Privacy Policy

1. Data Controller

The data controller responsible for your personal information is qqnisa, operating under an international gaming licence. For the purposes of data protection law, qqnisa is the entity that determines how and why your personal data is processed. Our contact details for privacy-related inquiries are provided at the end of this policy.

2. What Data We Collect

2.1 Personal Identification Information

When you register an account with qqnisa, we collect personal identification information including:

• Full Name: Your legal name as it appears on your government-issued identification document (Indonesian KTP / Kartu Tanda Penduduk).
• Date of Birth: To verify that you meet the minimum age requirement of 21 years.
• Gender: Optional field for demographic analysis and responsible gaming monitoring.
• Residential Address: Your current physical address in Indonesia (street, city, province, postal code).
• Email Address: Used for account verification, communication, and password recovery.
• Mobile Phone Number: Optional field for SMS notifications and two-factor authentication (2FA).
• National ID Number: Your Indonesian KTP number, required for Know Your Customer (KYC) verification and anti-money laundering (AML) compliance.

2.2 Financial Information

To process deposits and withdrawals, we collect financial information including:

• Bank Account Details: Bank name (BCA, BRI, BNI, Mandiri, etc.), account number, and account holder name (which must match your registered name).
• E-Wallet Information: E-wallet provider (OVO, DANA, GoPay, ShopeePay, LinkAja) and registered account number or phone number.
• Transaction History: Records of all deposits, withdrawals, bets placed, winnings, bonuses claimed, and account balance changes.
• Payment Verification: For large transactions or suspicious activity, we may request additional proof of payment method ownership, such as a bank statement or e-wallet screenshot showing your name and account number.

2.3 Identity Verification Documents

As part of our mandatory KYC (Know Your Customer) verification process, we collect copies of official documents including:

• Government-Issued Photo ID: Clear scans or photographs of your Indonesian national identity card (KTP), showing both front and back sides.
• Proof of Address: Recent utility bills, bank statements, or government documents dated within the last three months that confirm your residential address.
• Selfie Verification: A photograph of you holding your KTP next to your face, used to confirm that the person registering the account is the legitimate owner of the identity document.

2.4 Technical & Usage Data

When you use the qqnisa platform, we automatically collect technical and usage data including:

• IP Address: Your device's Internet Protocol (IP) address, which provides general geographic location (city level) and helps detect account sharing or fraudulent access.
• Device Information: Device type (desktop, mobile, tablet), operating system (Windows, Android, iOS), browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, time spent on each page, click patterns, login/logout times, session duration, and navigation paths through the website.
• Gameplay Data: Betting patterns, game preferences, wagering history, win/loss records, bonus usage, and responsible gaming tool activations (deposit limits, self-exclusion).
• Communication Records: Transcripts of live chat conversations with customer support, email correspondence, and any feedback or complaints submitted through our support channels.

3. How We Collect Your Data

3.1 Information You Provide Directly

Most personal data is collected directly from you when you:

• Register an account on the qqnisa platform
• Complete the KYC verification process by uploading identity documents
• Make a deposit or request a withdrawal
• Update your account settings or profile information
• Contact customer support via live chat, email, or phone
• Subscribe to promotional emails or SMS notifications
• Participate in surveys, promotions, or tournaments

3.2 Information Collected Automatically

Technical and usage data is collected automatically through:

• Cookies: Small text files stored on your device that track your preferences, session state, and browsing behavior (see Section 8 for detailed cookie information).
• Web Beacons: Invisible tracking pixels embedded in emails and web pages that track whether you have opened an email or viewed a specific page.
• Server Logs: Our web servers automatically log IP addresses, browser types, access times, and pages viewed for every request made to our platform.
• Analytics Tools: We use analytics services to track user behavior, measure marketing campaign effectiveness, and identify areas for platform improvement.

3.3 Information from Third Parties

In limited circumstances, we may receive information about you from third-party sources including:

• Payment Processors: Confirmation of transaction status, account ownership verification, and fraud detection flags from our payment gateway partners.
• Fraud Prevention Services: Shared databases of known fraudulent accounts, stolen payment methods, and blacklisted IP addresses used by multiple gaming platforms to prevent abuse.
• Affiliate Partners: If you registered through an affiliate link, the affiliate may provide us with a referral code or tracking ID to attribute your registration to their marketing efforts.

4. How We Use Your Data

qqnisa processes your personal data for the following purposes, each with a specific legal basis under data protection law:

5. Data Sharing & Third Parties

5.1 When We Share Your Data

qqnisa does not sell, rent, or trade your personal data to third parties for marketing purposes. However, we do share your data with trusted third-party service providers in the following circumstances:

5.1.1 Payment Processors

We share your financial information (bank account details, e-wallet information) with our payment gateway partners to process deposits and withdrawals. These processors operate under strict confidentiality agreements and are only permitted to use your data for payment processing purposes.

5.1.2 Identity Verification Services

Your identity documents (KTP, selfie verification, proof of address) may be shared with third-party KYC verification providers who perform automated identity checks, document authenticity verification, and age validation on our behalf.

5.1.3 Fraud Prevention & Security

We share certain account data (IP addresses, device fingerprints, transaction patterns) with fraud detection services and shared industry databases to identify and prevent fraudulent activity, multi-accounting, and bonus abuse.

5.1.4 Game Providers

When you play games from third-party providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, etc.), your gameplay data (bets, wins, game rounds) is shared with those providers to deliver the gaming experience and maintain game session state.

5.1.5 Analytics & Marketing Tools

We use third-party analytics services (Google Analytics, Mixpanel, etc.) to track website usage and marketing campaign performance. These services receive anonymized or pseudonymized data including IP addresses, device types, and page views.

5.1.6 Customer Support Tools

Live chat conversations and support tickets may be processed through third-party customer support platforms (Zendesk, Intercom, LiveChat, etc.) that host conversation transcripts and customer inquiry records.

5.2 Legal Disclosures

We may disclose your personal data if required by law, court order, or government regulation, including:

• Responding to subpoenas, search warrants, or legal requests from law enforcement agencies
• Complying with tax reporting obligations or anti-money laundering investigations
• Cooperating with gaming regulators or licensing authorities conducting audits or investigations
• Protecting qqnisa's legal rights in disputes, litigation, or arbitration proceedings

6. Data Retention & Storage

6.1 How Long We Keep Your Data

qqnisa retains your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. Specific retention periods include:

• Account Data: Retained for the duration of your active account, plus 7 years after account closure to comply with financial record-keeping and anti-money laundering regulations.
• Identity Documents: Retained for 7 years after account closure, as required by KYC/AML laws.
• Transaction Records: Retained for 7 years after the transaction date, as required by financial and tax regulations.
• Gameplay Records: Retained for 5 years after the gaming session, for dispute resolution and game integrity audits.
• Marketing Communications: If you opt out of marketing emails, your email address is retained on our suppression list indefinitely to ensure we do not accidentally re-subscribe you.
• Chat Transcripts: Retained for 3 years after the conversation date, for quality assurance and training purposes.

6.2 Data Storage Location

Your personal data is stored on secure servers located in data centers operated by reputable hosting providers in jurisdictions with strong data protection laws. Data may be stored in multiple geographic locations for redundancy, backup, and disaster recovery purposes. All data storage locations meet international security standards including ISO 27001 certification.

7. Data Security Measures

qqnisa implements comprehensive technical and organizational security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction:

7.1 Encryption

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using 256-bit Secure Socket Layer (SSL) technology, the same standard used by major financial institutions worldwide.
• Database Encryption: Sensitive data stored in our databases (passwords, financial information, identity documents) is encrypted at rest using AES-256 encryption.

7.2 Access Controls

• Role-Based Access: Only authorized qqnisa employees with a legitimate business need can access personal data, and access is limited based on job role (e.g., customer support agents cannot access financial data; finance team cannot access identity documents).
• Multi-Factor Authentication: All qqnisa employees accessing sensitive systems must use two-factor authentication (2FA) to prevent unauthorized access.

7.3 Security Audits

• Regular Penetration Testing: Our platform undergoes quarterly penetration testing by independent security firms to identify and remediate vulnerabilities.
• Vulnerability Scanning: Automated security scans are conducted daily to detect known vulnerabilities, malware, or suspicious activity.

7.4 Employee Training

All qqnisa employees receive mandatory data protection training and sign confidentiality agreements. Employees are prohibited from accessing personal data for personal purposes or sharing data with unauthorized parties.

8. Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files stored on your device by your web browser when you visit a website. Cookies allow the website to remember your preferences, keep you logged in, and track your behavior across multiple visits.

8.2 Types of Cookies We Use

8.2.1 Essential Cookies

These cookies are strictly necessary for the qqnisa platform to function. They enable core features such as user authentication, session management, load balancing, and security. You cannot disable essential cookies without severely limiting your ability to use the platform.

8.2.2 Functional Cookies

These cookies remember your preferences such as language selection, preferred currency display format, and recently played games. Disabling functional cookies may reduce your user experience but will not prevent you from using the platform.

8.2.3 Analytics Cookies

These cookies collect anonymized data about how you use the qqnisa platform, including which pages you visit, how long you stay, and what links you click. This data helps us improve the website and identify technical issues. You can opt out of analytics cookies through your browser settings or by using our cookie preference center.

8.2.4 Marketing Cookies

These cookies track your activity across the qqnisa website and other sites to deliver personalized advertisements and measure marketing campaign effectiveness. You can opt out of marketing cookies through your browser settings or our cookie preference center.

8.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can configure your browser to block all cookies, accept only first-party cookies, or prompt you before accepting each cookie. However, blocking essential cookies will prevent you from using the qqnisa platform.

9. Your Privacy Rights

Under international data protection laws, you have the following rights regarding your personal data:

9.1 Right of Access

You have the right to request a copy of all personal data qqnisa holds about you. We will provide this data in a structured, commonly used, machine-readable format (typically a CSV or JSON file) within 30 days of your request.

9.2 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 (email address, phone number, residential address) directly through your account settings. For changes to your name or date of birth, contact customer support with proof of the correct information.

9.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal data in certain circumstances. However, this right is not absolute — qqnisa is legally required to retain certain data (financial transactions, identity documents) for 7 years to comply with anti-money laundering and financial record-keeping laws. After this mandatory retention period, we will delete your data upon request.

9.4 Right to Restrict Processing

You have the right to request that we stop processing your personal data for specific purposes (e.g., marketing) while still retaining the data. For example, you can opt out of promotional emails but continue using the platform.

9.5 Right to Data Portability

You have the right to receive your personal data in a portable format and request that we transmit it directly to another service provider (where technically feasible).

9.6 Right to Object

You have the right to object to data processing based on legitimate interests (e.g., analytics, marketing profiling). We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

9.7 Right to Withdraw Consent

Where processing is based on consent (e.g., marketing emails), you have the right to withdraw consent at any time by clicking the unsubscribe link in emails or adjusting your account settings.

9.8 How to Exercise Your Rights

To exercise any of the above rights, contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request". Include your account username and a description of your request. We will respond within 30 days.

10. International Data Transfers

qqnisa operates as an international platform and may transfer your personal data outside Indonesia to data centers, service providers, or payment processors located in other countries. When we transfer data internationally, we ensure adequate protection through:

• Standard Contractual Clauses: We use European Commission-approved Standard Contractual Clauses (SCCs) with all third-party processors located in jurisdictions without adequate data protection laws.
• Adequacy Decisions: Where possible, we transfer data only to countries that have been deemed by international data protection authorities to provide adequate protection (e.g., European Economic Area, UK, Switzerland, Canada).
• Binding Corporate Rules: Some of our service providers operate under Binding Corporate Rules (BCRs) approved by data protection authorities, ensuring consistent protection across their global operations.

11. Children's Privacy

qqnisa does not knowingly collect personal data from individuals under the age of 21. Our Terms & Conditions explicitly prohibit minors from creating accounts or using our services. If we discover that a user is under 21 years of age, we will immediately suspend the account, forfeit any funds, and delete all associated personal data. If you believe a minor has created an account on qqnisa, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

qqnisa reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated to registered users via email or by displaying a prominent notice on the website. The "Last Updated" date at the bottom of this page indicates when the policy was most recently revised. Continued use of the qqnisa platform after changes constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or how qqnisa processes your personal data, please contact our Data Protection Officer:

• Email: [email protected] (subject line: "Privacy Inquiry")
• Live Chat: Available 24/7 via the qqnisa website
• Mailing Address: qqnisa Data Protection Officer, International Gaming Licence Jurisdiction (full address available upon request for formal legal correspondence)

We will respond to all privacy inquiries within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the data protection authority in the jurisdiction where qqnisa's gaming licence is issued.