Privacy Policy

1. Definitions

The following terms carry specific meanings throughout this Policy:

• "Personal Data" means any information that directly or indirectly identifies you as a natural person — for example, your full name, date of birth, email address, Indonesian national ID (KTP) number, bank account details, or IP address.
• "Processing" means any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, erasure, or destruction.
• "Controller" refers to rp444, the entity that determines the purposes and means of processing Personal Data.
• "Processor" means any third party that processes Personal Data on behalf of rp444 under a contractual arrangement (e.g., payment processors, game providers).
• "User" or "you" means any individual who accesses rp444.cam, whether registered or not.
• "Account" means the registered profile associated with your email address or mobile number on rp444.

2. Data We Collect

rp444 collects Personal Data in several ways, depending on how you interact with our Platform:

2.1 Information You Provide Directly

• Registration data: Full name, date of birth, email address, mobile number, residential address, city (e.g., Jakarta, Surabaya, Bandung, Bali, Medan), and chosen username.
• KYC documents: Scanned copies of government-issued identification such as KTP (Kartu Tanda Penduduk), driver's license (SIM), or passport, along with selfie images for identity verification.
• Payment information: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay), and transaction records. Note that we do not store full card numbers for card-based payments — these are processed by PCI-DSS-certified payment partners.
• Communications: Any messages, complaints, or support requests you send us via email or live chat.

2.2 Information Collected Automatically

• Usage data: Pages visited, games played, bets placed, session duration, click patterns, and navigation flow within rp444.cam.
• Device and technical data: IP address, browser type and version, operating system, device model, screen resolution, and referring URL.
• Location data: General geographic location derived from your IP address (city and country level). We do not collect precise GPS coordinates.
• Cookies and similar technologies: Session cookies, preference cookies, and analytics identifiers. See Section 8 for full cookie details.

2.3 Information From Third Parties

• Identity verification results from our KYC partner services.
• Fraud-screening signals from payment processors and anti-fraud networks.
• Publicly available information where necessary for responsible gaming checks.

3. How We Use Your Data

We use your Personal Data for the following purposes, each grounded in a specific legal basis:

4. Data Sharing and Disclosure

rp444 does not sell your Personal Data. We share your data with third parties only in the following circumstances:

4.1 Service Providers and Processors

We work with trusted third-party companies that process data on our behalf under strict data processing agreements:

• Payment processors: For transaction routing via Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallets (OVO, DANA, GoPay, ShopeePay).
• KYC and identity verification providers: To confirm user identities and documents.
• Game studios: Pragmatic Play, Evolution Gaming, and other certified providers may receive anonymized session data for game performance and fairness auditing.
• Analytics providers: Aggregated, anonymized usage data for platform improvement.
• Customer support tools: Support ticket systems may store support communications.

4.2 Legal and Regulatory Disclosure

We may disclose your Personal Data if required to do so by:

• Court order, subpoena, or legally binding government request.
• Anti-money-laundering (AML) or counter-terrorism financing (CTF) reporting obligations.
• Any applicable international regulatory authority overseeing gaming platforms.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business assets, your Personal Data may be transferred to the acquiring entity, who will be bound by this Policy or a substantially equivalent privacy commitment.

5. Data Retention

We retain your Personal Data only for as long as necessary to fulfill the purposes described in this Policy:

• Account data and KYC documents: Retained for the lifetime of your Account plus five (5) years after Account closure, in compliance with AML record-keeping requirements.
• Transaction records: Retained for seven (7) years as required for financial audit and AML compliance.
• Support communications: Retained for three (3) years from the date of last contact.
• Analytics data: Aggregated and anonymized within 12 months of collection; raw session logs deleted after 90 days.
• Marketing preferences: Retained until you withdraw consent, at which point we suppress your details from all marketing systems within 7 business days.

When Personal Data is no longer required, we securely destroy or anonymize it so it can no longer be linked to you.

6. Your Privacy Rights

As a user of rp444, you have the following rights regarding your Personal Data. To exercise any of these rights, email us at [email protected] with the subject line "Privacy Rights Request" and your registered Account email. We will respond within 30 calendar days:

• Right of Access: Request a copy of the Personal Data we hold about you.
• Right of Rectification: Request correction of inaccurate or incomplete Personal Data.
• Right of Erasure: Request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restrict Processing: Request that we limit how we use your data while a correction or objection request is being resolved.
• Right to Data Portability: Request a structured, machine-readable copy of your Personal Data for transfer to another service provider, where technically feasible.
• Right to Object: Object to processing based on our legitimate interests, including profiling for responsible gaming purposes.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), withdraw that consent at any time without affecting the lawfulness of prior processing.

Please note that some requests may be declined where they conflict with our legal obligations (e.g., AML record-keeping) or where fulfilling the request would impair our ability to detect fraud or protect other users.

7. Data Security

rp444 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, or alteration:

• 256-bit SSL/TLS encryption on all data in transit between your browser and our servers.
• AES-256 encryption for sensitive data stored in our databases, including KYC documents and payment identifiers.
• Role-based access controls (RBAC) ensuring that only authorized personnel can access specific categories of user data on a need-to-know basis.
• Multi-factor authentication (MFA) required for all internal systems that handle user data.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Incident response procedures — in the event of a data breach affecting your rights and freedoms, we will notify you within 72 hours of discovery where required by applicable law.

While we implement industry-standard protections, no system is completely immune to security threats. You also have a role to play: keep your rp444 Account password strong and unique, enable two-factor authentication on your Account, and contact us immediately at [email protected] if you suspect unauthorized access.

8. Cookies and Tracking Technologies

rp444 uses cookies and similar technologies to operate the Platform and improve your experience. Here is a summary of the cookies we use:

We do not use advertising or cross-site tracking cookies. You may manage or disable cookies through your browser settings, though disabling strictly necessary cookies will prevent you from logging in or using core Platform features.

9. Minors and Age Restriction

rp444 is strictly an adults-only platform. We do not knowingly collect Personal Data from individuals under the age of 21. Our registration process includes:

• A mandatory declaration confirming you are 21 years of age or older.
• Date-of-birth verification during Account registration.
• KYC identity verification that cross-references your stated date of birth against your submitted identification documents.

If we discover that we have inadvertently collected Personal Data from a user under 21 years of age, we will immediately suspend that Account, delete the associated Personal Data, and reverse any transactions processed. If you believe a minor may have registered on our Platform, please report it to [email protected] immediately.

10. International Data Transfers

rp444 operates as an international platform, and your data may be processed on servers located outside of Indonesia. When we transfer Personal Data internationally, we take the following steps to protect it:

• We transfer data only to countries or entities that provide an adequate level of data protection, or we put in place contractual safeguards (such as standard contractual clauses) to ensure equivalent protection.
• All third-party processors handling Indonesian user data sign data processing agreements that require them to apply security standards consistent with this Policy.
• Transfer to game providers (e.g., Pragmatic Play, Evolution Gaming) is limited to anonymized session identifiers necessary for game-state management. No financial or identity data is shared with game studios.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page.
• Send an email notification to all registered Account holders at least 7 days before the changes take effect.
• Display a notice within the Platform for a minimum of 14 days following publication.

Your continued use of rp444 after the effective date of any revised Policy constitutes your acceptance of the changes. If you disagree with the updated terms, you may close your Account by contacting [email protected] before the effective date.

12. Contact and Data Inquiries

For any questions, concerns, or requests related to this Privacy Policy or your Personal Data, please contact our Privacy team:

• Email: [email protected]
• Subject Line for Privacy Requests: "Privacy Rights Request" or "Data Inquiry"
• Response Time: Within 30 calendar days of receiving a valid request
• Support Hours: 24/7 for live chat; email monitored Monday–Friday, 09:00–21:00 WIB

When submitting a privacy request, please include your registered Account email address and a clear description of your request. We may ask for additional information to verify your identity before fulfilling the request, as a security safeguard to protect your data from unauthorized access by third parties.