Privacy Policy

This Privacy Policy ("Policy") describes how vip22 ("vip22", "we", "us", or "our") collects, uses, stores, discloses, and protects personal data belonging to individuals ("you", "Member", or "User") who access or use the vip22 website at https://vip22.lat, its associated mobile-optimized interface, and all services provided therein (collectively, the "Platform").

vip22 operates an international online gaming platform serving adult players, with a primary focus on the Indonesian market. Our players are located across Indonesia's major cities — including Jakarta, Surabaya, Medan, Bandung, Bali, Semarang, and Makassar — and we recognize that trust and data transparency are as fundamental to the player relationship as game quality or payment speed.

This Policy should be read alongside the vip22 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference and form part of the overall agreement between you and vip22. In the event of any conflict between this Policy and the Terms & Conditions on a matter specifically relating to personal data, this Policy shall prevail.

If you have questions about how vip22 handles your personal data, or if you wish to exercise any of your data-subject rights, please contact our Data Privacy team using the details provided in Section 15 of this Policy.

Throughout this Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, account number, location data, or online identifiers.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure by transmission, dissemination, restriction, erasure, or destruction.
• "Controller" — the entity that determines the purposes and means of Processing Personal Data. For data collected via the vip22 Platform, vip22 is the Controller.
• "Processor" — a third party that Processes Personal Data on behalf of vip22 under a written data-processing agreement (e.g., KYC verification providers, payment processors).
• "Sensitive Data" — a subset of Personal Data that warrants heightened protection, including government-issued identification numbers (such as Indonesian KTP numbers), financial account details, and biometric data submitted during KYC verification.
• "Cookie" — a small data file stored on your device by a web browser at the instruction of the Platform to enable session continuity, preference storage, and analytics functions.

vip22 collects Personal Data from Members across several categories. The table below summarizes the main data types collected, their source, and their primary purpose:

vip22 collects only the Personal Data that is necessary for the stated purposes. We do not collect Special Category data such as racial or ethnic origin, political opinions, religious beliefs, or health data except where this is directly relevant to a responsible gaming assessment and you have provided explicit consent.

vip22 collects Personal Data through the following channels:

• Direct submission: Information you actively provide during account registration, KYC document upload, deposit or withdrawal requests, support interactions, or competition entries.
• Automated technical collection: Data collected automatically as you browse and use the Platform, including IP address, device ide ntifiers, session data, and Cookie data (see Section 10).
• Third-party sources: Identity verification data returned by our KYC provider following document checks; fraud-risk signals provided by our payment processors; geolocation data derived from your IP address to confirm jurisdiction eligibility.
• Referral partners: Where you arrive at the Platform via an affiliate or marketing partner, we may receive limited data indicating the referral source. We do not receive your Personal Data from affiliates beyond what is necessary to attribute the referral.

vip22 processes your Personal Data for the following specific purposes:

1. Account creation and management: To register your Account, authenticate your identity, maintain your account settings, and provide you with access to the Platform's services.
2. Age and identity verification: To confirm that you are at least 21 years of age and are who you claim to be, as required by our responsible gaming commitments and licensing obligations.
3. Payment processing: To facilitate deposits via Indonesian banking channels (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and to process withdrawal requests to your verified payment method.
4. Game delivery and personalization: To deliver the games and services you request, remember your preferences, and provide a personalized experience including recommended games and relevant promotional offers.
5. Fraud prevention and platform security: To detect, investigate, and prevent fraudulent transactions, account takeover attempts, bonus abuse, money laundering, and other forms of Malicious Activity as defined in our Terms & Conditions.
6. Legal and regulatory compliance: To meet our obligations under applicable anti-money-laundering (AML), counter-terrorist financing (CTF), and data-protection regulations, including responding to lawful requests from competent authorities.
7. Customer support: To respond to your inquiries, resolve disputes, and maintain records of communications for quality assurance and training purposes.
8. Responsible gaming monitoring: To identify patterns of play that may indicate problem gambling behavior and to enforce the self-exclusion, deposit limit, and cool-off tools you activate through your Account settings.
9. Marketing and promotions: To send you information about bonuses, new game releases, seasonal promotions (including offers around Idul Fitri, Ramadhan, and Indonesian Independence Day), and VIP program updates — but only where you have provided explicit consent or where we have a legitimate interest that is not overridden by your privacy rights.
10. Analytics and platform improvement: To analyze usage patterns, measure feature performance, and improve the overall quality and reliability of the Platform.

vip22 does not use your Personal Data for automated decision-making that produces legal or similarly significant effects on you without providing an opportunity for human review.

vip22 relies on one or more of the following legal bases when processing your Personal Data:

• Contractual necessity: Processing required to perform the contract between you and vip22 — including operating your Account, processing payments, and delivering games.
• Legal obligation: Processing necessary for vip22 to comply with applicable law, including AML/CTF regulations and lawful orders from regulatory or law-enforcement authorities.
• Legitimate interests: Processing carried out for purposes that represent legitimate business interests of vip22, where those interests are not overridden by your fundamental rights — including fraud prevention, platform security, and analytics for service improvement.
• Consent: Processing carried out on the basis of your freely given, specific, informed, and unambiguous consent — including sending direct marketing communications and placing non-essential Cookies. You may withdraw consent at any time without detriment to your ability to use the Platform, though withdrawal will not affect the lawfulness of processing carried out before withdrawal.

vip22 may share your Personal Data with the following categories of third parties under strictly controlled conditions:

• KYC and identity-verification providers: Specialist third-party services that verify your identity and age documents. These providers act as Processors under written data-processing agreements and may not use your data for any purpose beyond the verification service.
• Payment processors and banking partners: Financial institutions and payment service providers (including those facilitating transfers via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and similar channels) who require transaction data to execute and reconcile your deposits and withdrawals.
• Game software providers: Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive session-level technical data to render and settle game outcomes. These providers do not receive your identity or financial data beyond what is needed for game delivery.
• Fraud prevention and cybersecurity services: Third-party security platforms that help vip22 detect account takeover attempts, bot activity, and other fraudulent behavior by analyzing technical and behavioral signals.
• Regulatory and law-enforcement authorities: Where required by applicable law, court order, or regulatory instruction, vip22 will disclose the minimum Personal Data necessary to comply with the lawful demand. vip22 will notify the affected Member where legally permitted to do so.
• Group companies and successors: In the event of a merger, acquisition, restructuring, or sale of all or substantially all of vip22's assets, your Personal Data may be transferred to the relevant acquiring entity, subject to equivalent privacy protections.

vip22 retains Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

When Personal Data is no longer required, vip22 securely deletes or anonymizes it so that it can no longer be associated with any individual. Anonymized data may be retained indefinitely for statistical and research purposes.

vip22 implements a layered security architecture designed to protect your Personal Data against unauthorized access, accidental loss, alteration, and destruction. Key measures include:

• 256-bit SSL/TLS encryption on all data transmissions between your device and the vip22 Platform.
• Encryption at rest for all Sensitive Data stored in vip22's database infrastructure, including KTP numbers, financial account details, and KYC document images.
• Role-based access controls ensuring that only staff members with a demonstrable business need can access specific categories of Personal Data. Access permissions are reviewed quarterly.
• Multi-factor authentication on all internal systems that store or process Member Personal Data.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• Incident response procedures that ensure prompt identification, containment, and notification in the event of a data breach. Where a breach is likely to result in a high risk to your rights and freedoms, vip22 will notify affected Members without undue delay.

While vip22 takes all reasonable technical and organizational measures to secure your data, no digital system can guarantee absolute security. You are responsible for maintaining the confidentiality of your own login credentials and for notifying vip22 promptly if you suspect unauthorized access to your Account.

vip22 uses Cookies and similar tracking technologies (including web beacons and local storage) to operate the Platform effectively, remember your preferences, and gather analytics data that helps us improve the player experience.

The following categories of Cookies are used on the Platform:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens, load-balancing identifiers, and security Cookies. These Cookies cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: Store your preferences such as language settings, display preferences, and recently played game history to personalize your experience across sessions.
• Analytics Cookies: Collect aggregated, anonymized data about how Members navigate and use the Platform — including which pages are visited most frequently and where users exit. This data is used solely to improve Platform performance.
• Marketing Cookies: Used to measure the effectiveness of promotional campaigns and to attribute registrations to the correct marketing channel. These Cookies are only placed with your consent.

You may manage your Cookie preferences at any time through your browser settings. Most modern browsers allow you to block or delete Cookies. Please note that blocking Strictly Necessary Cookies will prevent you from logging into your Account. Blocking other Cookie categories may reduce the personalization of your experience but will not prevent access to core Platform features.

As a Member whose Personal Data is processed by vip22, you have a number of rights with respect to that data. vip22 will respond to all valid data-subject requests within thirty (30) calendar days of receipt, or within ninety (90) days where the complexity of the request justifies an extension (in which case we will notify you of the extension within the first thirty days).

To exercise any of these rights, please contact our Data Privacy team using the details in Section 15. We may require you to verify your identity before processing a data-subject request, to ensure that Personal Data is not disclosed to an unauthorized party.

If you are a parent or guardian and you believe that a person under the age of 21 in your care has registered an Account or provided Personal Data to vip22, please contact us immediately at the details in Section 15. We will investigate and take appropriate action as quickly as possible.

vip22 operates infrastructure and engages service providers that may be located outside Indonesia. Where Personal Data is transferred to a country that does not provide an equivalent level of data protection, vip22 implements appropriate safeguards — such as Standard Contractual Clauses or equivalent contractual protections — to ensure that your data remains protected to a standard consistent with this Policy.

Transfers to game-software providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft are governed by data-processing agreements that restrict those providers from using Member data for any purpose beyond delivering the specific game service to vip22.

vip22 reserves the right to update this Privacy Policy at any time. When material changes are made, vip22 will notify active Members by displaying a prominent notice on the Platform and, where appropriate, by sending a notification to the email address registered to your Account. The updated Policy will take effect on the date stated at the top of this page.

We encourage you to review this Policy periodically to stay informed about how vip22 protects your Personal Data. Continued use of the Platform following the effective date of an amendment constitutes your acceptance of the revised Policy. If you do not agree with the revised Policy, you should close your Account before the amendment takes effect.

For all privacy-related inquiries, data-subject rights requests, or concerns about how vip22 handles your Personal Data, please reach our Data Privacy team through the following channels:

• Email: [email protected] — please mark the subject line "Privacy Request" for prioritized routing. Response within 4–6 hours.
• Live Chat: Available 24/7 directly from the Platform. For data-subject rights requests submitted via live chat, our agents will route your request to the Data Privacy team and confirm receipt within one business day.
• WhatsApp: +62 811 9900 2200 — Indonesian-speaking support agents are available around the clock across WIB (UTC+7), WITA (UTC+8), and WIT (UTC+9) time zones.

vip22 will acknowledge all data-subject rights requests within five (5) business days of receipt and will provide a substantive response within thirty (30) calendar days, or notify you of an extension if required.