Privacy Policy

This Privacy Policy is issued by qq108 International Ltd. (referred to throughout this document as "qq108", "we", "us", or "our"), the operator of the online gaming and sports-betting platform accessible at https://qq108.app. qq108 acts as the data controller in respect of all personal data collected from members and visitors of the Platform.

qq108 is committed to handling your personal data with transparency, integrity, and in full accordance with the privacy principles embedded in our international licensing obligations. If you have any questions about our data practices, you may contact our Data Protection team at any time — see Clause 14 for contact details.

qq108 collects personal data in the following categories:

qq108 does not collect special categories of sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) unless expressly required for responsible gaming self-exclusion processing, in which case only the minimum necessary information will be collected and stored with enhanced security controls.

We collect personal data through the following channels:

• Direct submission: When you register an Account, complete KYC verification, submit a deposit or withdrawal request, contact our support team, respond to a survey, or participate in a promotion, you provide data to us directly.
• Automated technologies: As you browse the qq108 Platform, we automatically collect Technical Data and Usage Data via cookies, web beacons, pixel tags, and server-side logging. See Clause 7 for full details on our cookie practices.
• Third-party payment processors: When you initiate a transaction through a local Indonesian bank or e-wallet, the payment provider shares transaction confirmation data with qq108 to enable crediting or debiting of your Account Balance.
• Identity verification services: Where we use a third-party KYC provider to verify your identity documents, that provider will share a verification result and relevant extracted data fields with qq108.
• Fraud prevention and compliance partners: We may receive risk signals and flagging data from licensed fraud-prevention, anti-money-laundering (AML), and responsible gaming screening services.

qq108 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contract performance: Processing is necessary to create and maintain your Account, process transactions, and deliver the gaming services you have requested.
• Legal obligation: Processing is required to comply with our international licensing conditions, anti-money laundering regulations, and Know Your Customer (KYC) obligations.
• Legitimate interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and product improvement — provided those interests are not overridden by your rights.
• Consent: Where we send you optional marketing communications or use non-essential cookies, we rely on your freely given, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

qq108 uses the personal data we hold about you for the following purposes:

• To create, manage, and maintain your Account, including verifying your identity and age (21+ requirement) at registration and at subsequent KYC checkpoints.
• To process deposits and withdrawals in Indonesian Rupiah (IDR) through your chosen local bank or e-wallet, and to maintain accurate financial records of all transactions.
• To deliver the gaming and betting services available on the Platform, including sportsbook markets, live casino games, slot titles, scratch cards, and Live Dragon Tiger.
• To detect, investigate, and prevent fraud, money laundering, underage gambling, multi-accounting, and any other prohibited conduct set out in our Terms & Conditions.
• To monitor your gaming activity for responsible gaming purposes — including identifying patterns that may indicate problem gambling — and to proactively communicate with you about available support tools where appropriate.
• To respond to your support inquiries via live chat or email, resolve disputes, and maintain records of communications for quality-assurance purposes.
• To send you service-related notifications, including Account alerts, deposit confirmations, withdrawal status updates, and important policy changes.
• To send you promotional and marketing communications about qq108 offers, bonuses, and new features — where you have provided consent or where permitted under our legitimate-interests basis. You may opt out at any time.
• To personalise your experience on the Platform, including surfacing relevant sports markets, game recommendations, and promotional offers based on your preferences and activity history.
• To comply with our obligations under international gaming regulations, report suspicious transactions to competent authorities where legally required, and cooperate with law enforcement investigations.

qq108 may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate confidentiality and data protection agreements:

• Payment processors and banks: Indonesian local banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Danamon) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum transaction data necessary to execute deposit and withdrawal instructions.
• KYC and identity verification providers: We share identity documents and personal details with licensed third-party KYC verification services to confirm your identity and age as part of our regulatory obligations.
• Game content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Pocket Games Soft, and Spribe may receive a session token and anonymised player identifiers necessary to deliver their games on the Platform. These providers do not receive your full identity or financial data.
• Fraud prevention and AML screening services: We share risk-relevant data with licensed compliance service providers for the purpose of detecting and preventing financial crime.
• Regulatory and law enforcement authorities: We may disclose personal data to competent authorities where we are legally required to do so — for example, in response to a court order, a regulatory investigation, or a suspicious transaction report filed under AML obligations.
• IT infrastructure and hosting providers: Our platform is hosted on secure cloud infrastructure. Our hosting and content-delivery partners process Technical Data in the course of providing infrastructure services and are bound by strict data processing agreements.
• Customer support platforms: Our live chat and ticketing system providers process Communications Data to enable our support team to handle your inquiries. These providers operate under confidentiality agreements and do not use your data for any purpose beyond service delivery.

All third-party data processors engaged by qq108 are contractually required to implement appropriate technical and organisational security measures, to process data only on qq108's documented instructions, and to promptly notify qq108 of any data security incident that may affect your personal data.

The qq108 Platform uses cookies and similar tracking technologies to deliver a functional, secure, and personalised experience. The following table describes the categories of cookies we deploy:

You may manage your cookie preferences at any time by adjusting your browser settings to block or delete cookies. Please note that blocking strictly necessary cookies will impair your ability to log in and use core Platform features. Disabling analytics or marketing cookies will not affect your access to the Platform's gaming services.

qq108 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable laws and our international licensing obligations. The following general retention periods apply:

• Active Account data: Retained for the full duration of your membership and for a minimum of five (5) years following Account closure, to satisfy AML and gaming regulatory record-keeping requirements.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of submission, or longer if required by a regulatory investigation or legal hold.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction in accordance with AML best practice.
• Customer support communications: Retained for two (2) years from the date of each interaction unless the content is relevant to an ongoing dispute or compliance matter, in which case it is retained until resolution.
• Marketing consent records: Retained for the duration of the consent period plus two (2) years, to demonstrate compliance with consent requirements.
• Analytics and usage data: Retained in aggregated, anonymised form indefinitely for product improvement purposes. Raw session-level data is purged after thirteen (13) months.

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised so that it can no longer be associated with an identifiable individual.

qq108 implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key measures include:

• TLS/SSL encryption: All data transmitted between your browser and the qq108 Platform is encrypted using industry-standard Transport Layer Security (TLS 1.2 or higher). The padlock icon in your browser confirms an active secure connection.
• Encryption at rest: Sensitive fields — including identity document data, payment account details, and passwords — are encrypted at rest using AES-256 or equivalent symmetric encryption.
• Access controls: Access to personal data within qq108 is restricted on a strict need-to-know basis. Staff with authorised access are subject to confidentiality obligations and regular security awareness training.
• Two-factor authentication (2FA): qq108 supports 2FA on Member Accounts. We strongly encourage all members to enable 2FA to add a second layer of protection to their login process.
• Penetration testing and vulnerability assessments: The Platform undergoes regular third-party security assessments to identify and remediate vulnerabilities before they can be exploited.
• Incident response: In the event of a data security incident that poses a risk to your rights and freedoms, qq108 will notify affected Members and the relevant regulatory authority without undue delay and within the timeframes required by applicable law.

As a data subject, you hold the following rights in respect of your personal data held by qq108. To exercise any of these rights, please contact us using the details in Clause 14. We will respond to all valid requests within 30 days.

• Right of Access: You have the right to request a copy of the personal data qq108 holds about you, along with information about how it is being processed. This is commonly known as a Subject Access Request (SAR).
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or supplemented without undue delay.
• Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal data. Note that this right is subject to overriding legal obligations — for example, we may be required to retain transaction records for AML compliance even after Account closure.
• Right to Restriction of Processing: You may request that we restrict the processing of your data in specific situations — for example, while a rectification request is pending or while you contest the lawfulness of our processing.
• Right to Data Portability: Where processing is based on consent or contract performance, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to Object: You have the right to object to processing carried out on the basis of our legitimate interests, and to opt out of direct marketing communications at any time without giving any reason.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before the withdrawal.

If you believe qq108 has not handled your personal data in accordance with this Privacy Policy or applicable law, you have the right to lodge a complaint with the relevant data protection supervisory authority in the jurisdiction governing our licence. We would, however, encourage you to contact us directly in the first instance so that we can address your concern promptly.

Age verification is a mandatory step in the Account registration and KYC process. If qq108 becomes aware that personal data has been collected from a person under the age of 21 — whether through a false age declaration at registration or any other means — the relevant Account will be immediately suspended, all associated funds will be frozen pending review, and all personal data collected from that individual will be securely deleted to the extent permitted by applicable legal obligations.

If you are a parent or guardian and have reason to believe that a person under 21 in your care has registered on the qq108 Platform, please contact our support team immediately at [email protected] so that we can take prompt action.

The qq108 Platform may contain references or contextual links to third-party websites or services — for example, game studios, sports data providers, or regulatory bodies. This Privacy Policy applies solely to the qq108 Platform and does not extend to any third-party sites or services you may visit as a result of links found on the Platform.

qq108 has no control over the content or privacy practices of third-party websites and accepts no responsibility for them. We encourage you to review the privacy policy of any third-party site you visit before providing any personal data to that site.

qq108 reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, operational requirements, or applicable law. When material changes are made, we will notify you by email or by displaying a prominent notice on the Platform prior to the changes taking effect. The "Last Updated" date at the top of this page will be revised accordingly.

Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of the updated policy. If you do not agree with any material changes to this policy, you should cease using the Platform and request Account closure in accordance with the Terms & Conditions.

We recommend bookmarking this page and reviewing it periodically to stay informed about how qq108 protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way qq108 processes your personal data, please reach out to our Data Protection team through the following channels:

• Live Chat: Available 24/7 directly on the Platform. Native Indonesian-speaking agents are on hand across WIB, WITA, and WIT time zones. Average first response time is under 30 seconds.
• Email: [email protected] — data protection and privacy inquiries are prioritised and typically responded to within one (1) business day.

When submitting a rights request (e.g., Subject Access Request, erasure request), please include your registered email address and Member ID to allow our team to locate your Account and process your request efficiently. We will acknowledge all formal data protection requests within 72 hours and provide a full response within 30 calendar days.