Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by rbt52 through our website at https://rbt52.cam, mobile applications, customer support channels, and any other services we provide (collectively referred to as "the Platform"). This policy covers information collected from residents of Indonesia and other jurisdictions where we operate. By creating an account or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

rbt52 acts as the data controller for the personal information we collect and process. We are responsible for ensuring that your personal data is handled in accordance with this Privacy Policy and applicable data protection laws. If you have questions or concerns about how we handle your data, please contact us using the information provided at the end of this policy.

2. Information We Collect

2.1 Information You Provide Directly

When you register for an rbt52 account, use our services, or communicate with us, we collect personal information that you voluntarily provide, including but not limited to:

• Account Registration Information: Full name, date of birth, email address, phone number, residential address, username, and password.
• Identity Verification Documents: Government-issued identification (KTP, passport, or driver's license), proof of address documents, photographs for identity verification, and payment method verification documents.
• Financial Information: Bank account details, e-wallet account information (OVO, DANA, GoPay, ShopeePay), transaction history, deposit and withdrawal records, and payment method preferences.
• Communication Data: Customer support inquiries, chat messages, email correspondence, feedback, complaints, and any other communications you send to us.
• Voluntary Information: Survey responses, competition entries, promotional preferences, and any other information you choose to provide.

2.2 Information Collected Automatically

When you access and use the rbt52 platform, we automatically collect certain technical and usage information through cookies, web beacons, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers, and mobile network information.
• Usage Data: Pages visited, features used, time spent on pages, click patterns, search queries, bet history, game play records, session duration, and referral sources.
• Location Data: IP address, geographic location derived from IP address, and time zone information.
• Technical Data: Browser cookies, log files, error reports, performance metrics, and security event logs.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment processors and financial institutions that verify your payment methods and process transactions.
• Identity verification services that confirm your identity and age to ensure regulatory compliance.
• Fraud prevention and security services that help us detect and prevent fraudulent activity.
• Marketing partners and affiliates who refer you to our platform (with appropriate consent).

3. How We Use Your Information

rbt52 uses your personal information for the following legitimate business purposes:

3.1 Account Management and Service Provision

• Creating and maintaining your player account.
• Processing deposits, withdrawals, and other financial transactions.
• Providing access to betting markets, casino games, and other platform features.
• Recording and settling bets, calculating winnings, and updating account balances.
• Managing bonuses, promotions, and loyalty programs.

3.2 Verification and Compliance

• Verifying your identity and age to ensure you are at least 21 years old.
• Complying with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations.
• Detecting and preventing fraud, money laundering, and other illegal activities.
• Enforcing our Terms & Conditions and preventing prohibited uses of the platform.
• Responding to legal requests from government authorities and law enforcement.

3.3 Communication and Customer Support

• Responding to your inquiries, support requests, and complaints.
• Sending transactional notifications about deposits, withdrawals, bets, and account activity.
• Providing customer service through live chat, email, and other support channels.
• Notifying you of changes to our services, policies, or terms.

3.4 Marketing and Promotions (With Your Consent)

• Sending promotional emails, SMS messages, and push notifications about bonuses, special offers, and new features (only if you have opted in).
• Personalizing marketing communications based on your preferences and betting behavior.
• Conducting surveys and research to improve our services.

3.5 Platform Improvement and Analytics

• Analyzing usage patterns to improve platform performance and user experience.
• Testing new features and functionality.
• Monitoring platform security and detecting technical issues.
• Conducting data analytics and statistical analysis (using aggregated, anonymized data where possible).

3.6 Responsible Gaming and Player Protection

• Identifying and assisting players who may be experiencing problem gambling behaviors.
• Implementing self-exclusion requests and deposit limits.
• Monitoring for unusual betting patterns that may indicate problematic gambling.
• Providing access to responsible gaming tools and resources.

4. Legal Basis for Processing

Under applicable data protection laws, rbt52 relies on the following legal bases for processing your personal information:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., providing betting services as outlined in our Terms & Conditions).
• Legal Obligation: Processing is required to comply with legal and regulatory obligations, including age verification, AML/KYC compliance, and responding to law enforcement requests.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, platform improvement, and customer support, provided these interests are not overridden by your privacy rights.
• Consent: Where required by law, we obtain your explicit consent before processing your data for marketing purposes or using non-essential cookies.

5. How We Share Your Information

rbt52 does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for the purposes described in this policy:

5.1 Service Providers and Business Partners

• Payment Processors: Banks, e-wallet providers, and payment gateways that process your deposits and withdrawals (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay).
• Identity Verification Providers: Third-party services that verify your identity and age for regulatory compliance.
• Game Providers: Licensed software providers that supply casino games, live dealer games, and other gaming content.
• Cloud Infrastructure Providers: Hosting and data storage services that maintain our platform infrastructure.
• Customer Support Tools: Software platforms that enable us to provide live chat, email support, and ticketing services.
• Analytics and Performance Monitoring: Services that help us analyze platform usage and improve performance.

All service providers are contractually required to protect your data and use it only for the specific purposes we authorize.

5.2 Legal and Regulatory Authorities

We may disclose your personal information to government authorities, law enforcement agencies, regulators, and courts when required by law or when necessary to:

• Comply with legal obligations, court orders, subpoenas, or regulatory requests.
• Investigate and prevent fraud, money laundering, or other illegal activities.
• Protect our legal rights, property, or safety, or the rights and safety of our players and the public.
• Enforce our Terms & Conditions and other policies.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor company as part of the business transaction. We will notify you via email or prominent notice on our platform before your data is transferred and becomes subject to a different privacy policy.

6. Data Security Measures

rbt52 implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security practices include:

• Encryption: All sensitive data, including passwords and financial information, is encrypted using industry-standard SSL/TLS encryption during transmission and at rest.
• Access Controls: Strict internal access controls ensure that only authorized personnel can access your personal data, and only when necessary for legitimate business purposes.
• Secure Infrastructure: Our platform is hosted on secure servers with firewalls, intrusion detection systems, and regular security patches.
• Regular Security Audits: We conduct periodic security assessments and penetration testing to identify and address vulnerabilities.
• Employee Training: All staff members receive training on data protection principles and security best practices.
• Data Minimization: We collect and retain only the personal information necessary for our legitimate business purposes.

While we implement robust security measures, no system is completely secure. You are responsible for maintaining the confidentiality of your account credentials and should notify us immediately if you suspect unauthorized access to your account.

7. Data Retention

rbt52 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal and regulatory obligations. Specific retention periods include:

• Active Accounts: Personal information associated with active accounts is retained for the duration of your relationship with rbt52.
• Closed Accounts: After you close your account, we retain certain information for a minimum of 5 years (or longer if required by law) to comply with AML/KYC regulations, tax obligations, and to resolve disputes or enforce our terms.
• Transaction Records: Financial transaction records are retained for at least 7 years as required by financial regulations.
• Marketing Data: If you opt out of marketing communications, we retain minimal information (email address or phone number) on a suppression list to ensure we do not contact you again.
• Legal Hold: If information is subject to litigation, investigation, or regulatory inquiry, we retain it until the matter is resolved.

Once retention periods expire, we securely delete or anonymize your personal information so that it can no longer identify you.

8. Your Privacy Rights

Under applicable data protection laws, you have certain rights regarding your personal information. These rights may vary depending on your jurisdiction, but generally include:

• Right to Access: You can request a copy of the personal information we hold about you.
• Right to Rectification: You can request that we correct inaccurate or incomplete information.
• Right to Erasure: You can request deletion of your personal data, subject to legal retention requirements.
• Right to Restrict Processing: You can request that we limit how we use your information in certain circumstances.
• Right to Data Portability: You can request a copy of your data in a structured, machine-readable format.
• Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where we rely on consent, you can withdraw it at any time (though this does not affect prior processing).

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided below. We will respond to your request within 30 days. Please note that certain rights may be limited by legal requirements or legitimate business needs (e.g., we cannot delete information required for regulatory compliance).

9. Cookies and Tracking Technologies

rbt52 uses cookies, web beacons, and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze platform usage. We use the following types of cookies:

• Essential Cookies: Required for basic platform functionality, such as maintaining your login session and processing transactions. These cannot be disabled.
• Performance Cookies: Collect anonymous information about how you use our platform to help us improve performance and user experience.
• Functionality Cookies: Remember your preferences (e.g., language, time zone) and provide enhanced features.
• Marketing Cookies: Track your activity across websites to deliver personalized advertisements (only with your consent).

You can manage cookie preferences through your browser settings. However, disabling essential cookies may prevent you from using certain platform features. For more information about cookies and how to control them, visit www.allaboutcookies.org.

10. International Data Transfers

rbt52 primarily operates in Indonesia and stores data within Indonesian data centers or with cloud providers serving the Indonesian market. However, some of our service providers may process data in other countries. When we transfer personal information internationally, we ensure that appropriate safeguards are in place, such as standard contractual clauses, to protect your data in accordance with applicable data protection laws.

11. Children's Privacy

The rbt52 platform is intended exclusively for adults aged 21 years and older. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete that information and terminate the associated account. If you believe a minor has provided us with personal information, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

rbt52 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or platform features. When we make material changes, we will notify you by email (to the address associated with your account) or by posting a prominent notice on our platform. The updated policy will indicate the date of the most recent revision. Continued use of the platform after changes take effect constitutes acceptance of the revised Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

13. Contact Us and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact us:

• Email: [email protected]
• Subject Line: Privacy Inquiry - Data Protection Request
• Response Time: We will respond to all privacy-related inquiries within 30 days.

For specific data protection concerns, you may also contact our Data Protection Officer, who is responsible for overseeing compliance with this Privacy Policy and applicable data protection regulations.