rubyqq Privacy Policy

1. Introduction

At rubyqq, we understand that trust is the foundation of any successful gaming platform. We are committed to safeguarding your personal data and ensuring that your privacy is protected at every stage of your interaction with our Platform. This Privacy Policy is designed to provide you with complete transparency regarding our data handling practices.

We comply with international data protection principles and best practices, including those outlined in widely recognized frameworks such as the General Data Protection Regulation (GDPR) and applicable Indonesian privacy regulations. While online gaming operates in a complex legal landscape in Indonesia, we apply these global standards to protect all our users regardless of jurisdiction.

This Policy covers all aspects of personal data processing carried out by rubyqq, including data collected during account registration, gameplay, financial transactions, customer support interactions, and marketing communications. We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

2. Data Controller

For the purposes of applicable data protection laws, rubyqq acts as the "data controller" with respect to the personal information collected through the Platform. This means we determine the purposes and means of processing your personal data and bear responsibility for its lawful and secure handling.

As data controller, we implement appropriate technical and organizational measures to ensure that your data is processed in accordance with this Policy and applicable legal requirements. Where we engage third-party service providers to process data on our behalf (such as payment processors or game providers), we ensure they act strictly as "data processors" under contractual obligations that mandate compliance with our privacy standards.

You may contact our Data Protection Officer or customer support team at any time with questions or concerns regarding how your personal data is processed. Contact details are provided in Section 14 of this Policy.

3. Information We Collect

We collect several categories of personal information necessary to provide you with a secure, personalized, and compliant gaming experience. The specific data we collect depends on how you interact with the Platform.

3.1 Information You Provide Directly

When you register an account or use certain features of the Platform, you voluntarily provide us with personal information including:

• Registration Data: Full legal name, date of birth, email address, mobile phone number, username, password, and preferred language
• Identity Verification (KYC) Data: Government-issued identity documents (Indonesian National Identity Card / KTP, passport, driver's license), proof of address, facial photographs, and other documents required for age verification and anti-money laundering compliance
• Financial Data: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata), e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history, deposit and withdrawal records
• Communication Data: Content of messages sent to customer support via live chat or email, survey responses, feedback forms, and any other voluntary communications
• Preference Data: Game preferences, notification settings, responsible gaming limits (deposit limits, loss limits, session time limits), self-exclusion preferences

3.2 Information Collected Automatically

When you access or use the Platform, we automatically collect certain technical and usage information:

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, device identifiers
• Usage Data: Pages visited, games played, time spent on each section, clickstream data, referral sources, session duration, login times, bet history, game outcomes
• Location Data: Approximate geographic location derived from IP address (city/region level, not precise GPS coordinates), time zone (WIB, WITA, or WIT)
• Cookies and Similar Technologies: See Section 9 for detailed information on cookies and tracking technologies

3.3 Information from Third Parties

We may receive limited information about you from third-party service providers, including:

• Payment Processors: Transaction confirmation, payment method verification, fraud detection signals
• Game Providers: Game session data, RTP outcomes, bonus utilization statistics (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft, Ezugi, and others)
• Identity Verification Services: Confirmation of document authenticity, age verification results, sanctions screening results

4. How We Use Your Data

We process your personal data for specific, explicit, and legitimate purposes only. We do not use your data in ways that would be unexpected or incompatible with the purposes disclosed in this Policy.

4.1 Service Provision

• Create and manage your account on the Platform
• Process deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Provide access to casino games, live dealer experiences, sports betting markets (including BRI Liga 1, Timnas Indonesia, EPL, La Liga, Champions League, mix parlay, voor bola markets), togel games, and other gaming products
• Track gameplay activity, bet history, and account balance in real time
• Award bonuses, promotions, and loyalty rewards according to published terms

4.2 Legal and Regulatory Compliance

• Verify your identity and age to ensure you are 21 years or older
• Conduct Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by our international licensing obligations
• Monitor for fraudulent activity, collusion, bonus abuse, and other prohibited conduct
• Maintain records as required by gaming regulators and applicable law
• Respond to legal requests, court orders, and regulatory inquiries

4.3 Platform Security and Integrity

• Detect and prevent fraud, hacking attempts, unauthorized access, and malicious activity
• Monitor gameplay patterns to identify potential game manipulation or exploits
• Maintain audit trails for dispute resolution and investigation purposes
• Implement and test security measures including encryption, firewalls, and intrusion detection systems

4.4 Customer Support and Communication

• Respond to your inquiries via live chat, email, or other communication channels
• Send transactional notifications regarding deposits, withdrawals, bonus awards, and account activity
• Provide technical support and troubleshooting assistance
• Send service announcements, maintenance notifications, and policy updates

4.5 Responsible Gaming

• Enforce deposit limits, loss limits, and session time limits configured by you
• Monitor gameplay patterns for indicators of problem gambling behavior
• Implement self-exclusion requests and cooling-off periods
• Provide access to responsible gaming tools and resources

4.6 Marketing and Personalization (with your consent)

• Send promotional offers, bonus announcements, and seasonal campaigns (e.g., Idul Fitri, Chinese New Year / Imlek, Indonesian Independence Day, Ramadhan promotions)
• Personalize game recommendations based on your play history and preferences
• Conduct market research and customer satisfaction surveys

You may opt out of marketing communications at any time by adjusting your account settings or clicking the unsubscribe link in promotional emails.

4.7 Platform Improvement and Analytics

• Analyze usage patterns to improve Platform performance, user experience, and game selection
• Conduct A/B testing of new features and interface designs
• Generate aggregated, anonymized statistics for business intelligence purposes

5. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We share your data only in the limited circumstances described below, and only with parties who are contractually obligated to protect your information.

5.1 Service Providers

We share necessary data with trusted third-party service providers who perform services on our behalf:

• Payment Processors: To facilitate deposits and withdrawals through Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Game Providers: To deliver gaming content from Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft, Ezugi, and other licensed studios
• Identity Verification Services: To conduct KYC checks, age verification, and document authentication
• Customer Support Tools: To operate live chat, email ticketing, and helpdesk systems
• Hosting and Infrastructure Providers: To maintain servers, databases, and content delivery networks

5.2 Legal Obligations

We may disclose your personal data where required by law, regulation, legal process, or governmental request, including:

• Compliance with court orders, subpoenas, or warrants
• Cooperation with law enforcement investigations
• Reporting to gaming regulators in our licensing jurisdiction
• Response to regulatory inquiries or audits

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the successor entity, subject to the continued application of this Privacy Policy or a substantially similar policy.

5.4 With Your Consent

We may share your data for purposes not described in this Policy where we have obtained your explicit, informed consent to do so.

6. Data Security

We implement industry-standard technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security framework includes:

6.1 Technical Safeguards

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL/TLS encryption. Sensitive data at rest (including passwords, financial information, and identity documents) is encrypted using AES-256 encryption
• Secure Infrastructure: Our servers are hosted in certified data centers with physical security controls, redundant power supplies, and disaster recovery capabilities
• Firewall Protection: Multi-layer firewalls and intrusion detection/prevention systems monitor and block unauthorized access attempts
• Access Controls: Role-based access controls ensure that only authorized personnel can access personal data, and only to the extent necessary for their job functions
• Regular Security Audits: We conduct periodic security assessments, penetration testing, and vulnerability scans performed by independent security firms

6.2 Organizational Safeguards

• Employee Training: All staff members receive regular training on data protection principles, security best practices, and our internal privacy policies
• Confidentiality Agreements: Employees and contractors with access to personal data are bound by strict confidentiality obligations
• Incident Response Plan: We maintain a documented data breach response plan to ensure rapid detection, containment, and notification in the event of a security incident
• Vendor Management: Third-party service providers are subject to due diligence reviews and must demonstrate compliance with our security standards

6.3 Your Role in Security

While we implement robust security measures, you also play a critical role in protecting your account:

• Choose a strong, unique password and do not share it with anyone
• Enable two-factor authentication if available
• Log out of your account when using shared or public devices
• Be cautious of phishing emails or messages claiming to be from rubyqq (we will never ask for your password via email)
• Report any suspicious account activity to our support team immediately

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.

7.1 Active Account Data

While your account remains active, we retain all personal data necessary to provide services, maintain security, and comply with legal obligations. This includes your registration information, transaction history, gameplay records, and communication logs.

7.2 Closed Account Data

When you close your account (either voluntarily or due to a breach of our Terms & Conditions), we retain certain data for the following periods:

• Financial Records: 7 years from the date of the last transaction (required for tax, accounting, and anti-money laundering compliance)
• Identity Verification Documents: 7 years from account closure (required for regulatory compliance and fraud prevention)
• Gameplay History: 5 years from account closure (required for dispute resolution and regulatory reporting)
• Communication Records: 3 years from account closure (required for quality assurance and dispute resolution)
• Marketing Data: Deleted immediately upon account closure or earlier if you opt out of marketing communications

7.3 Dormant Accounts

If you do not log in to your account for 12 consecutive months, your account will be classified as dormant. We may apply an inactivity fee as specified in our Terms & Conditions. After 24 months of inactivity, we may close the account and retain only the minimum data required for legal compliance.

7.4 Legal Holds

Where data is subject to a legal hold (e.g., due to ongoing litigation, regulatory investigation, or law enforcement request), we will retain the relevant data until the hold is lifted, regardless of the standard retention periods outlined above.

8. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal data. We respect these rights and will facilitate your exercise of them subject to applicable legal limitations and exceptions.

8.1 Right of Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of that data. You may also request information about the purposes of processing, categories of data, recipients, and retention periods.

8.2 Right to Rectification

If your personal data is inaccurate or incomplete, you have the right to request correction or completion. You can update most information directly through your account settings. For changes requiring verification (e.g., name, date of birth), please contact our support team.

8.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data where:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw consent (where processing was based on consent)
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed

This right is not absolute. We may retain data where required by law (e.g., financial records, KYC documents) or necessary for legal claims.

8.4 Right to Restriction of Processing

You may request that we limit the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.

8.5 Right to Data Portability

Where technically feasible, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

8.6 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 interests, subject to our demonstration of compelling legitimate grounds.

8.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

8.8 Right to Lodge a Complaint

If you believe we have processed your data unlawfully or violated your privacy rights, you have the right to lodge a complaint with a supervisory authority in your jurisdiction.

9. Cookies and Tracking Technologies

Like most online platforms, rubyqq uses cookies and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content. This section explains what cookies are, why we use them, and how you can control them.

9.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They contain information that is transferred to your device's hard drive and allow the website to recognize your device and remember certain information about your preferences or past actions.

9.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These enable core functionality such as security, authentication, and account management. You cannot opt out of these cookies.
• Performance Cookies: Collect anonymous information about how visitors use the Platform, including which pages are most popular and if users encounter errors. These help us improve Platform performance.
• Functional Cookies: Remember your preferences (e.g., language, region, game favorites) and provide enhanced, personalized features.
• Targeting/Advertising Cookies: Track your browsing activity to deliver relevant promotional offers and measure the effectiveness of marketing campaigns.

9.3 Managing Cookie Preferences

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Please note that disabling certain cookies may limit your ability to use some features of the Platform. To manage cookies:

• Visit your browser's help menu for instructions on blocking or deleting cookies
• Use browser privacy modes (e.g., Incognito, Private Browsing) for temporary cookie-free sessions
• Adjust your preferences in your account settings where cookie customization is available

9.4 Other Tracking Technologies

In addition to cookies, we may use web beacons, pixel tags, and similar technologies to track user behavior, measure email open rates, and analyze Platform usage patterns. These technologies operate similarly to cookies and are subject to the same controls.

10. Third-Party Services and Links

The rubyqq Platform integrates with various third-party services to provide you with a comprehensive gaming experience. This section explains our relationship with these services and their respective privacy practices.

10.1 Game Providers

Our casino games, live dealer experiences, and sports betting markets are powered by leading international game studios including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft, and Ezugi. When you launch a game, you may be redirected to the provider's platform, which may collect technical data about your gameplay. These providers operate under their own privacy policies, and we encourage you to review them.

10.2 Payment Service Providers

Deposits and withdrawals are processed through Indonesian financial institutions (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja). These providers may collect transaction data in accordance with their own privacy policies and Indonesian banking regulations. We do not store your full banking credentials or card numbers on our servers.

10.3 External Links

The Platform may contain links to external websites (e.g., responsible gaming resources, payment provider portals). We are not responsible for the privacy practices or content of these external sites. We recommend reviewing the privacy policy of any website you visit through a link from our Platform.

10.4 Social Media

If we integrate social media features (e.g., sharing gameplay achievements), these features may collect your IP address, which page you are visiting, and may set cookies. Social media features are governed by the privacy policies of the respective social media companies.

11. International Data Transfers

rubyqq operates an international online gaming platform licensed and regulated in a jurisdiction outside Indonesia. As a result, your personal data may be transferred to, stored at, or processed in locations outside your country of residence, including jurisdictions that may not provide the same level of data protection as Indonesian law.

11.1 Safeguards for International Transfers

When we transfer your data internationally, we implement appropriate safeguards to ensure your data remains protected, including:

• Data processing agreements incorporating standard contractual clauses approved by international data protection authorities
• Technical measures such as encryption during transmission and at rest
• Restricting access to personal data to authorized personnel only
• Regular audits of third-party service providers' data protection practices

11.2 Indonesian Player Data

We recognize the importance of protecting the personal data of Indonesian players. While our servers may be located internationally, we apply the same high standards of data protection to all users regardless of their location. Transaction data related to Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja) is processed in accordance with Indonesian banking regulations and international payment security standards.

12. Children's Privacy

The rubyqq Platform is strictly for users aged 21 and above. We do not knowingly collect, use, or disclose personal information from individuals under 21 years of age.

12.1 Age Verification

During registration, all users must confirm they are at least 21 years old. We verify age through the KYC process, which requires submission of government-issued identity documents showing the user's date of birth. Accounts found to belong to underage individuals will be immediately closed, and any balances forfeited.

12.2 Parental Notice

If you are a parent or guardian and believe your child has provided personal information to rubyqq, please contact us immediately at [email protected]. We will take prompt action to remove any such data from our systems and close any associated account.

12.3 Responsible Marketing

We do not target marketing or advertising toward individuals under 21. Our promotional materials and social media content are designed and delivered with age restrictions in place to prevent exposure to underage audiences.

13. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or industry standards. When we make material changes, we will notify you through one or more of the following methods:

• A prominent notice on the Platform homepage or login screen
• An email notification sent to the address registered on your account
• An in-Platform notification delivered upon your next login

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

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

14. Contact Us

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

• Email: [email protected] (for privacy-related inquiries, use subject line "Privacy Inquiry")
• Data Protection Officer: [email protected] (use subject line "Attention: Data Protection Officer")
• Live Chat: Available 24/7 through the Platform interface
• Response Time: We aim to respond to all privacy inquiries within 48 hours and formal rights requests within 30 days
• Operating Hours: Customer support operates 24/7, including Indonesian public holidays, in Western Indonesia Time (WIB, UTC+7)

For formal privacy rights requests (access, rectification, erasure, etc.), please include:

• Your full name and registered email address
• A clear description of your request
• Verification of your identity (for security purposes)
• Your preferred method of response