Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by qqrr through our website at https://qqrr.cam, mobile applications, and any related services (collectively, "Services"). This policy covers information collected directly from you, information generated through your use of our Services, and information obtained from third parties as necessary for providing our gaming platform to Indonesian players.

qqrr operates as an online gaming platform offering sports betting, live casino games, slot machines, and other gaming products to residents of Indonesia who are at least 21 years of age. As the data controller for the personal information we collect, qqrr is responsible for ensuring that your data is processed lawfully, fairly, and transparently in accordance with applicable data protection principles.

This policy should be read in conjunction with our Terms & Conditions, which govern your use of qqrr services. By using our platform, you acknowledge that you have read and understood both documents. If you do not agree with the practices described herein, you should not use our Services or provide any personal information to qqrr.

2. Information We Collect

To provide you with a secure, personalized gaming experience and comply with legal obligations, qqrr collects various types of personal information:

2.1 Registration and Account Information

When you create an account with qqrr, we collect the following mandatory information:

• Personal Identifiers: Full legal name as it appears on your Indonesian National Identity Card (KTP), date of birth, gender
• Contact Information: Email address, mobile phone number, residential address including city and postal code
• Account Credentials: Username, password (stored in encrypted format), and security questions/answers
• Preferred Language and Currency: Default settings for platform display (English) and transactions (Indonesian Rupiah/IDR)

2.2 Identity Verification (KYC) Documents

To comply with age verification, anti-money laundering (AML), and regulatory requirements, we collect and verify:

• Scanned copy or clear photograph of your valid Indonesian National Identity Card (KTP) showing your photograph, full name, date of birth, ID number, and expiry date
• Selfie photograph of you holding your KTP next to your face with both your facial features and ID card details clearly visible
• Proof of address documentation such as utility bills, bank statements, or government correspondence dated within the last three months (when required)
• Additional verification documents as may be requested in cases of suspected fraud or identity theft

2.3 Financial and Transaction Data

For processing deposits, withdrawals, and maintaining accurate financial records, we collect:

• Bank account details including bank name (BCA, BRI, BNI, Mandiri, etc.), account number, and account holder name
• E-wallet information including service provider (OVO, DANA, GoPay, ShopeePay, LinkAja) and registered phone number or account ID
• Transaction history including deposit amounts, withdrawal requests, dates, times, and processing status
• Bonus claims, wagering progress, and promotional activity records
• Payment verification documents when necessary to confirm payment method ownership

2.4 Gaming Activity and Behavioral Data

To provide personalized gaming experiences, ensure fair play, and detect suspicious activity, we automatically collect:

• Gaming history including bets placed, games played, stakes wagered, winnings, and losses across all product categories (sports betting, live casino, slots, etc.)
• Login and session information including timestamps, duration, and frequency of platform access
• Customer support interactions including chat transcripts, email correspondence, and support ticket history
• Account preferences and customization settings selected by you
• Responsible gaming tool usage including deposit limits, session time limits, and self-exclusion periods

2.5 Technical and Device Information

For security purposes, fraud prevention, and platform optimization, we automatically collect:

• IP address, geolocation data (city/region level), and timezone information to verify you are accessing from Indonesia
• Device information including device type, operating system, browser type and version, screen resolution, and unique device identifiers
• Website navigation data including pages visited, links clicked, time spent on pages, and referral sources
• Cookies and similar tracking technologies as described in Section 8 of this policy

3. How We Use Your Personal Data

qqrr processes your personal information for the following legitimate purposes:

3.1 Service Provision and Account Management

• Creating and maintaining your gaming account
• Authenticating your identity and processing login requests
• Processing deposits, withdrawals, and other financial transactions
• Providing access to gaming products including sports betting, live casino, slots, and other games
• Tracking your gaming activity, account balance, and transaction history
• Administering bonuses, promotions, and loyalty rewards

3.2 Legal and Regulatory Compliance

• Verifying you are at least 21 years of age and eligible to use our services
• Confirming your identity through Know Your Customer (KYC) procedures
• Complying with anti-money laundering (AML) and counter-terrorism financing regulations
• Preventing underage gambling and promoting responsible gaming practices
• Responding to legal requests, court orders, and regulatory inquiries
• Maintaining records as required by applicable gaming and financial regulations

3.3 Security, Fraud Prevention, and Risk Management

• Detecting and preventing fraudulent transactions, unauthorized account access, and identity theft
• Monitoring for suspicious betting patterns, bonus abuse, and terms violations
• Verifying payment method ownership to prevent third-party transactions
• Protecting against technical vulnerabilities, system exploitation, and cyberattacks
• Investigating disputes, chargebacks, and customer complaints

3.4 Customer Support and Communication

• Responding to your inquiries, support requests, and technical issues via live chat, email, and other channels
• Sending transactional notifications related to deposits, withdrawals, bonus activations, and account changes
• Providing important updates regarding service changes, policy modifications, and security alerts
• Delivering personalized customer service based on your gaming preferences and history

3.5 Marketing and Promotions (With Your Consent)

• Sending promotional offers, bonus opportunities, and special event announcements via email or SMS
• Personalizing marketing content based on your gaming preferences and activity patterns
• Conducting surveys and requesting feedback to improve our services
• Displaying targeted advertisements and promotions relevant to Indonesian players

You may opt out of marketing communications at any time by adjusting your account preferences or clicking unsubscribe links in our emails. Transactional and service-related communications cannot be opted out of as they are essential for account management.

4. Data Sharing and Third-Party Disclosure

qqrr does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality obligations:

4.1 Service Providers and Business Partners

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, etc.) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process your deposits and withdrawals
• Game Providers: Third-party software suppliers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and others to deliver gaming content
• Identity Verification Services: KYC verification partners to authenticate your identity documents and age
• Customer Support Tools: Live chat, email, and ticketing system providers to deliver customer service
• Security and Fraud Prevention: Anti-fraud systems, risk management platforms, and cybersecurity service providers
• Cloud Infrastructure: Hosting providers and data center operators where our systems and databases are maintained

4.2 Legal and Regulatory Authorities

We may disclose your personal information to law enforcement agencies, regulatory bodies, courts, or government authorities when:

• Required by applicable law, regulation, court order, or legal process
• Necessary to investigate suspected fraud, money laundering, or other illegal activities
• Responding to subpoenas, warrants, or official requests for information
• Protecting the rights, property, or safety of qqrr, our users, or the public

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity or successor organization. We will notify you via email and prominent website notice before your data is transferred and becomes subject to a different privacy policy.

4.4 Aggregated and Anonymized Data

We may share aggregated, anonymized data that does not personally identify you with third parties for analytics, research, and business intelligence purposes. Such data cannot be used to identify individual users.

5. Security Measures and Data Protection

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

5.1 Technical Security Controls

• Encryption: All data transmitted between your device and our servers is protected using 256-bit SSL/TLS encryption protocols
• Password Security: User passwords are hashed and salted using strong cryptographic algorithms and never stored in plain text
• Secure Storage: Personal information and financial data are stored in encrypted databases with access controls and audit logging
• Firewall Protection: Network-level firewalls and intrusion detection systems monitor and block unauthorized access attempts
• Regular Security Audits: Periodic vulnerability assessments, penetration testing, and security reviews by independent experts

5.2 Access Controls and Internal Policies

• Access to personal data is restricted to authorized employees on a need-to-know basis only
• All staff members with access to personal data receive mandatory privacy and security training
• Confidentiality agreements and data protection obligations are included in employment contracts
• Multi-factor authentication is required for employees accessing sensitive systems

5.3 Third-Party Security

All third-party service providers with access to your personal information are contractually obligated to implement appropriate security measures and use your data only for specified purposes. We conduct due diligence assessments before engaging vendors and monitor their compliance with security standards.

5.4 Data Breach Response

In the unlikely event of a data breach that compromises your personal information, qqrr will notify affected users within 72 hours of discovering the incident. Notifications will include details of the breach, data affected, and steps being taken to mitigate harm. We will also report significant breaches to relevant authorities as required by law.

6. Data Retention and Deletion

qqrr retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal, regulatory, and business requirements:

6.1 Active Account Data

While your account remains active, we retain all personal information, transaction history, and gaming records to provide ongoing services, comply with regulatory obligations, and support customer service needs.

6.2 Closed Account Data

After you close your account (voluntarily or through termination by qqrr), we will retain certain personal information for the following periods:

• Financial Records: 7 years from the date of last transaction for tax, accounting, and anti-money laundering compliance
• Identity Verification Documents: 5 years after account closure for regulatory compliance and dispute resolution
• Gaming History and Transactions: 5 years to support potential disputes, chargebacks, or legal claims
• Support Communications: 3 years for quality assurance and training purposes
• Marketing Preferences: Until you request deletion or withdraw consent, whichever comes first

6.3 Legal Hold Exceptions

If your data is subject to a legal hold (due to litigation, investigation, or regulatory inquiry), we will retain relevant information until the hold is lifted, even if it exceeds standard retention periods.

6.4 Secure Deletion

Once the retention period expires and no legal obligations require continued storage, we will securely delete or anonymize your personal information using industry-standard data destruction methods to prevent recovery or reconstruction.

7. Your Privacy Rights

As a qqrr user, you have the following rights regarding your personal information:

7.1 Right of Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of your personal information held by qqrr. You can access most of your data directly through your account dashboard. For comprehensive data export, please contact our customer support team.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most account details (email, phone number, address) directly in your account settings. For changes to legal name or date of birth, please contact customer support with supporting documentation.

7.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal information if processing is no longer necessary, you withdraw consent, or you object to processing. However, this right is subject to legal limitations. We may be required to retain certain data for regulatory compliance, fraud prevention, or legal defense purposes even after your request.

7.4 Right to Restrict Processing

You may request that we limit how we use your personal data in certain circumstances, such as while we verify data accuracy or assess whether you have legitimate grounds to object to processing.

7.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, machine-readable format and to transmit it to another service provider where technically feasible.

7.6 Right to Object

You may object to processing of your personal data for direct marketing purposes at any time. You can opt out of marketing communications through your account settings or by clicking unsubscribe links in our emails.

7.7 Right to Withdraw Consent

Where we process your data based on consent (such as for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

7.8 Exercising Your Rights

To exercise any of these rights, please contact us at [email protected] with your request. We will respond within 30 days and may require identity verification to protect your privacy. There is no fee for exercising these rights unless your request is manifestly unfounded or excessive.

8. Cookies and Tracking Technologies

qqrr uses cookies and similar tracking technologies to enhance your gaming 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 our website. They help us recognize your device, remember your preferences, and analyze how you use our platform.

8.2 Types of Cookies We Use

8.3 Managing Cookie Preferences

You can manage cookie settings through your browser preferences to block or delete cookies. However, disabling essential cookies may prevent you from accessing certain features of our platform. Most browsers allow you to refuse third-party cookies while still accepting first-party cookies from qqrr.

9. International Data Transfers

qqrr primarily operates within Indonesia and stores your data on servers located within Indonesian territory. However, some of our service providers and technology partners may be located in other countries. When we transfer your personal information internationally, we ensure adequate safeguards are in place:

• Data Processing Agreements with contractual clauses ensuring equivalent data protection standards
• Verification that recipient countries provide adequate data protection levels
• Technical measures such as encryption to protect data in transit
• Limited transfers only to trusted partners with demonstrated security capabilities

You have the right to obtain information about the safeguards we use for international transfers by contacting us at [email protected].

10. Changes to This Privacy Policy

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

• Email notification to your registered email address
• Prominent notice on our website homepage
• In-account notification upon your next login

We encourage you to review this Privacy Policy periodically. The "Effective Date" at the top of this document indicates when it was last updated. Your continued use of qqrr services after policy changes constitutes acceptance of the modified terms.

11. Contact Information and Data Protection Officer

If you have questions, concerns, or complaints regarding this Privacy Policy or our data handling practices, please contact us through the following channels:

Thank you for trusting qqrr with your personal information. We are committed to maintaining the highest standards of data protection and transparency in our privacy practices.