Privacy Policy — roq77

01 Introduction

roq77 ("we", "us", "our") operates the online betting and gaming platform accessible at roq77.app. We understand that when you entrust us with your personal information, you are placing significant confidence in our ability to handle that information responsibly. This Privacy Policy is designed to give you clear, honest, and complete information about our data practices.

This Policy applies to all personal data we collect and process in connection with your use of the roq77 platform, whether you are browsing as a visitor, completing account registration, placing bets, depositing or withdrawing funds, or contacting our support team. It covers data collected through the website, live chat, email, and any other channel through which you interact with roq77.

By registering an account or using any part of the roq77 platform, you confirm that you have read this Privacy Policy and agree to the collection and use of your personal data as described herein. If you do not agree, you must refrain from using the Platform. This Privacy Policy forms part of our Terms & Conditions, which govern your use of roq77 in their entirety.

02 Data Controller

The data controller responsible for your personal data is the entity that owns and operates the roq77 platform, as identified in our licensing documentation. As the data controller, roq77 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out lawfully, fairly, and transparently.

For all privacy -related enquiries, requests, or complaints, please contact our Data Protection team using the contact details set out in Section 14 of this Policy. We aim to acknowledge all privacy-related communications within 5 business days.

03 Data We Collect

roq77 collects the following categories of personal data. We collect only what is necessary for the purposes described in this Policy — we do not collect data speculatively or beyond what our platform operations genuinely require.

We do not collect sensitive special-category personal data (such as health data, religious beliefs, or biometric data) unless you voluntarily provide health-related context when requesting responsible gaming accommodations, in which case it is processed solely for that purpose and with your explicit consent.

04 How We Collect Data

roq77 collects your personal data through the following means:

• Direct submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or filling in any form on the Platform.
• Automated collection: Technical and usage data collected automatically when you browse or use the Platform, via server logs, session tracking, and first-party cookies (see Section 10).
• Third-party sources: Identity verification and fraud-screening data from regulated KYC/AML service providers; payment confirmation data from your bank or e-wallet provider (e.g., BCA, OVO, DANA); game session data from our licensed game studio partners (e.g., Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft).
• Inferred data: Behavioural patterns derived from your transaction history or platform usage that inform responsible gaming assessments or fraud risk scoring — these are used internally only and are not shared with third parties for marketing purposes.

05 Legal Basis for Processing

roq77 processes your personal data only where a valid legal basis exists. The primary legal bases on which we rely are as follows:

• Contractual necessity: Processing required to perform the contract between you and roq77 — including account creation, bet settlement, payment processing, and customer support. Without this processing, we cannot provide the Platform services.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money-laundering (AML) obligations, know-your-customer (KYC) requirements, and record-keeping mandates imposed by the Operator's licensing authority.
• Legitimate interests: Processing carried out for roq77's legitimate business interests — including fraud detection and prevention, security monitoring, platform analytics, and responsible gaming risk assessment — where those interests are not overridden by your privacy rights.
• Consent: Where we rely on your consent to process personal data (e.g., for certain marketing communications or for processing health-related responsible gaming disclosures), you may withdraw that consent at any time by contacting support or adjusting your account preferences. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

06 How We Use Your Data

roq77 uses the personal data we collect for the following specific purposes:

• Account management: Creating, maintaining, and securing your roq77 account, including processing password resets and account preference updates.
• Identity and age verification: Confirming that you are at least 21 years of age and that your identity matches the registration details provided, in compliance with our KYC obligations.
• Payment processing: Executing deposit and withdrawal transactions via your chosen payment method (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, OVO, DANA, GoPay, ShopeePay, LinkAja), verifying transaction authenticity, and preventing payment fraud.
• Bet and game management: Recording, settling, and displaying your betting and gaming activity, resolving disputes, and maintaining accurate account balances in Indonesian Rupiah (IDR).
• Responsible gaming: Monitoring your account for patterns that may indicate problem gambling behaviour, enforcing deposit limits, loss limits, session alerts, cooling-off periods, and self-exclusion settings that you activate.
• Fraud and security: Detecting and preventing unauthorised access, cheating, multi-accounting, bonus abuse, match-fixing, money laundering, and other activity that could harm the integrity of the Platform or other Members.
• Customer support: Processing and responding to your support requests, complaints, and feedback.
• Platform improvement: Analysing aggregated and anonymised usage data to improve the performance, design, and feature set of the roq77 Platform.
• Legal and regulatory compliance: Meeting record-keeping, reporting, and disclosure obligations imposed by the Operator's licensing jurisdiction and applicable international standards.
• Marketing communications (consent-based): Sending you promotional offers, bonus notifications, and platform updates by email or in-app notification — only where you have opted in to receive such communications. You may opt out at any time.

07 Data Sharing & Disclosure

roq77 shares your personal data only in the limited circumstances described below. All third parties with whom we share data are contractually required to maintain the confidentiality and security of that data and to use it only for the purposes for which it was shared.

• KYC / Identity verification providers: Regulated third-party services that verify your identity documents and age on our behalf. These providers operate under strict data processing agreements and applicable data protection law.
• Payment processors: Your bank (e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI) or e-wallet provider (OVO, DANA, GoPay, ShopeePay, LinkAja) receives the minimum data necessary to process your financial transactions — typically your account name and transaction reference.
• Game studio partners: Licensed game providers such as Evolution Gaming, Pragmatic Play, Spribe, and Pocket Games Soft may receive a pseudonymous player identifier and relevant session data to operate their game engines within the roq77 Platform. They do not receive your full name, contact details, or financial data.
• AML and fraud screening services: Specialised compliance providers that help roq77 meet its anti-money-laundering obligations by cross-referencing transaction patterns against regulatory watchlists.
• IT infrastructure and hosting providers: Cloud hosting, content delivery, and database services that store and transmit Platform data on our behalf under data processing agreements.
• Legal and regulatory authorities: Where required by law, court order, or regulatory mandate, roq77 may disclose personal data to the relevant authority. We will notify you of such disclosure to the extent permitted by law.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of the roq77 business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

roq77 does not transfer your personal data to countries that do not offer an adequate level of data protection without first implementing appropriate safeguards, such as standard contractual clauses or equivalent protective mechanisms.

08 Data Retention

roq77 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following retention guidelines apply:

• Active account data: Retained for the duration of your account's active period plus a minimum of 5 years following account closure, to satisfy AML record-keeping requirements.
• Transaction records: Financial transaction records, including deposits, withdrawals, and bet history, are retained for a minimum of 5 years from the date of each transaction.
• KYC documents: Identity verification documents are retained for the duration of account activity plus 5 years, unless a longer period is required by the licensing authority's regulations.
• Support communications: Chat transcripts and email correspondence are retained for 2 years from the date of the last interaction, unless they relate to an open or unresolved dispute.
• Technical and usage data: Server logs and session data are retained for up to 12 months for security analysis purposes, after which they are anonymised or deleted.
• Marketing preferences: Records of your marketing consent and opt-out status are retained indefinitely to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked back to you as an individual.

09 Security Measures

roq77 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure:

• 256-bit SSL/TLS encryption: All data transmitted between your browser and the roq77 Platform is encrypted in transit using industry-standard TLS 1.2 or higher.
• Encrypted data storage: Sensitive personal data — including identity documents and financial account details — is encrypted at rest using AES-256 encryption.
• Password security: Account passwords are never stored in plain text. We use salted cryptographic hashing to store password credentials securely.
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis. Staff who access Member data are subject to confidentiality obligations and regular security training.
• Intrusion detection and monitoring: Our infrastructure is continuously monitored for anomalous access patterns, with automated alerts and incident response procedures in place.
• Regular security audits: roq77 conducts periodic third-party security assessments to identify and remediate vulnerabilities in our systems and processes.

10 Cookies & Tracking Technologies

roq77 uses cookies and similar tracking technologies to operate the Platform, remember your session, and analyse usage patterns. The following categories of cookies are used:

roq77 does not use third-party advertising cookies or cross-site tracking pixels. You can manage cookie preferences through your browser settings. Please note that disabling essential cookies will prevent you from logging in and using the Platform.

11 Your Data Rights

As a Member of roq77, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us using the details in Section 14. We will respond within 30 days of receiving a valid request.

• Right of access: You may request a copy of the personal data roq77 holds about you, along with information about how it is being processed.
• 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 completed.
• Right to erasure: You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations (see Section 8). Note that we cannot erase data that we are required to retain by law.
• Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of your data is being resolved.
• Right to data portability: Where processing is based on your consent or on a contractual basis, you may request a machine-readable copy of the personal data you provided to us, for transfer to another service provider.
• Right to object: You may object to processing carried out on the basis of legitimate interests. We will assess whether our interests are overridden by your privacy rights and respond accordingly.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

12 Minors & Age Verification

The roq77 Platform is strictly restricted to individuals who are 21 years of age or older. We do not knowingly collect personal data from anyone under the age of 21. Age verification is a mandatory step in our KYC process, and any account found to belong to a person under the minimum age will be immediately closed.

If you are a parent or guardian and believe that a person under the age of 21 in your care has registered an account on roq77 and submitted personal data, please contact us immediately at the address in Section 14. We will investigate the matter promptly and, where confirmed, close the account and securely delete all associated personal data.

We strongly encourage parents and guardians to use parental control software and to maintain open conversations about responsible online behaviour and the risks associated with gambling. roq77 is an adults-only platform — 21+ strictly enforced.

13 Changes to This Policy

roq77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or the structure of the Platform. When we make material changes, we will notify registered Members via their registered email address or through a prominent notice displayed upon their next login, at least 7 days before the changes take effect.

The "Effective Date" at the top of this Policy indicates when the current version came into force. We encourage you to review this Policy periodically. Your continued use of the roq77 Platform following the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. The most current version of this Policy is always accessible at roq77.app/privacy-policy.

14 Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a privacy-related concern, please contact our Data Protection team. We are available 24/7 and aim to respond to all privacy enquiries within 5 business days.