Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all users of alfaqq services, including visitors to our website, registered account holders, and anyone who interacts with our platform. alfaqq operates as an online gaming platform providing sports betting, live casino games, slot games, and lottery services to users in Indonesia. We are the data controller responsible for your personal information collected through our services.

This policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your relationship with alfaqq. If you have questions about how we handle your data or wish to exercise your privacy rights, please contact our Data Protection Officer using the contact details provided at the end of this document.

We respect your privacy and are committed to complying with applicable data protection laws and regulations. This includes implementing appropriate technical and organizational measures to ensure the security of your personal data and processing it only for legitimate, specified purposes with your informed consent.

2. Information We Collect

2.1 Information You Provide Directly

When you register for an alfaqq account, we collect personal information that you provide directly to us, including:

• Identity Information: Full legal name, date of birth, gender, and nationality as shown on your government-issued identification documents
• Contact Information: Email address, telephone number, residential address including street address, city, province, and postal code
• Account Credentials: Username, password, and security questions/answers that you create during registration
• Identification Documents: Copies of your Indonesian identity card (KTP), proof of address documents, and selfie photographs for identity verification purposes
• Financial Information: Bank account details including bank name, account number, and account holder name for processing deposits and withdrawals
• Communication Records: Content of your communications with our customer support team via live chat, email, WhatsApp, or other channels

2.2 Information Collected Automatically

When you access and use alfaqq services, we automatically collect certain information about your device and usage patterns:

• Device Information: Device type, operating system, browser type and version, screen resolution, and unique device identifiers
• Usage Data: Pages viewed, features used, time spent on pages, click patterns, scroll behavior, and navigation paths through our platform
• Transaction History: Records of all deposits, withdrawals, bets placed, games played, winnings, losses, and bonus claims
• Technical Data: IP address, browser settings, time zone, location data (where permitted), and other diagnostic data
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies as detailed in our Cookie Policy

2.3 Information from Third Parties

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

• Payment processors and financial institutions that facilitate your transactions with us
• Identity verification services that help us confirm your identity and age during the KYC process
• Fraud prevention services that provide risk assessment data to protect against fraudulent activities
• Marketing partners if you interact with alfaqq through third-party promotions or affiliate links

3. How We Use Your Information

alfaqq collects and processes your personal information for the following legitimate purposes:

• Account Management: Creating, maintaining, and securing your alfaqq account, including authentication and access control
• Service Provision: Enabling you to place bets, play games, and access all features of our platform
• Payment Processing: Processing deposits, withdrawals, and all financial transactions associated with your account
• Identity Verification: Confirming your identity, age, and address to comply with legal requirements and prevent underage gambling
• Customer Support: Responding to your inquiries, resolving technical issues, and providing assistance with account matters
• Fraud Prevention: Detecting, investigating, and preventing fraudulent activities, cheating, money laundering, and other illegal activities
• Regulatory Compliance: Meeting our legal obligations under gaming regulations, anti-money laundering laws, and tax reporting requirements
• Platform Improvement: Analyzing usage patterns to improve our services, develop new features, and enhance user experience
• Marketing Communications: Sending promotional offers, bonuses, and newsletters (with your consent, which you can withdraw at any time)
• Responsible Gaming: Monitoring gambling behavior to identify potential problem gambling and implementing responsible gaming measures

4. Legal Basis for Processing

Under data protection laws, we must have a valid legal basis for processing your personal information. We process your data based on one or more of the following grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., providing gaming services as outlined in our Terms & Conditions)
• Legal Obligation: Processing is required to comply with legal obligations such as age verification, anti-money laundering checks, and tax reporting
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security enhancement, and service improvement, provided these interests do not override your rights
• Consent: You have given explicit consent for specific processing activities, such as receiving marketing communications or participating in optional surveys

5. Data Sharing and Disclosure

5.1 When We Share Your Information

alfaqq does not sell your personal information to third parties. However, we may share your data with carefully selected partners and service providers in the following circumstances:

• Payment Processors: Banks, e-wallet providers, and payment gateways that facilitate your deposits and withdrawals (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, etc.)
• Game Providers: Software companies that supply our casino games and ensure fair play (Pragmatic Play, Evolution Gaming, Microgaming, etc.)
• Verification Services: Third-party identity verification and KYC service providers that help us confirm your identity and age
• Fraud Prevention Services: Security companies that provide fraud detection, risk assessment, and cybersecurity services
• Customer Support Tools: Communication platforms that power our live chat and help desk services
• Marketing Partners: Email service providers and advertising platforms (only if you have consented to marketing communications)
• Legal Authorities: Law enforcement, regulatory bodies, and government agencies when legally required or to protect our legitimate interests
• Professional Advisors: Lawyers, auditors, accountants, and consultants who provide professional services to alfaqq

5.2 International Data Transfers

As an international gaming platform, some of our service providers and partners may be located outside of Indonesia. When we transfer your data internationally, we ensure that appropriate safeguards are in place to protect your information in accordance with applicable data protection standards. These safeguards may include standard contractual clauses, adequacy decisions by relevant authorities, or other legally approved transfer mechanisms.

6. Data Security Measures

alfaqq takes data security extremely seriously and implements comprehensive technical and organizational measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

• Encryption: All sensitive data transmitted between your device and our servers is protected using 256-bit SSL encryption, the same technology used by major banks
• Secure Storage: Personal data is stored on secure servers with restricted access, multiple redundancies, and regular backups
• Access Controls: Strict internal policies limit employee access to personal data on a need-to-know basis, with all access logged and audited
• Authentication: Strong password requirements, account verification processes, and optional two-factor authentication for enhanced security
• Monitoring: Continuous monitoring systems detect and alert us to potential security threats or suspicious activities
• Regular Audits: Independent security audits and penetration testing to identify and address vulnerabilities
• Staff Training: Regular training for all alfaqq employees on data protection principles and security best practices

While we implement industry-leading security measures, no method of transmission over the internet or electronic storage is completely secure. You also have a responsibility to protect your account by keeping your login credentials confidential and logging out after each session, especially on shared devices.

7. Data Retention

alfaqq retains your personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, regulatory, accounting, and reporting requirements. Our retention periods vary depending on the type of data:

• Account Information: Retained for the duration of your active account plus 5 years after account closure for regulatory compliance and dispute resolution purposes
• Transaction Records: Retained for 7 years after the transaction date to meet financial reporting and anti-money laundering obligations
• Identity Verification Documents: Retained for 5 years after account closure as required by KYC regulations
• Marketing Consents: Retained until you withdraw consent or for 3 years of inactivity, whichever is earlier
• Customer Support Records: Retained for 3 years after the last interaction for quality assurance and dispute resolution

When data is no longer needed, we securely delete or anonymize it in accordance with our data retention policy. Anonymized data that cannot be linked back to you may be retained indefinitely for analytical purposes.

8. Your Privacy Rights

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

• Right to Access: You can request a copy of the personal data we hold about you, including information about how we use it
• Right to Rectification: You can request correction of inaccurate or incomplete personal data
• Right to Erasure: You can request deletion of your personal data in certain circumstances, subject to legal retention obligations
• Right to Restriction: You can request that we limit how we use your data in certain situations
• Right to Data Portability: You can request a copy of your data in a structured, commonly used format for transfer to another service
• Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw that consent at any time

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 11. We will respond to your request within 30 days. Please note that some rights may be subject to limitations based on legal obligations or legitimate business needs.

9. Cookies and Tracking Technologies

alfaqq uses cookies 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 provide personalized services. We use the following types of cookies:

• Essential Cookies: Necessary for the basic functioning of our platform, including authentication, security, and navigation
• Functional Cookies: Remember your preferences and choices to provide enhanced, personalized features
• Analytics Cookies: Collect anonymous data about how you use our platform to help us improve services and user experience
• Marketing Cookies: Track your browsing habits to deliver relevant promotional content (only with your consent)

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our services. Most browsers accept cookies automatically, but you can modify your browser settings to decline cookies if you prefer.

10. Children's Privacy

alfaqq services are strictly intended for adults aged 21 and over. We do not knowingly collect personal information from individuals under the legal gambling age. Our registration process includes mandatory age verification, and we require government-issued identification to confirm that all users meet the minimum age requirement.

If we become aware that we have inadvertently collected information from someone under 21 years of age, we will immediately delete that information and permanently close the account. Parents and guardians who believe their child has provided personal information to alfaqq should contact us immediately so we can take appropriate action.

11. Changes to This Privacy Policy

alfaqq reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or technological developments. When we make material changes, we will notify you by posting the updated policy on our website with a new "Last Updated" date. For significant changes that materially affect your rights, we may also notify you via email or through a prominent notice on our platform.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of alfaqq services after any changes indicates your acceptance of the updated Privacy Policy.

12. Contact Information and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

• Email: [email protected] (displayed as plain text only, not a clickable link)
• Subject Line: Please use "Privacy Inquiry" or "Data Protection Request" for faster routing
• Live Chat: Available 24/7 through our website for immediate assistance
• Response Time: We aim to respond to all privacy inquiries within 10 business days

When contacting us about your personal data, please provide sufficient information to verify your identity to protect against unauthorized access to your information. We may request additional verification before processing certain requests.