoring, age verification, and record-keeping requirements imposed by our licensing jurisdiction.

3.3 Legitimate Interests

Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, platform improvement, and analytics—provided these interests do not override your fundamental privacy rights.

3.4 Consent

For marketing communications and non-essential cookies, we process your data based on your explicit consent, which you can withdraw at any time through your account settings or by contacting support.

4. How We Share Your Information

hugo77 does not sell or rent your personal information to third parties. However, we may share your data in the following limited circumstances:

4.1 Service Providers

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

• Payment Processors: To facilitate deposits and withdrawals via Indonesian banks and e-wallets
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and other developers who supply casino games and live dealer services
• KYC and Verification Services: Specialized providers who verify identity documents and detect fraudulent IDs
• Cloud Hosting Providers: Servers and infrastructure providers who store and process data on our behalf
• Customer Support Tools: Live chat software, ticketing systems, and communication platforms
• Analytics Services: Platforms that help us understand user behavior and improve our services (data is anonymized where possible)

All service providers are contractually obligated to protect your data, use it only for the specified purposes, and comply with applicable data protection laws.

4.2 Legal and Regulatory Authorities

We may disclose your information to law enforcement, regulatory bodies, or courts if:

• Required by law, subpoena, court order, or legal process
• Necessary to investigate suspected fraud, money laundering, or other illegal activity
• Required to comply with licensing obligations or regulatory inquiries
• Necessary to protect hugo77's rights, property, or safety, or that of our users

4.3 Business Transfers

If hugo77 undergoes a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the successor entity. We will notify you via email or prominent notice on our website 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 not described above if you provide explicit consent for us to do so.

5. Data Retention

hugo77 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 Accounts

While your account is active, we retain all associated data to provide continuous service, maintain transaction history, and comply with ongoing legal obligations.

5.2 Closed Accounts

After you close your account:

• Transaction Records: Retained for 7 years to comply with financial record-keeping and tax regulations
• KYC Documents: Retained for 7 years for AML compliance and potential regulatory audits
• Dispute-Related Data: Retained until the dispute is resolved and any appeal periods have expired
• Marketing Data: Deleted immediately upon account closure or opt-out from marketing communications
• Anonymized Analytics: May be retained indefinitely in aggregated, non-identifiable form for research purposes

5.3 Inactive Accounts

If you have not logged into your account for 2 consecutive years, we may archive your account and anonymize personal data while retaining transaction records as required by law.

6. Cookies and Tracking Technologies

hugo77 uses cookies and similar tracking technologies to enhance your experience and analyze platform usage.

6.1 What Are Cookies?

Cookies are small text files stored on your device when you visit hugo77. They contain information that helps the website recognize your device on subsequent visits.

6.2 Types of Cookies We Use

6.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse or delete cookies, though this may limit your ability to use certain features of hugo77. Essential cookies cannot be disabled without affecting site functionality.

7. Data Security

hugo77 implements comprehensive security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.

7.1 Technical Security Measures

• SSL/TLS Encryption: All data transmitted between your device and hugo77 servers is encrypted with 256-bit SSL/TLS protocols
• Secure Servers: Data is stored on servers located in secure facilities with physical access controls, surveillance, and redundant power supplies
• Firewall Protection: Network firewalls prevent unauthorized access to our systems and databases
• Data Encryption at Rest: Sensitive data such as KYC documents and financial records are encrypted when stored on our servers
• Regular Security Audits: Third-party security experts conduct penetration testing and vulnerability assessments

7.2 Operational Security Measures

• Access Controls: Employee access to personal data is restricted on a need-to-know basis with role-based permissions
• Staff Training: All employees receive training on data protection, privacy laws, and security best practices
• Incident Response Plan: We maintain protocols for detecting, responding to, and reporting data breaches
• Two-Factor Authentication (2FA): Available for user accounts to add an extra layer of login security

7.3 Your Responsibilities

While hugo77 implements robust security measures, you also play a role in protecting your account:

• Choose a strong, unique password and change it regularly
• Never share your password or account credentials with anyone
• Enable two-factor authentication (2FA) for enhanced security
• Log out after using hugo77 on shared or public devices
• Report any suspicious activity or unauthorized access immediately

8. Your Privacy Rights

As a hugo77 user, you have certain rights regarding your personal information:

8.1 Right to Access

You have the right to request a copy of the personal data we hold about you. This includes account details, transaction history, betting records, and KYC documents. Access requests can be made by contacting our support team at [email protected]. We will respond within 30 days.

8.2 Right to Rectification

If your personal information is inaccurate or incomplete, you have the right to request correction. You can update most information directly in your account settings. For changes requiring verification (e.g., name, date of birth), contact customer support with supporting documentation.

8.3 Right to Erasure (Right to Be Forgotten)

You may request deletion of your personal data in certain circumstances:

• The data is no longer necessary for the purposes it was collected
• You withdraw consent (for data processed based on consent)
• You object to processing based on legitimate interests, and there are no overriding grounds for continued processing

Note: We may be unable to delete data required for legal compliance, such as transaction records and KYC documents, which must be retained for 7 years under financial regulations.

8.4 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format (e.g., CSV or JSON) and transfer it to another service provider. Contact support to request a data export.

8.5 Right to Object

You can object to processing of your data for direct marketing purposes at any time. Click "Unsubscribe" in marketing emails or adjust preferences in your account settings. You may also object to processing based on legitimate interests, though we may continue processing if we can demonstrate compelling grounds that override your interests.

8.6 Right to Restrict Processing

You may request that we limit how we use your data in certain situations, such as while we verify the accuracy of disputed data or assess your objection to processing. During restriction, we will store the data but not use it without your consent (except for legal purposes).

8.7 How to Exercise Your Rights

To exercise any of the above rights, contact hugo77 customer support at [email protected] with your request. For security purposes, we may ask you to verify your identity before processing the request. We aim to respond to all requests within 30 days, though complex requests may take up to 60 days.

9. International Data Transfers

hugo77 primarily operates to serve Indonesian users. However, as an internationally licensed platform, your personal data may be transferred to, stored, or processed in countries outside Indonesia where our servers, service providers, or business partners are located. These countries may have different data protection laws than Indonesia.

9.1 Safeguards for International Transfers

When we transfer your data internationally, we implement appropriate safeguards to ensure its protection:

• Standard contractual clauses approved by international data protection authorities
• Data processing agreements with service providers requiring GDPR-equivalent protections
• Security measures such as encryption during transmission and at rest
• Regular audits of international service providers' data protection practices

10. Children's Privacy

hugo77 is not intended for individuals under the age of 21. We do not knowingly collect personal information from anyone under 21 years of age. Our registration process includes age verification, and we require KYC documentation to confirm legal age before processing the first withdrawal.

If we discover that we have inadvertently collected information from someone under 21, we will immediately delete that information and close the account. If you believe a minor has created an account with hugo77, please contact us immediately at [email protected].

11. Changes to This Privacy Policy

hugo77 may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. The "Last Updated" date at the top of this page indicates when the policy was most recently revised.

Material changes will be communicated to users via:

• Email notification to the address registered on your account
• Prominent notice on the hugo77 website or in your account dashboard
• Pop-up notification upon your next login after the update

Your continued use of hugo77's services after the updated Privacy Policy takes effect constitutes acceptance of the changes. If you do not agree with the updated policy, you should discontinue using hugo77 and may close your account.

12. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or how hugo77 handles your personal information, please contact us:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Live Chat: Available 24/7 on the hugo77 website
• WhatsApp: Contact details available on our website
• Response Time: We aim to respond to all privacy-related inquiries within 48 hours

For formal data protection complaints, you may also have the right to lodge a complaint with the data protection authority in your country or our licensing jurisdiction.