Privacy Policy

1 Introduction

This Privacy Policy governs the collection, use, storage, and protection of personal data by qq221, operating at https://qq221.cam (the "Platform"). By registering an account or using any service offered by qq221, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. This document forms an integral part of the qq221 Terms and Conditions and should be read in conjunction with them.

qq221 is committed to transparency and compliance with international data protection principles. We recognize that your personal data is valuable and sensitive, and we take our responsibility to protect it seriously. This Privacy Policy sets out what data we collect, why we collect it, how we use it, who we share it with, how we protect it, and what rights you have in relation to it.

If you do not agree with any part of this Privacy Policy, you must not register an account or use the Platform. Continued use of the Platform after any changes to this Privacy Policy constitutes acceptance of those changes.

2 Data Controller

For the purposes of applicable data protection law, the data controller responsible for your personal data is:

qq221
Registered address: [International Gaming License Jurisdiction]
Email: [email protected] (plain text — not a clickable link)
Data Protection Officer: [email protected] (plain text — not a clickable link)

All inquiries, complaints, or requests related to data protection and privacy should be directed to the above contact email addresses. We aim to respond to all privacy-related queries within seven (7) business days.

3 Data We Collect

qq221 collects personal data in several ways during your interaction with the Platform. The categories of data we collect include:

3.1 Registration Data

When you create a qq221 account, we collect the following information:

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify you are at least 21 years of age)
• Email address
• Mobile phone number (registered in Indonesia)
• Residential address in Indonesia
• Preferred username and password (password is stored in hashed form and is not accessible to qq221 staff)

3.2 Identity Verification (KYC) Data

To comply with regulatory requirements and prevent fraud, we collect identity verification documents including:

• Scanned or photographed copy of government-issued identification (KTP, passport, or SIM)
• Proof of address (utility bill, bank statement, or government correspondence issued within the last three months)
• Proof of payment method ownership (e.g., bank account statement or e-wallet screenshot showing your name)

3.3 Financial and Transaction Data

When you deposit, withdraw, or place bets on the Platform, we collect:

• Bank account details or e-wallet account identifiers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay)
• Transaction history: deposit amounts, withdrawal amounts, timestamps, and transaction status
• Betting history: game type (sports betting, live casino, slots, togel), bet amounts, outcomes, and winnings
• Bonus claim and wagering progress

3.4 Technical and Usage Data

We automatically collect certain technical information when you access the Platform:

• IP address and approximate geolocation (city/region level)
• Device type, operating system, browser type and version
• Pages visited, time spent on each page, clickstream data
• Referring URL and search terms used to find qq221
• Session logs and error reports for troubleshooting purposes

3.5 Communications Data

If you contact our customer support team via live chat, email, or WhatsApp, we retain records of those communications including:

• Content of messages exchanged
• Date, time, and channel of communication
• Support ticket ID and resolution status

4 How We Use Your Data

qq221 processes your personal data for the following purposes, each supported by a lawful basis under applicable data protection law:

We do not use your personal data for purposes beyond those listed above without obtaining your explicit consent. You have the right to withdraw consent at any time for processing activities based on consent (e.g., marketing communications).

5 Data Sharing

qq221 does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your data with the following categories of recipients in limited circumstances:

5.1 Payment Processors

We share transaction details with authorized payment service providers (banks and e-wallet operators such as BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and ShopeePay) to process deposits and withdrawals. These providers operate under their own privacy policies and are contractually obligated to protect your data.

5.2 Game Providers

When you play games from third-party providers (e.g., Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe), we share limited session data (bet amounts, game ID, timestamps) necessary to operate the game. Game providers do not receive your full name, address, or payment details unless required by their licensing jurisdiction.

5.3 KYC and Compliance Partners

We engage third-party identity verification services to validate government-issued documents and screen accounts against sanctions lists and politically exposed persons (PEP) databases. These services process your KYC documents under strict confidentiality agreements.

5.4 Law Enforcement and Regulators

qq221 may disclose personal data to law enforcement authorities, regulatory bodies, or courts if required by law, court order, or if we believe in good faith that such disclosure is necessary to: (a) comply with legal obligations, (b) protect the rights or safety of qq221, its Members, or the public, or (c) investigate suspected fraud or illegal activity.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of qq221's assets, your personal data may be transferred to the acquiring entity. You will be notified via email and/or a prominent notice on the Platform of any such change in ownership or control of your personal data.

6 Data Storage & Security

qq221 employs industry-standard technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These measures include but are not limited to:

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL/TLS encryption. Passwords are stored using bcrypt hashing with salt.
• Access Controls: Personal data is accessible only to authorized qq221 personnel who require it to perform their job functions. All staff members are bound by confidentiality agreements.
• Secure Servers: Data is stored on encrypted servers located in secure data centers with physical access controls, fire suppression systems, and 24/7 monitoring.
• Regular Audits: We conduct annual security audits and penetration testing to identify and remediate vulnerabilities.
• Incident Response: In the event of a data breach, qq221 has an incident response plan in place and will notify affected Members within 72 hours of discovering the breach, in accordance with applicable law.

Despite these measures, no method of electronic storage or transmission over the internet is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. Members are encouraged to use strong, unique passwords and enable two-factor authentication where available.

7 Retention Period

qq221 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specific retention periods are as follows:

• Account Data: Retained for the duration of your active membership and for seven (7) years after account closure to comply with AML and financial record-keeping regulations.
• Transaction History: Retained for seven (7) years from the date of transaction for tax, audit, and dispute resolution purposes.
• KYC Documents: Retained for seven (7) years after account closure or the last transaction, whichever is later, to meet regulatory obligations.
• Communications Logs: Retained for three (3) years to support customer service quality assurance and dispute resolution.
• Marketing Consent Records: Retained for the duration of consent and for one (1) year after withdrawal of consent to demonstrate compliance.

After the applicable retention period expires, personal data is securely deleted or anonymized such that it can no longer be associated with an identifiable individual.

8 Your Rights

Under applicable data protection law, you have the following rights in relation to your personal data held by qq221:

• Right of Access: You may request a copy of the personal data we hold about you. We will provide this information free of charge within 30 days of a valid request.
• Right to Rectification: If any of your personal data is inaccurate or incomplete, you have the right to request correction. You can update most information directly from your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data, subject to certain exceptions (e.g., ongoing legal obligations, unresolved disputes, or compliance with AML record-keeping requirements).
• Right to Restriction of Processing: You may request that we temporarily restrict processing of your data while we investigate a dispute or verify the accuracy of data.
• Right to Data Portability: Where technically feasible, you may request a machine-readable export of your personal data for transfer to another service provider.
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interest, in which case we will cease processing unless we can demonstrate compelling legitimate grounds.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing emails), you may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] (plain text — not a clickable link). We may request additional information to verify your identity before processing your request. There is no fee for exercising your rights unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee.

9 Cookies & Tracking Technologies

qq221 uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze Platform usage.

9.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly, including session management and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language, currency display format, and account settings.
• Analytics Cookies: Collect aggregated data on how users interact with the Platform (e.g., pages visited, time on site) to help us improve user experience. We use first-party analytics tools and do not share this data with external advertisers.
• Marketing Cookies: Track your activity across sessions to deliver personalized bonus offers and promotions. These require your consent and can be disabled via browser settings.

9.2 Managing Cookies

You can control and delete cookies through your browser settings. Please note that disabling essential or functional cookies may impair Platform functionality. Most browsers allow you to block third-party cookies while still accepting first-party cookies. For detailed instructions, consult your browser's help documentation.

10 Children's Privacy

qq221 does not knowingly collect or solicit personal data from individuals under the age of 21. Access to the Platform is strictly prohibited for persons under 21 years of age. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data from our systems and permanently close any associated account.

Parents or legal guardians who believe their child has provided personal data to qq221 should contact us immediately at [email protected] (plain text — not a clickable link).

11 Policy Updates

qq221 reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. The "Effective Date" at the top of this document indicates when the policy was last revised.

Material changes to this Privacy Policy will be communicated to all registered Members via email and/or a prominent notice on the Platform at least fourteen (14) days before the new policy takes effect. Non-material changes (such as clarifications or formatting updates) may take effect immediately upon posting. Continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acceptance of the changes.

12 Contact

If you have any questions, concerns, or complaints regarding this Privacy Policy or how qq221 handles your personal data, please contact us through the following channels:

• Data Protection Officer: [email protected] (plain text — not a clickable link)
• General Support: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly from the Platform

We aim to respond to all privacy-related inquiries within seven (7) business days (WIB). If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.