Privacy Policy

1. Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Platform" means the vip122 website at https://vip122.asia and all associated mobile-optimized pages and services.
• "Personal Data" means any information that identifies or can reasonably identify a living individual, including name, email address, phone number, date of birth, financial account details, and IP address.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means vip122, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of vip122 under a written data processing agreement.
• "User", "You", or "Member" means any individual who registers an account or otherwise accesses the Platform.
• "Cookies" means small text files stored on your device by your web browser when you visit the Platform.

2. Scope and Application

This Privacy Policy applies to all Personal Data collected and processed by vip122 in connection with your use of the Platform. It covers data collected directly from you (e.g., during registration), data generated by your use of our services (e.g., betting history, login records), and data received from third-party sources (e.g., payment processors and identity verification services).

This policy is intended primarily for residents of Indonesia who use vip122 as their online betting platform. By creating an account and using our services, you confirm that you are at least 21 years of age and that you consent to the collection and processing of your Personal Data as described in this policy.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register an account, verify your identity, contact customer support, or participate in promotions, you may provide us with the following categories of Personal Data:

• Identity Data: Full legal name, date of birth, nationality, government-issued ID number (e-KTP, passport, driver's license).
• Contact Data: Email address, mobile phone number, residential address (including city, province, and postal code).
• Financial Data: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history, deposit and withdrawal records.
• Verification Data: Copies of government-issued photo ID, proof-of-address documents, selfie photographs submitted for KYC (Know Your Customer) verification.
• Communications Data: Records of your interactions with our customer support team, including live chat transcripts, email correspondence, and support ticket history.

3.2 Data Collected Automatically

When you access and use the Platform, we automatically collect certain technical and behavioral data:

• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, time spent on each page, links clicked, search queries, game sessions played, bets placed, and features used.
• Log Data: Access logs, error logs, and security event logs.
• Cookie and Tracking Data: Session cookies, persistent cookies, and similar tracking technologies as described in Section 8 of this policy.

3.3 Data from Third Parties

We may receive Personal Data about you from third-party sources, including:

• Payment Processors: Transaction confirmation data and fraud signals from banks and e-wallet providers.
• Identity Verification Services: Results and scores from third-party KYC and AML screening services.
• Publicly Available Sources: Sanctions lists, politically exposed persons (PEP) databases, and public records used for regulatory compliance.

4. How We Use Your Personal Data

vip122 processes your Personal Data only for specific, legitimate purposes. The table below summarizes the primary purposes for which we use your data and the legal basis for each:

We do not use your Personal Data for automated decision-making that produces significant legal effects without human oversight, except where required by law (e.g., automated fraud detection that may temporarily restrict account access pending human review).

5. Data Sharing and Disclosure

5.1 Service Providers

We share Personal Data with carefully selected third-party service providers who assist us in operating the Platform. These include payment processing companies (banks and e-wallet operators), KYC and identity verification services, cloud hosting and infrastructure providers, customer support platform vendors, and game software providers (Pragmatic Play, Evolution Gaming, Microgaming, and others). All service providers are bound by data processing agreements that require them to process Personal Data only as instructed by vip122 and to maintain appropriate security standards.

5.2 Regulatory and Legal Requirements

We may disclose your Personal Data to regulatory authorities, law enforcement agencies, or courts when required to do so by applicable law, court order, or legal process. This includes disclosure to anti-money-laundering (AML) authorities and financial intelligence units where required under international gaming regulations.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of vip122's business, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will notify you in advance of any such transfer and explain how your data will be handled going forward.

5.4 No Sale of Personal Data

vip122 does not sell, rent, lease, or trade your Personal Data to third-party advertisers, data brokers, or marketing companies under any circumstances. Your personal information is never monetized.

6. Data Retention

We retain your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected. The specific retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by AML regulations.
• Transaction and financial data: Retained for a minimum of five (5) years to comply with financial record-keeping requirements.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Technical and usage data: Retained for up to twelve (12) months, after which it is anonymized or deleted.
• Cookie data: Session cookies expire when you close your browser. Persistent cookies expire as defined in Section 8.

Where retention beyond these periods is required by specific regulatory requirements applicable to vip122's operating jurisdiction, we will retain the data for the legally mandated period and then delete it securely.

7. Data Security

vip122 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• AES-256 encryption for Personal Data stored in our databases.
• Two-factor authentication (2FA) options for account access.
• Role-based access control limiting employee access to Personal Data on a strict need-to-know basis.
• Regular security audits and penetration testing conducted by independent cybersecurity firms.
• 24/7 intrusion detection and monitoring systems.
• Secure data disposal procedures for physical and digital media containing Personal Data.

Despite these measures, no data transmission over the internet can be guaranteed to be 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

8. Cookies and Tracking Technologies

8.1 What We Use Cookies For

vip122 uses cookies and similar technologies (including local storage and session storage) to operate and improve the Platform. Specifically, we use cookies to:

• Keep you logged in during your session (session cookies).
• Remember your language and display preferences.
• Analyze how you use the Platform (analytics cookies).
• Detect and prevent fraud and suspicious activity (security cookies).
• Deliver relevant promotional content based on your Platform activity (marketing cookies, subject to your consent).

8.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Please note that disabling certain cookies may affect the functionality of the Platform — for example, you may be unable to remain logged in or access certain features. For detailed guidance on managing cookies, refer to your browser's help documentation.

9. Your Data Protection Rights

As a vip122 member and a data subject, you have the following rights regarding your Personal Data:

• 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 that we correct any inaccurate or incomplete Personal Data.
• Right to Erasure: You may request deletion of your Personal Data where we no longer have a legitimate reason to retain it, subject to legal retention obligations.
• Right to Restriction of Processing: You may request that we restrict the processing of your Personal Data in certain circumstances (e.g., while you contest the accuracy of the data).
• Right to Data Portability: You may request a copy of your Personal Data in a structured, machine-readable format for transfer to another service provider.
• Right to Object: You may object to the processing of your Personal Data for direct marketing purposes or where we rely on legitimate interests as the legal basis for processing.
• Right to Withdraw Consent: Where we process your data based on your consent (e.g., for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact our Data Protection team at [email protected]. We will respond to all valid requests within 30 days. In some cases, we may need to verify your identity before processing a data rights request.

10. Third-Party Services and Links

The Platform integrates with third-party services, including payment gateways, game software providers, and analytics tools. These third parties operate under their own privacy policies, which we encourage you to review. vip122 is not responsible for the privacy practices of any third-party service and has no control over how those services collect or use your data. Any data you provide directly to a third-party service (e.g., entering payment details on a bank's website) is governed solely by that third party's privacy policy.

11. Minors and Age Restriction

vip122 does not knowingly collect, store, or process Personal Data from individuals under the age of 21. Our services are strictly for adults aged 21 and over. If we become aware that a minor has registered an account or provided Personal Data without parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe a minor has accessed our Platform, please contact us immediately at [email protected].

12. International Data Transfers

vip122 operates globally and may transfer your Personal Data to servers and service providers located outside of 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 data protection laws. These safeguards may include contractual clauses, data processing agreements, or reliance on the recipient country's adequacy determinations. By using the Platform, you acknowledge and consent to such international transfers of your Personal Data.

13. Marketing Communications

With your consent, vip122 may send you promotional communications by email or SMS regarding new games, bonuses, seasonal promotions (such as those tied to Idul Fitri, Ramadhan, or Indonesian Independence Day on 17 August), and platform updates. You may opt out of marketing communications at any time by contacting our customer support team or by following the unsubscribe instructions included in any marketing email. Opting out of marketing communications will not affect transactional messages related to your account, such as deposit confirmations, withdrawal notifications, and security alerts.

14. Changes to This Privacy Policy

vip122 reserves the right to update or revise this Privacy Policy at any time. When we make material changes, we will post the updated policy on this page with a new effective date and, where appropriate, notify you by email or through a notice on the Platform. We encourage you to review this page periodically to stay informed about how we protect your Personal Data. Your continued use of the Platform after any changes are posted constitutes your acceptance of the updated Privacy Policy.

15. Governing Law

This Privacy Policy is governed by the laws of the jurisdiction in which vip122 holds its operating license. Any disputes arising from or relating to this Privacy Policy shall be resolved in accordance with the dispute resolution procedures set out in our Terms & Conditions. Where Indonesian data protection laws are applicable to your use of the Platform, we commit to processing your Personal Data in a manner consistent with those requirements.

16. Contact and Data Protection Inquiries

If you have any questions, concerns, or complaints about this Privacy Policy or the way vip122 handles your Personal Data, please contact our Data Protection team using the details below. We are committed to resolving all privacy inquiries promptly and transparently.

• Email: [email protected]
• Live Chat: Available 24/7 directly on the Platform
• Response Time: We aim to respond to all data protection inquiries within 30 calendar days.

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

By registering an account and using vip122, you confirm that you have read, understood, and agreed to this Privacy Policy in full. If you do not agree with any part of this policy, please discontinue use of the Platform and contact our support team to request account closure.