Privacy Policy

1. Introduction

tren99 ("we," "us," or "our") operates the online betting and gaming platform accessible at https://tren99.cam. In the course of providing our services to registered Users, we necessarily collect and process certain categories of personal data. This Privacy Policy sets out, in clear and transparent terms, the nature of that data, our purposes for processing it, the parties with whom it may be shared, the safeguards we apply, and the rights available to you as a data subject.

This Privacy Policy is incorporated by reference into our Terms & Conditions and should be read alongside them. By registering an Account on tren99 or by continuing to use our platform, you acknowledge that you have read, understood, and consented to the data practices described herein. If you do not agree with any part of this policy, please discontinue use of the platform and contact us to request Account closure.

We are committed to handling your personal data in accordance with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, integrity, and confidentiality. Our data practices are reviewed regularly to ensure they remain current, proportionate, and aligned with best practice.

2. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" — any information relating to an identified or identifiable natural person. This includes, but is not limited to, name, identification number, location data, online identifier, or factors specific to the physical, economic, or social identity of that person.
• "Processing" — any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Subject" — the natural person (i.e., you, the User) to whom the Personal Data relates.
• "Controller" — tren99, as the entity that determines the purposes and means of processing Personal Data.
• "Processor" — any third party that processes Personal Data on behalf of tren99 under a data processing agreement.
• "Cookies" — small text files placed on your device by the tren99 platform to enable certain functionality, preferences, and analytics.
• "KYC" — Know Your Customer; the identity verification process required of all Users prior to withdrawal, further described in our Terms & Conditions.
• "Sensitive Data" — a subset of Personal Data afforded additional protection, including government-issued identification numbers (e.g., KTP numbers), financial account details, and any data relating to a person's health or welfare.

3. Data We Collect

tren99 collects Personal Data across several categories depending on how you interact with our platform. The categories are described in the table below:

4. How We Collect Data

tren99 collects Personal Data through the following channels:

4.1 Direct Collection

You provide data directly to us when you register an Account, complete KYC verification, make a deposit or withdrawal, contact customer support, or update your Account preferences. This is the primary channel through which Identity, Contact, and Financial Data is obtained.

4.2 Automated Collection

When you visit and interact with the tren99 platform, our servers and analytics tools automatically collect Technical Data and Usage Data. This includes IP addresses, device identifiers, and session behaviour logs. This data is collected via server logs, cookies, and similar tracking technologies as described in Section 11.

4.3 Third-Party Sources

In limited circumstances, tren99 may receive Personal Data about you from third parties, including:

• Payment processors (e.g., bank transfer confirmation services for BCA, BRI, BNI, Mandiri; e-wallet providers such as OVO, DANA, and GoPay) who confirm transaction status and account ownership.
• Identity verification services used during KYC processing to cross-reference document authenticity.
• Fraud detection partners who provide risk scoring and flagging services to protect the integrity of our platform.

5. Purpose of Processing

tren99 processes your Personal Data for the following specific and legitimate purposes:

1. Account Management: To create, maintain, and administer your tren99 Account, including verifying your identity and enforcing our one-account-per-person policy.
2. Transaction Processing: To process deposits and withdrawals via local bank transfer (BCA, BRI, BNI, Mandiri) and e-wallets (OVO, DANA, GoPay), and to maintain accurate financial records.
3. KYC and Fraud Prevention: To verify your identity in compliance with our KYC obligations, detect and prevent fraudulent activity, money laundering, and unauthorised Account access.
4. Customer Support: To respond to your enquiries, resolve disputes, and maintain records of communications for quality assurance and compliance purposes.
5. Platform Improvement: To analyse usage patterns, diagnose technical issues, and enhance the features, security, and overall performance of the tren99 platform.
6. Responsible Gaming: To monitor betting patterns, apply deposit limits and self-exclusion requests, and fulfil our obligations under our Responsible Gaming Policy — including identifying Users who may require intervention or support.
7. Legal and Regulatory Compliance: To comply with applicable legal obligations, respond to lawful requests from competent authorities, and maintain records as required by law.
8. Marketing and Promotions: To send you relevant promotional offers, bonus notifications, and platform updates — but only where you have provided explicit consent or where we have a legitimate interest in communicating with you as an active Account holder. You may opt out at any time via your Account notification settings.
9. Security and Risk Management: To protect the platform, its Users, and tren99's business interests from security threats, technical vulnerabilities, and abuse of our services.

6. Legal Basis for Processing

tren99 processes your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you have accepted — including Account creation, transaction processing, and customer support.
• Legitimate Interests: Processing necessary for tren99's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided those interests are not overridden by your fundamental rights and freedoms.
• Legal Obligation: Processing required to comply with applicable legal or regulatory requirements, including KYC verification, anti-money laundering obligations, and responses to lawful authority requests.
• Consent: Where we rely on your consent — for example, for direct marketing communications beyond standard transactional messaging — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing

tren99 does not sell, rent, or trade your Personal Data to third parties. We may, however, share your data with the following categories of recipients where necessary and proportionate:

7.1 Service Providers and Processors

We engage carefully vetted third-party service providers who process data strictly on our behalf and under binding data processing agreements. These include:

• Payment processing partners — to facilitate deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, and GoPay.
• Identity verification providers — to perform document authentication and biometric checks during KYC.
• Cloud hosting and infrastructure providers — to store platform data and deliver platform functionality reliably and securely.
• Customer support platform providers — to manage live chat and email ticketing systems.
• Fraud detection and risk analytics providers — to identify and mitigate suspicious activity on the platform.

7.2 Game Studios and Content Providers

Certain game studios — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — may receive limited Technical Data (such as session tokens and anonymised player identifiers) to facilitate game delivery and integrity monitoring. These providers do not receive your name, financial details, or contact information.

7.3 Legal and Regulatory Authorities

tren99 may disclose Personal Data to competent governmental, regulatory, law enforcement, or judicial authorities where required to do so by applicable law, court order, or regulatory directive. We will, where lawfully permitted, notify affected Users of such disclosures.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of tren99's business, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such change and your rights as a data subject will be preserved.

8. International Data Transfers

Given the global nature of our technology infrastructure, your Personal Data may be transferred to and processed in countries outside of Indonesia. When such transfers occur, tren99 takes all reasonable steps to ensure that your data receives an equivalent level of protection to that which would apply within Indonesia, including through:

• Entering into data processing agreements with receiving entities that incorporate internationally recognised data transfer safeguards.
• Selecting service providers that operate under recognised security certification frameworks (e.g., ISO 27001, SOC 2).
• Applying technical controls — including end-to-end encryption in transit and at rest — to all data transferred across borders.

By using the tren99 platform, you acknowledge and consent to the transfer of your Personal Data to countries outside Indonesia where necessary for the delivery of our services, subject to the safeguards described above.

9. Data Retention

tren99 retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention schedules are as follows:

Following the expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised data may be retained indefinitely for aggregate analytics and platform improvement purposes.

10. Security Measures

tren99 applies a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, or alteration. Our security framework includes:

• SSL/TLS Encryption: All data transmitted between your device and the tren99 platform is encrypted using industry-standard TLS 1.2 or higher protocols, ensuring that information cannot be intercepted in transit.
• Encryption at Rest: Sensitive data stored on our servers — including KTP numbers, bank account details, and financial records — is encrypted at rest using AES-256 or equivalent standards.
• Access Controls: Access to Personal Data within our organisation is restricted on a strict need-to-know basis. All staff with data access are subject to confidentiality obligations and regular security training.
• Two-Factor Authentication (2FA): Available to all Users on their tren99 Accounts to provide an additional layer of protection against unauthorised login.
• Intrusion Detection and Monitoring: Continuous automated monitoring of platform infrastructure to detect and respond to suspicious activity in real time.
• Regular Security Audits: Periodic penetration testing and vulnerability assessments conducted by independent security professionals to identify and remediate weaknesses before they can be exploited.
• Secure Development Practices: Our engineering team follows security-by-design principles throughout the software development lifecycle, with code reviews and automated scanning for known vulnerability patterns.

11. Cookies & Tracking Technologies

tren99 uses cookies and similar tracking technologies to deliver platform functionality, remember your preferences, and gather analytics data that helps us improve our services. The types of cookies we use are described below:

11.1 Strictly Necessary Cookies

These cookies are essential for the platform to function. They enable core features such as session management, login authentication, and security token verification. These cookies cannot be disabled without severely impairing your ability to use the platform.

11.2 Functional Cookies

These cookies remember choices you make — such as your preferred payment method, language settings, and odds display format — to provide a more personalised experience. Disabling them may result in loss of personalisation across sessions.

11.3 Analytics Cookies

We use analytics tools to understand how Users interact with the tren99 platform — which pages are most visited, where users encounter difficulties, and how navigation flows can be improved. Analytics data is collected in aggregated and anonymised form wherever possible.

11.4 Managing Cookies

You may control and manage cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that blocking strictly necessary cookies will affect the functionality of the tren99 platform. Refer to your browser's help documentation for instructions on managing cookie preferences.

12. Your Data Rights

As a data subject, you have the following rights with respect to your Personal Data held by tren99. To exercise any of these rights, please contact us at the address provided in Section 16:

• Right of Access: You have the right to request a copy of the Personal Data we hold about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data. You may update certain information directly through your Account settings; for other changes, please contact support.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing was unlawful. This right is subject to overriding legal retention obligations described in Section 9.
• Right to Restriction of Processing: You may request that we restrict the processing of your Personal Data in certain circumstances — for example, while a dispute about its accuracy is being resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests, including profiling and direct marketing. Where you object to direct marketing, we will cease processing for that purpose immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing.

tren99 will respond to all valid rights requests within 30 days of receipt. In cases of complexity or high volume, this period may be extended by a further 60 days, of which you will be informed. We will not charge a fee for exercising your rights unless requests are manifestly unfounded or excessive.

13. Minors and Age Restriction

tren99 is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or retain the Personal Data of individuals under the age of 21. All registration and KYC processes include age verification steps specifically designed to identify and exclude underage applicants.

If tren99 becomes aware that Personal Data has been collected from an individual under the age of 21 — whether through fraudulent misrepresentation or any other means — that data will be deleted promptly and the associated Account permanently closed. Any funds held in such Accounts will be handled in accordance with applicable legal requirements.

Parents and guardians who believe their child may have accessed or registered on tren99 are encouraged to contact us immediately at [email protected] so that we can take appropriate action without delay.

14. Third-Party Links and Services

The tren99 platform may, from time to time, reference third-party services or technologies — such as game studio platforms, payment processors, or support tools — that operate under their own independent privacy policies. tren99 is not responsible for the data practices of these third parties, and this Privacy Policy does not extend to any external website, service, or application not directly operated by tren99.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of tren99. If you have concerns about how a specific third-party provider handles your data, please raise them directly with that provider or contact our support team for guidance.

15. Policy Amendments

tren99 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform functionality. The effective date at the top of this document will be updated with each revision.

Where changes are material — meaning they significantly affect how we collect, use, or share your Personal Data — we will notify you by email to your registered address and/or by a prominent notice on the platform at least 7 days before the changes take effect. For non-material changes (such as typographic corrections or clarifications that do not alter the substance of our practices), we may update the policy without individual notice.

Your continued use of the tren99 platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any change, you must cease using the platform and may request Account closure by contacting us at the details in Section 16.

16. Contact & Data Enquiries

If you have any questions, concerns, or requests regarding this Privacy Policy or the way tren99 handles your Personal Data — including requests to exercise any of the rights described in Section 12 — please contact our dedicated support and data team through the following channel:

Please mark your message with the subject line "Privacy Request" or "Data Enquiry" so that it is routed promptly to the appropriate team. Our support team is available 24 hours a day, 7 days a week, with Indonesian-speaking agents on hand during WIB (Western Indonesia Time, UTC+7) peak hours. We aim to acknowledge all formal privacy-related requests within 48 hours and to provide a full response within 30 days.

For urgent matters related to suspected data breaches or unauthorised Account access, please mark your message "URGENT — Security" to ensure it is escalated immediately to our security operations team.