Privacy Policy

1 Definitions

Throughout this Privacy Policy, the following terms carry the meanings set out below:

• "Platform" — the lisa22 website, mobile-optimized web application, and all associated digital services accessible at lisa22.cam.
• "Personal Data" — any information that identifies or can reasonably be used to identify a living individual, including name, date of birth, contact details, financial account information, device identifiers, and behavioral data.
• "Processing" — any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, storage, use, disclosure, and deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For this platform, the Data Controller is lisa22.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller under a contractual agreement and in accordance with documented instructions.
• "Player" / "User" / "you" — any individual who registers an account, visits the Platform, or interacts with any of its services.
• "KYC" — Know Your Customer; the identity, age, and source-of-funds verification process conducted before a Player may withdraw funds.
• "Cookie" — a small text file placed on your device by the Platform to enable functionality, retain session preferences, and analyze aggregate usage patterns.
• "IDR" / "Rp" — Indonesian Rupiah; the exclusive transaction currency of the Platform.

2 Data Controller

lisa22 is the Data Controller for all Personal Data collected through the Platform. As Data Controller, lisa22 is responsible for ensuring that your Personal Data is processed lawfully, fairly, and transparently in accordance with this Privacy Policy and applicable international data protection standards.

For all privacy-related inquiries, data access requests, or complaints, please contact our Data Protection team at:

• Email: [email protected]
• Subject Line: DATA PRIVACY REQUEST
• Response Time: Within 14 business days of receipt of a complete request.

3 Data We Collect

lisa22 collects the following categories of Personal Data in the course of providing its services:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification.
• Date of birth (to verify eligibility — Players must be at least 21 years of age).
• Email address and mobile phone number.
• Residential address, city, and province (e.g., Jakarta, Surabaya, Bandung, Bali, Medan, Yogyakarta).
• Username and encrypted password hash.

3.2 KYC & Verification Documents

• Copies of government-issued photo identification (Indonesian National Identity Card / KTP, or passport).
• Proof of payment method ownership (e.g., bank account screenshot or e-wallet registration confirmation).
• Source-of-funds declaration where applicable for high-value withdrawals.

3.3 Financial & Transaction Data

• Bank account details for deposit and withdrawal purposes (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon).
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Deposit and withdrawal history, transaction timestamps, and transaction reference numbers.
• Betting and wagering history across all product verticals.

3.4 Technical & Device Data

• IP address and approximate geolocation derived from IP.
• Device type, operating system, browser type and version.
• Session duration, pages visited, features used, and click-path data.
• Login timestamps and session identifiers.

3.5 Communication Data

• Records of live chat conversations, WhatsApp support interactions, and email correspondence with lisa22 support staff.
• Feedback, complaints, and survey responses submitted voluntarily.

4 How We Collect Data

lisa22 collects Personal Data through the following channels and mechanisms:

• Direct submission: Data you provide when completing the registration form, KYC submission, deposit or withdrawal request, or support inquiry.
• Automated collection: Technical and device data collected automatically when you visit or interact with the Platform, using server logs, session tracking, and analytics tools.
• Cookies and similar technologies: Data collected via cookies, local storage, and similar browser-based mechanisms as described in the Cookies Policy section of this document.
• Third-party verification providers: Identity and address data confirmed or supplemented via licensed KYC verification service providers during the account verification process.
• Payment processors: Transaction confirmation data received from your bank or e-wallet provider when processing deposits and withdrawals.
• Game providers: Aggregated game performance and session data shared by our licensed game studios (such as Pragmatic Play, Evolution Gaming, and Spribe) for audit, dispute resolution, and responsible gaming monitoring purposes.

5 Purpose & Legal Basis for Processing

lisa22 processes your Personal Data only for clearly defined purposes and on an appropriate legal basis for each processing activity:

5.1 Contract Performance

Processing necessary to fulfill our contractual obligations to you as a registered Player — including account management, transaction processing, customer support, and withdrawal facilitation. Without this processing, we cannot deliver the services you have contracted for.

5.2 Legal Compliance

Processing required to comply with our obligations under applicable anti-money laundering (AML) regulations, KYC requirements, responsible gaming standards, and international licensing conditions. This includes identity verification, transaction monitoring, and record-keeping for audit purposes.

5.3 Legitimate Interests

Processing carried out to pursue our legitimate business interests, where those interests are not overridden by your rights and freedoms. This includes fraud detection, security monitoring, platform improvement, abuse prevention, and responsible gaming monitoring.

5.4 Consent

Where we rely on your consent as a legal basis — for example, for optional marketing communications — you may withdraw that consent at any time by contacting us at [email protected]. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.

6 Data Sharing

lisa22 does not sell, rent, or trade your Personal Data to third parties for commercial or marketing purposes. We share your data only in the following limited and necessary circumstances:

• KYC and identity verification providers: Licensed third-party services used to verify your identity and age as required by our operating obligations.
• Payment processors and banking partners: Financial institutions (including BCA, BRI, BNI, Mandiri, and e-wallet providers) that process your deposits and withdrawals as instructed.
• Game software providers: Studios such as Evolution Gaming, Pragmatic Play, and Spribe receive session and wagering data necessary to operate their game software and resolve disputes.
• Regulatory and licensing authorities: Our international licensing authority may request access to player records and transaction logs as part of routine compliance audits or specific investigations.
• Law enforcement and government agencies: Where we are legally compelled to disclose data by a valid court order, subpoena, or regulatory directive, we will comply and will notify the affected Player where permitted by law.
• Fraud prevention and AML networks: Aggregated or flagged transaction data may be shared with licensed fraud prevention services to protect the integrity of the platform and the broader financial system.

7 International Data Transfers

As an internationally operated platform, lisa22 may transfer your Personal Data to servers and service providers located outside Indonesia. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that required under applicable international data protection frameworks.

Safeguards applied to international data transfers include:

• Contractual data processing agreements with all third-party processors that impose equivalent data protection obligations.
• Transfer of data only to jurisdictions that maintain adequate data protection standards as recognized by relevant international regulatory authorities.
• Encryption of data in transit and at rest for all cross-border data flows.

If you would like further information about the specific safeguards applied to any international transfer of your Personal Data, please contact us at [email protected] with the subject line "DATA PRIVACY REQUEST — INTERNATIONAL TRANSFER".

8 Data Retention

lisa22 retains your Personal Data only for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by applicable law and our licensing obligations. The following retention guidelines apply:

Upon expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymized so that it can no longer be associated with any identifiable individual.

9 Your Rights

Subject to applicable law and our legitimate processing obligations, you hold the following rights with respect to your Personal Data held by lisa22:

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data we hold about you. Minor updates (such as phone number changes) may be made directly from your Account settings page.
• 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, or where you withdraw consent and no other legal basis applies. Note that erasure requests may be declined where retention is required by law or our licensing obligations.
• Right to Restriction of Processing: You may request that we restrict the processing of your Personal Data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: You may request that we provide your Personal Data in a structured, commonly used, machine-readable format where technically feasible and where processing is based on your consent or a contract.
• Right to Object: You may object to processing based on legitimate interests, including profiling for responsible gaming monitoring or fraud detection, where you have grounds relating to your particular situation.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, submit a written request to [email protected] with the subject line "DATA PRIVACY REQUEST" and your full registered name and account email. We will respond within 14 business days.

10 Cookies Policy

The lisa22 Platform uses cookies and similar technologies to deliver a functional, personalized, and secure experience. Below is a breakdown of the cookie types we deploy and their purposes:

10.1 Managing Cookies

You may control or disable cookies through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in or using core platform features. Disabling functional cookies may reset your preferences on each visit. Disabling analytics cookies will not affect your ability to use the Platform but will prevent us from collecting aggregate usage data used to improve the service.

For detailed browser-specific instructions on managing cookies, refer to your browser's official help documentation. lisa22 does not deploy third-party advertising cookies or cross-site tracking technologies.

11 Security Measures

lisa22 implements a layered set of technical and organizational security measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Data-at-rest encryption for all stored Personal Data and financial records.
• Role-based access controls ensuring that only authorized personnel with a specific operational need may access Player data.
• Regular penetration testing and security audits conducted by independent third-party security professionals.
• Two-factor authentication (2FA) available and strongly recommended for all Player accounts.
• Automated anomaly detection systems that flag and investigate unusual login patterns, withdrawal requests, or transaction volumes in real time.

In the event of a data breach that poses a material risk to your rights and freedoms, lisa22 will notify affected Players without undue delay and will take immediate remediation action. We will also notify the relevant regulatory authority where required by applicable law.

12 Minors & Age Restriction

The lisa22 Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect Personal Data from individuals under the age of 21. Age verification is a mandatory step in the KYC process, and any account found to belong to an underage individual will be immediately closed and all associated data deleted in accordance with our data retention obligations.

If you believe that a minor has accessed the Platform or submitted Personal Data without appropriate authorization, please notify us immediately at [email protected] so we can take prompt action to remove the data and close the account.

13 Third-Party Links & Services

The lisa22 Platform may display content or reference services provided by third parties — including game studios, payment partners, and sports data providers. These third-party services operate under their own privacy policies, and lisa22 accepts no responsibility or liability for the data practices of any third party. We encourage you to review the privacy policy of any third-party service before interacting with it.

lisa22 does not embed social media plugins, advertising networks, or cross-site tracking pixels from third-party platforms on any page of the Platform.

14 Policy Amendments

lisa22 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or licensing requirements. When material changes are made, registered Players will be notified via the email address associated with their Account no less than seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not agree with any change, you must stop using the Platform and contact us to arrange account closure and a data erasure request if applicable.

15 Contact & Complaints

If you have any questions, concerns, or formal complaints regarding this Privacy Policy or the way in which lisa22 handles your Personal Data, please contact our Data Protection team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: DATA PRIVACY REQUEST
• Live Chat: Available 24/7 via the platform homepage.
• WhatsApp: Contact details provided upon account registration.
• Response Time: Within 14 business days for formal written requests; within 2 hours for general support queries via live chat.

Our support team includes native Indonesian-speaking agents available around the clock, covering all major Indonesian public holidays including Idul Fitri, Idul Adha, Indonesian Independence Day (17 August), Nyepi, and others. Queries submitted in English or Bahasa Indonesia will both be handled promptly.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection authority in your jurisdiction.