Privacy Policy

1. Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person — directly or indirectly — including name, national ID number, email address, IP address, device identifiers, financial account details, and behavioral data linked to a player profile.
• "Processing" means any operation performed on Personal Data, whether automated or not, including collection, recording, storage, retrieval, use, disclosure, combination, restriction, and deletion.
• "Data Controller" refers to qq3889, which determines the purposes and means of processing your Personal Data.
• "Data Processor" refers to a third party that processes Personal Data on behalf of qq3889 under a written data processing agreement (e.g., payment gateway providers, KYC verification services).
• "Consent" means freely given, specific, informed, and unambiguous agreement to the processing of your Personal Data for a stated purpose.
• "KYC" (Know Your Customer) refers to the identity and age verification process required to process withdrawals and comply with anti-money-laundering obligations.
• "Platform" refers to the qq3889 website at qq3889.cam, its subdomains, and any associated mobile interfaces.

2. Scope & Application

This Policy applies to all individuals who interact with the Platform, including:

• Registered members with active qq3889 Accounts.
• Individuals who visit qq3889.cam without registering.
• Individuals who communicate with qq3889 via email or support channels.
• Individuals who have submitted a registration application but have not yet completed account activation.

qq3889 primarily serves players resident in Indonesia, including those in Jakarta, Surabaya, Bandung, Medan, Semarang, Bali, Yogyakarta, Makassar, and Palembang. Where you access the Platform from outside Indonesia, you do so on your own initiative and remain responsible for compliance with any applicable local data protection laws in your jurisdiction.

This Policy does not cover data practices of third-party websites or services that may be linked from the Platform. Please review the privacy policies of any such third parties independently.

3. Personal Data We Collect

qq3889 collects the following categories of Personal Data, depending on how you interact with the Platform:

3.1 Registration & Identity Data

• Full legal name (as it appears on government-issued ID)
• Date of birth (to verify you are 21 years of age or older)
• Residential address in Indonesia
• Email address and mobile phone number
• Username and encrypted password
• National identification number (Indonesia KTP number) — collected at KYC stage

3.2 Financial & Transaction Data

• Bank account details (account name, account number, and bank name — e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon)
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Deposit and withdrawal history, including transaction amounts in Indonesian Rupiah (IDR / Rp), timestamps, and processing status
• Bonus and promotional credit history

3.3 Identity Verification (KYC) Documents

• Scanned copies or photographs of government-issued ID (Indonesia KTP, passport, or SIM)
• Proof of address documentation (utility bill, bank statement dated within 90 days)
• Source of funds documentation where required by compliance review

3.4 Usage & Behavioral Data

• Login timestamps, session durations, and IP addresses
• Device type, operating system, browser type, and version
• Pages visited, games played (including sports betting on bandar bola markets and togel lottery products), bet amounts, and game outcomes
• Responsible gaming tool usage (deposit limits set, session time controls activated)

3.5 Communications Data

• Content of emails, live chat transcripts, and support tickets sent to qq3889
• Survey responses and feedback submissions
• Records of marketing preference settings and opt-out requests

4. How We Collect Personal Data

qq3889 collects Personal Data through the following means:

• Directly from you — when you complete the registration form, submit KYC documentation, initiate a deposit or withdrawal, or contact our support team.
• Automatically — through cookies, server log files, and analytics tools that record your device information, IP address, and on-site behavior when you visit or use the Platform.
• From third-party service providers — including KYC verification partners (e.g., identity document verification services), fraud detection providers, and payment processors who share data with us as part of a transaction or identity check.
• From public sources — where permitted by law, we may cross-reference publicly available records (such as sanctions lists or politically exposed persons databases) to fulfill our anti-money-laundering obligations.

5. Legal Basis for Processing

qq3889 processes your Personal Data on one or more of the following legal bases:

Where we rely on legitimate interests as our legal basis, we have assessed that our interests do not override your fundamental rights and freedoms as a data subject. You may object to processing based on legitimate interests at any time by contacting us at the details in Section 16.

6. How We Use Your Personal Data

qq3889 uses the Personal Data we collect for the following specific purposes:

6.1 Account & Platform Operations

• Creating, maintaining, and managing your qq3889 Account.
• Authenticating your identity when you log in and detecting unauthorized access attempts.
• Processing deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Calculating and crediting bonus funds, free bets, and promotional awards in accordance with applicable promotion terms.
• Providing access to all Services on the Platform, including sports betting on BRI Liga 1, EPL, Champions League, and other markets, togel (Indonesia's traditional numbers lottery) draws, live casino, and sabung ayam (cockfighting) streams.

6.2 Legal & Compliance Obligations

• Conducting KYC verification to confirm you are at least 21 years of age and to establish your identity before processing withdrawals.
• Monitoring transactions for signs of money laundering, terrorist financing, or other financial crime, as required by our licensing obligations.
• Responding to lawful requests from regulatory authorities, law enforcement agencies, or courts of competent jurisdiction.
• Maintaining records for the minimum retention periods required by applicable law and our gaming license.

6.3 Responsible Gaming

• Monitoring gameplay patterns for indicators of problem gambling behavior, as part of our duty of care to all Players.
• Enforcing self-exclusion requests, deposit limits, loss limits, and session time controls activated by the Player.
• Contacting Players proactively where our monitoring identifies a potentially problematic gambling pattern, in line with our Responsible Gaming commitments.

6.4 Communications & Marketing

• Sending transactional notifications — deposit confirmations, withdrawal updates, security alerts, and Account status communications. These are sent regardless of marketing preferences as they are necessary for the operation of your Account.
• Sending promotional communications — bonus offers, seasonal promotions (e.g., Idul Fitri specials, Ramadhan campaigns), and product updates — only where you have provided explicit consent and have not subsequently opted out.
• Responding to support queries submitted via email or live chat, in English and Indonesian (Bahasa Indonesia).

6.5 Platform Improvement & Analytics

• Analyzing aggregated and anonymized usage data to understand how Players interact with the Platform and to improve product features, performance, and user experience.
• Conducting internal fraud analysis and security auditing using behavioral and transaction data.
• Testing and deploying new Platform features, payment methods, and game integrations.

7. Data Sharing with Third Parties

qq3889 does not sell, rent, or trade your Personal Data. We share data only in the following specific, controlled circumstances:

7.1 Service Providers & Data Processors

We engage carefully vetted third-party service providers who process Personal Data on our behalf under written data processing agreements that bind them to confidentiality and data protection standards equivalent to those in this Policy. These providers include:

• Payment processors: Banks and e-wallet platforms (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, LinkAja) process transaction data necessary to complete your deposits and withdrawals in IDR.
• KYC verification partners: Third-party identity verification services that validate government-issued ID documents and cross-reference sanctions and PEP lists.
• Game content providers: Licensed game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive anonymized session data necessary for game functionality and RTP verification; they do not receive your personally identifiable information.
• Fraud prevention and cybersecurity providers: Services that analyze login patterns, device fingerprints, and transaction anomalies to protect your Account from unauthorized access.
• Cloud infrastructure providers: Encrypted hosting and data storage infrastructure, bound by strict data processing agreements.

7.2 Regulatory & Legal Disclosure

qq3889 may disclose Personal Data to government authorities, regulators, law enforcement agencies, or courts when required to do so by applicable law, court order, or regulatory mandate. We will, where legally permitted, notify you of such disclosure unless prohibited from doing so by law.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a material part of qq3889's business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified via the email address on your Account at least 30 days before any such transfer takes effect, and your rights under this Policy will continue to apply to your data.

8. International Data Transfers

qq3889 operates infrastructure and engages service providers across multiple international jurisdictions. As a result, your Personal Data may be transferred to and stored on servers located outside Indonesia. Where such transfers occur, qq3889 ensures that appropriate safeguards are in place, including:

• Data processing agreements that incorporate standard contractual clauses providing equivalent protections to those required under applicable Indonesian data protection frameworks.
• Transfers only to jurisdictions or entities that maintain data protection standards assessed as adequate for the processing purpose.
• Technical and organizational safeguards — including end-to-end encryption in transit and AES-256 encryption at rest — that apply regardless of the physical location of the data.

By using the Platform, you acknowledge that your data may be processed in jurisdictions outside Indonesia. If you have concerns about specific cross-border data flows, please contact us using the details in Section 16.

9. Cookies & Tracking Technologies

qq3889 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies may be placed on your device:

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair or prevent your ability to use the Platform. Disabling analytics or functional cookies will not affect your ability to access your Account or place bets. qq3889 does not use third-party advertising or retargeting cookies.

10. Data Retention Periods

qq3889 retains Personal Data only for as long as necessary to fulfill the purpose for which it was collected, comply with legal and licensing obligations, resolve disputes, and enforce our agreements. The following general retention guidelines apply:

• Active Account data (registration details, transaction history, game logs): retained for the lifetime of the Account plus 5 years from the date of Account closure, in line with standard anti-money-laundering record-keeping requirements.
• KYC documents (identity documents, proof of address): retained for 5 years from the date the document was submitted or from the date of Account closure, whichever is later.
• Financial transaction records: retained for a minimum of 5 years from the date of each transaction, as required by applicable financial compliance regulations.
• Customer support communications: retained for 3 years from the date of the last communication in a given support thread.
• Marketing preference records: retained for the duration of your Account membership and for 2 years following Account closure as evidence of consent and opt-out compliance.
• Website analytics data: aggregated and anonymized after 24 months; anonymized data is not Personal Data and may be retained indefinitely.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized using approved data destruction methods.

11. Security Measures

qq3889 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, loss, alteration, or disclosure:

• Encryption in transit: All data exchanged between your browser or app and our servers is encrypted using TLS 1.2 or TLS 1.3 with 256-bit cipher suites.
• Encryption at rest: Stored Personal Data, including KYC documents and financial records, is encrypted using AES-256.
• Access controls: Access to Personal Data is restricted to qq3889 personnel and authorized Data Processors who need the data to perform their role. Access is granted on a least-privilege basis and reviewed quarterly.
• Multi-factor authentication: Administrative access to data systems requires multi-factor authentication. Players are strongly encouraged to enable two-factor authentication on their Accounts.
• Penetration testing: qq3889 conducts regular third-party penetration testing and vulnerability assessments of its Platform infrastructure.
• Incident response: We maintain a documented data breach response procedure. In the event of a breach that poses a risk to your rights, we will notify affected Players and relevant regulators within the timeframes required by applicable law.

12. Your Data Rights

As a data subject, you hold the following rights in relation to the Personal Data that qq3889 holds about you. To exercise any of these rights, contact our Data Protection team using the details in Section 16. We will respond within 30 calendar days of receiving a verifiable request.

Please note that exercising certain rights — in particular the right to erasure or restriction — may affect your ability to continue using the Platform, as some Personal Data is essential for Account operation and regulatory compliance. We will advise you of any such impact when responding to your request.

13. Minors

qq3889 enforces a strict 21+ age policy and does not knowingly collect or process Personal Data belonging to individuals under the age of 21. The Platform is not directed at minors, and we take reasonable steps — including mandatory age declaration at registration and KYC age verification — to prevent underage individuals from accessing the Services.

If we become aware that Personal Data has been collected from an individual under 21, we will immediately suspend the associated Account, delete the Personal Data in question, and return any funds in accordance with our Terms & Conditions. If you are a parent or guardian and believe that a minor in your care has registered an Account on qq3889, please contact us immediately at the address provided in Section 16.

14. Third-Party Links & Services

The Platform may contain references to third-party services, including payment providers (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja) and game studio platforms (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft). Interactions with those third parties — including any data you provide directly to them — are governed by their own privacy policies, which qq3889 has no control over.

qq3889 is not responsible for the privacy practices of any third party. We encourage you to review the privacy policy of any third-party service before providing personal information directly to them.

15. Changes to This Privacy Policy

qq3889 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform functionality. When material changes are made, we will:

• Update the "Last Updated" date and version number at the top of this page.
• Send a notification to your registered email address at least 14 days before the updated Policy takes effect, where the changes materially affect your rights or how we use your data.
• Where required by law, seek fresh consent for any new processing activities.

Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you should cease using the Platform and contact us to close your Account.

16. Contact & Data Protection Inquiries

For all privacy-related questions, requests to exercise your data rights, or concerns regarding qq3889's data practices, please contact our dedicated Data Protection team. All inquiries are handled in English and Indonesian (Bahasa Indonesia) and are treated as strictly confidential.

When submitting a data rights request, please provide your full registered name, the email address associated with your qq3889 Account, and a clear description of your request. We may need to verify your identity before actioning any request that involves access to or deletion of Personal Data, in order to prevent unauthorized disclosure.

If you are unsatisfied with how qq3889 has handled a privacy concern, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction.