qq121 Privacy Policy

qq121 ("we", "us", "our", or "the Company") operates the online casino and sportsbook platform accessible at qq121.club (the "Platform"). The Platform is designed for adult players in Indonesia and the broader Southeast Asian region who prefer an English-language gaming experience delivered through a premium, internationally licensed operator.

This Privacy Policy describes how qq121 collects, processes, stores, and protects personal data submitted by users ("you", "your", or "Member") in connection with your use of the Platform, including registration, deposits, withdrawals, gameplay, bonus participation, and all associated customer support interactions.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming page. By registering an Account or continuing to use the Platform, you confirm that you have read and understood this Privacy Policy and consent to the data processing practices described herein.

For the purposes of this Privacy Policy:

• "Personal Data" means any information that identifies or can reasonably identify a natural person, directly or in combination with other data held by qq121.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, erasure, and destruction.
• "Data Controller" means qq121, 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 qq121, bound by contractual obligations consistent with this Policy.
• "KYC" means Know Your Customer — the identity verification and document review process required by our anti-money laundering and fraud prevention obligations.
• "Cookies" means small text files placed on your device by the Platform to facilitate session management, analytics, and personalisation.
• "Sensitive Data" means a subset of Personal Data that warrants heightened protection, including financial account details, government-issued identity document numbers, and health-related information submitted in the context of responsible gaming self-exclusion requests.

qq121 collects the following categories of Personal Data in the ordinary course of operating the Platform:

We collect only the minimum data necessary for each purpose. Where we have discretion, we prefer pseudonymised or aggregated data over directly identifiable records.

qq121 collects Personal Data through the following channels:

• Direct submission: Information you provide when registering an Account, completing the KYC process, depositing or withdrawing funds, contacting support, or participating in promotions.
• Automated technical collection: Server logs, cookies, pixel tags, and similar tracking technologies that record Technical and Behavioural Data each time you interact with the Platform.
• Third-party identity verification providers: KYC and anti-money laundering (AML) platforms that cross-reference your submitted identity documents against authoritative databases to confirm authenticity.
• Payment processors: Local Indonesian bank transfer gateways and e-wallet providers that relay transaction confirmation data (status, amount, timestamp) back to qq121 upon completion of a deposit or withdrawal.
• Analytics partners: Aggregated, pseudonymised usage data gathered via analytics tools to help qq121 understand platform performance and improve the user experience.

qq121 processes your Personal Data only where a lawful basis exists. The table below maps each processing purpose to its legal basis:

Where processing is based on consent, you may withdraw that consent at any time by updating your communication preferences in Account settings or by contacting our support team. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

qq121 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share your data only in the following limited circumstances:

• Service providers and Data Processors: Third-party companies engaged to provide specific services on our behalf — including payment gateway operators, KYC verification platforms, fraud screening tools, cloud hosting providers, and customer support software — receive only the Personal Data strictly necessary to perform their contracted service and are bound by data processing agreements that prohibit secondary use.
• Regulatory and law enforcement authorities: qq121 may disclose Personal Data to competent authorities where required to do so by applicable law, court order, or regulatory request. We will notify you of such disclosure where we are legally permitted to do so.
• Group companies: Personal Data may be shared within the qq121 corporate group for internal compliance, risk management, and operational purposes, under the same privacy protections that apply to third-party processors.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of the Company's assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections. You will be notified in advance of any such transfer.
• With your explicit consent: In any other circumstance where you have given specific, informed, and unambiguous consent to a particular disclosure.

qq121 retains your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following default retention periods apply:

• Account and Identity Data: Retained for the duration of your active Account plus a minimum of 5 years after Account closure, in accordance with standard AML record-keeping obligations.
• Financial Transaction Data: Retained for a minimum of 5 years from the date of each transaction, as required for financial audit and AML compliance purposes.
• KYC Documents: Retained for a minimum of 5 years from the date of verification, or longer if required by a specific regulatory investigation.
• Communications Data (support tickets, chat logs): Retained for 2 years from the date of the last interaction, unless the communication relates to an open dispute, in which case it is retained until the dispute is fully resolved.
• Technical and Behavioural Data: Aggregated analytics data is retained indefinitely in anonymised form. Raw log files containing IP addresses are retained for 12 months and then deleted or anonymised.
• Responsible Gaming Data: Self-exclusion records are retained for the full duration of the exclusion period plus 5 years after expiry, to prevent circumvention of exclusion commitments.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised so that it can no longer be associated with any identifiable individual.

qq121 employs a layered, defence-in-depth approach to protecting your Personal Data. Our primary technical and organisational security measures include:

• TLS/SSL Encryption: All data in transit between your browser and our servers is encrypted using industry-standard TLS 1.2 or higher protocols.
• Encryption at rest: Sensitive fields — including identity document images, bank account details, and password hashes — are encrypted at the database level using AES-256 or equivalent standards.
• Access controls: Personal Data is accessible only to authorised qq121 personnel whose roles genuinely require it. Access is enforced via role-based permissions, multi-factor authentication, and comprehensive audit logging.
• Penetration testing: The Platform undergoes regular third-party security assessments and penetration tests to identify and remediate vulnerabilities before they can be exploited.
• Intrusion detection: Automated monitoring systems flag anomalous access patterns, unusual transaction volumes, and other indicators of unauthorised activity in real time.
• Incident response: qq121 maintains a documented data breach response procedure. In the event of a confirmed breach that is likely to result in a risk to your rights and freedoms, you will be notified without undue delay and in accordance with applicable notification requirements.

The qq121 Platform uses cookies and similar tracking technologies to deliver core functionality, analyse usage patterns, and personalise your experience. The cookies we deploy fall into four categories:

Most modern browsers allow you to control cookie behaviour via browser settings. Note that disabling strictly necessary cookies will prevent you from logging into your qq121 Account and using core platform features.

Subject to applicable data protection law, you hold the following rights with respect to your Personal Data held by qq121:

• Right of Access: You may request a copy of the Personal Data qq121 holds about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data. Minor updates (email address, phone number) can be made directly in Account settings without submitting a formal request.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where qq121 no longer has a legitimate basis for retaining it. Note that this right is subject to our legal obligation to retain certain data (particularly KYC and financial transaction records) for the mandatory retention periods described in Section 7.
• Right to Restriction: You may request that qq121 suspend processing of your data in certain circumstances — for example, while the accuracy of the data is contested or while a complaint is under review.
• Right to Data Portability: You may request a machine-readable copy of the Personal Data you provided to qq121, to the extent technically feasible.
• Right to Object: You may object to processing based on legitimate interests at any time. qq121 will cease that processing unless it can demonstrate compelling legitimate grounds that override your interests, or the processing is necessary for the establishment or defence of legal claims.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, submit your request in writing to [email protected] with the subject line "Privacy Rights Request — [Your Account Username]". We will acknowledge your request within 3 business days and provide a substantive response within 30 calendar days. Complex requests may be extended by a further 30 days, with written notice to you.

The qq121 Platform integrates with a number of third-party service providers to deliver the full range of features available to Members. These include game content providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft), payment infrastructure partners for Indonesian bank transfers and e-wallet processing, and KYC verification platforms.

Each third-party provider operates under its own privacy policy in relation to data they independently collect through their embedded services. qq121 is not responsible for the privacy practices of third-party game studios or providers with respect to data collected directly by their own software components. We recommend reviewing the privacy notices of any third-party service you interact with directly.

qq121 does not permit any third-party provider to use your Personal Data for purposes beyond those strictly necessary to provide the contracted service. All providers are vetted for data security compliance prior to integration and are subject to ongoing review.

The qq121 Platform is strictly for adults aged 21 years and older. We do not knowingly collect, process, or store Personal Data relating to persons under the age of 21. The Platform employs age verification checks at registration, and any Account found to have been created by a person under the age of 21 will be immediately suspended and all associated data will be deleted, except where retention is required to prevent future underage registration attempts or to comply with regulatory obligations.

If you are a parent or guardian and have reason to believe that a minor under your care has submitted Personal Data to qq121, please contact us immediately at [email protected]. We will investigate and take prompt corrective action, including deletion of the relevant data.

qq121 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the structure of the Platform. When we make a material change — one that substantively affects how your Personal Data is used or the rights available to you — we will notify you via email to the address registered on your Account, and we will display a prominent notice on the Platform for a minimum of 14 days before the revised Policy takes effect.

Non-material changes (such as typographical corrections or rewording that does not alter the substance of a clause) may take effect immediately upon publication. The "Effective date" and "Version" at the top of this document are updated with every revision to provide a clear audit trail.

Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you should cease using the Platform and contact support to arrange closure of your Account and withdrawal of your available balance.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way qq121 handles your Personal Data, please contact us through the following channels:

• Email: [email protected] (plain text — not a clickable link). Use the subject line "Privacy Query — [Your Account Username]" for fastest routing.
• Live Chat: Available 24/7 via the built-in live chat widget on the Platform.
• Indonesian-speaking agents: Available daily from 08:00 to 24:00 WIB for Members who prefer to discuss privacy matters in Bahasa Indonesia.

qq121 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection law. The DPO can be reached at the same email address above with the subject line "Attn: Data Protection Officer".

We aim to acknowledge all privacy-related correspondence within 3 business days and to resolve substantive queries within 30 calendar days. Where a resolution requires additional time due to complexity or third-party dependencies, we will communicate a revised timeline in writing.