rvp1 Privacy Policy

1. Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure, dissemination, restriction, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this case, rvp1 and its authorized operators.
• "Data Processor" means a natural or legal person that processes Personal Data on behalf of the Data Controller.
• "User", "You", "Your" refers to any individual who accesses, registers on, or uses the rvp1 platform.
• "Platform" refers to the rvp1 website at https://rvp1.cam, its sub-domains, mobile applications, and all associated digital services.
• "KYC" (Know Your Customer) refers to the identity and address verification procedures required under our anti-money laundering obligations.
• "Sensitive Personal Data" means special categories of Personal Data such as financial information, identification documents, and payment card data, which require heightened protection.

2. Data Controller Identity

rvp1 acts as the Data Controller for all Personal Data collected through the Platform. As Data Controller, rvp1 is responsible for determining how and why your Personal Data is processed, and for ensuring that such processing complies with applicable data protection principles.

For data protection inquiries, you may contact our Data Protection Team at the contact details provided in Section 15 of this Policy. We are committed to responding to all privacy-related inquiries within 14 business days of receipt.

3. Personal Data We Collect

rvp1 collects several categories of Personal Data to operate our platform securely and provide a personalized, compliant service to Indonesian players. The categories of data we collect are detailed below:

3.1 Identity and Registration Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify you are 21 years of age or older);
• Indonesian National Identity Card number (NIK from your KTP);
• Gender (optional, collected for demographic analysis only);
• Profile photograph where submitted as part of KYC verification.

3.2 Contact Data

• Primary email address;
• Indonesian mobile phone number (required for account verification and two-factor authentication);
• Residential address, including province, city, and postal code.

3.3 Financial and Payment Data

• Bank account details including bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, and others), account number, and account holder name;
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja;
• Deposit and withdrawal transaction records including amounts in Indonesian Rupiah (IDR/Rp), timestamps, and payment method used;
• Account balance history and gaming activity records for financial reconciliation.

3.4 Verification Documents (KYC Data)

• Scanned or photographed copies of your KTP (Indonesian National Identity Card);
• Proof of address documentation (utility bills, bank statements, or official correspondence dated within the last 3 months);
• Identity verification selfies (photographs of you holding your KTP);
• Source of funds documentation where requested for large transactions.

3.5 Technical and Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser version;
• Session duration, pages visited, and features used;
• Game play history, betting activity, and wagering patterns;
• Login timestamps, access logs, and account activity records.

3.6 Communications Data

• Records of your interactions with our customer support team via live chat, email, or WhatsApp;
• Feedback and survey responses submitted through the platform;
• Promotional communication preferences (opt-in and opt-out records).

4. How We Collect Your Data

rvp1 collects Personal Data through the following channels:

Collection Method	Data Types Collected
Account Registration Form	Name, email, phone number, date of birth, password
KYC Verification Process	Identity documents, proof of address, verification selfies
Deposit & Withdrawal Transactions	Bank account details, e-wallet IDs, transaction amounts
Platform Usage (Automatic)	IP address, device data, session logs, game history
Cookies & Tracking Technologies	Browsing behavior, preferences, referral source
Customer Support Interactions	Chat transcripts, email correspondence, feedback
Third-Party Payment Processors	Transaction confirmation data, payment status

5. Lawful Basis for Processing

rvp1 processes your Personal Data only where a valid lawful basis exists. Depending on the specific processing activity, we rely on one or more of the following legal grounds:

• Contractual Necessity: Processing is required to perform our contractual obligations to you as a registered rvp1 member — including account management, transaction processing, and customer support;
• Legal Obligation: Processing is necessary to comply with applicable anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and international gaming compliance standards. We are legally required to retain certain records and report suspicious activity to relevant authorities;
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, product improvement, and responsible gaming enforcement — provided these interests are not overridden by your fundamental rights and freedoms;
• Consent: Where required by applicable law, we will obtain your explicit consent before processing your Personal Data — particularly for direct marketing communications, non-essential cookies, and optional analytics. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

rvp1 uses your Personal Data for the following specific purposes:

6.1 Account Creation and Management

We use your registration data to create and maintain your rvp1 account, verify your identity, manage your account preferences, and provide access to all platform features. This includes processing your login credentials, managing your account balance, and maintaining your transaction and gaming history.

6.2 Identity Verification and KYC Compliance

We use your identity documents and verification data to comply with KYC obligations, confirm you are at least 21 years of age, verify that your payment methods belong to you, and detect and prevent fraudulent account registrations. This is a legal obligation we cannot waive.

6.3 Payment Processing

We use your financial data to process deposits and withdrawals via Indonesian bank transfers (BCA, BRI, BNI, Mandiri, and others) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja). All payment data is handled securely and is never stored on our servers in unencrypted form.

6.4 Fraud Prevention and Security

We analyze usage patterns, IP addresses, device fingerprints, and transaction data to detect suspicious activity, prevent unauthorized account access, identify potential money laundering, and protect both rvp1 and its members from fraud. This is a legitimate interest that benefits all users of the platform.

6.5 Customer Support

When you contact our support team, we use your account data and communication history to verify your identity, understand your issue, and provide accurate and efficient assistance. Support interactions are recorded for quality assurance and training purposes.

6.6 Responsible Gaming Monitoring

We monitor gaming activity and transaction patterns to identify potential signs of problem gambling, enforce self-exclusion and deposit limit settings, and proactively reach out to members who may need support. This processing is a core part of our responsible gaming commitment.

6.7 Marketing and Promotions

With your consent, we may use your contact details and platform preferences to send you information about bonuses, promotional offers, new game launches, and seasonal events relevant to the Indonesian market (such as Idul Fitri and Ramadhan promotions). You may withdraw marketing consent at any time via your account settings or by contacting support.

6.8 Platform Improvement and Analytics

We use aggregated and anonymized usage data to analyze how members interact with rvp1, identify technical issues, optimize game performance, and improve overall user experience. Analytics data is de-identified wherever possible and never sold to third parties.

7. Data Sharing and Disclosure

rvp1 does not sell, rent, or trade your Personal Data to any third party for commercial purposes. We may share your data only in the following strictly defined circumstances:

7.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process data on our behalf, subject to binding data processing agreements that require them to maintain the same level of data protection we apply. These include:

• Payment processing partners (banks, e-wallet providers, and payment gateways) — to facilitate deposits and withdrawals;
• Identity verification service providers — to assist with KYC document checks;
• Cloud hosting and infrastructure providers — to store platform data securely;
• Customer support platform providers — to manage live chat and ticketing systems;
• Email and SMS communication providers — to deliver transactional and marketing communications;
• Analytics and fraud detection providers — to monitor platform integrity and security.

7.2 Game Software Providers

Where necessary for the provision of specific games, limited technical data (such as session tokens and game round identifiers) may be shared with licensed game studios including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft. These providers do not receive personally identifiable information beyond what is technically necessary to render the game correctly.

7.3 Legal and Regulatory Disclosure

rvp1 may be required to disclose your Personal Data to law enforcement agencies, regulatory authorities, or courts of competent jurisdiction where required by law, court order, or regulatory direction. We will notify you of any such disclosure where legally permitted to do so.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of rvp1's assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy.

7.5 Consent-Based Disclosure

With your explicit prior consent, we may share your data with selected third parties for purposes you have specifically approved. You have the right to withdraw such consent at any time.

8. Data Retention

rvp1 retains your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. Our general retention periods are as follows:

Data Category	Retention Period	Reason
Account registration data	Duration of account + 5 years after closure	Contractual obligation, legal compliance
KYC identity documents	5 years after account closure	AML regulatory requirement
Financial transaction records	7 years after each transaction	Financial record-keeping requirements
Customer support records	3 years after last interaction	Dispute resolution, quality assurance
Marketing consent records	Until consent withdrawn + 2 years	Proof of consent compliance
Technical/session logs	12 months	Security monitoring, fraud detection

Upon expiration of the applicable retention period, Personal Data will be securely deleted or anonymized in a manner that prevents reconstruction of the original data.

9. Security Measures

rvp1 implements a comprehensive suite of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, alteration, or disclosure. Our security infrastructure includes:

9.1 Technical Safeguards

• SSL/TLS Encryption: All data transmitted between your browser and the rvp1 platform is encrypted using industry-standard SSL/TLS protocols (minimum TLS 1.2). Connections are validated by a trusted certificate authority;
• Data Encryption at Rest: Sensitive Personal Data, including KYC documents and financial records, is stored using AES-256 encryption on secure servers;
• Two-Factor Authentication (2FA): Members are encouraged and may be required to enable 2FA for account login, adding an additional layer of identity verification beyond the password;
• Firewall and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and continuous network monitoring;
• Regular Penetration Testing: rvp1 engages independent cybersecurity firms to conduct regular penetration tests and vulnerability assessments of the platform.

9.2 Organizational Safeguards

• Access to Personal Data is restricted on a strict need-to-know basis; only authorized personnel whose roles require access to specific data categories are granted that access;
• All rvp1 staff with access to Personal Data undergo regular data protection and security training;
• Internal data handling procedures are reviewed and updated at least annually;
• Data breaches are subject to an internal incident response protocol that includes impact assessment, containment, and user notification where required.

While we apply industry-leading security standards, no system is completely immune to cyber threats. In the event of a data breach that poses a significant risk to your rights and freedoms, rvp1 will notify affected users and relevant authorities in accordance with applicable data breach notification obligations.

10. Cookies and Tracking Technologies

rvp1 uses cookies and similar tracking technologies to enhance your experience on our platform, ensure the platform functions correctly, and gather analytical insights. A cookie is a small text file stored on your device by your web browser when you visit a website.

10.1 Types of Cookies We Use

• Essential Cookies: Required for core platform functionality, including user authentication (keeping you logged in), session management, and security features. These cookies cannot be disabled without disrupting platform operation;
• Performance and Analytics Cookies: Collect anonymized data about how visitors use the platform — which pages are visited most, how long sessions last, and where technical errors occur. This data helps us improve platform performance;
• Functional Cookies: Remember your preferences such as language settings, preferred deposit method, and display options to provide a more personalized experience;
• Marketing and Tracking Cookies: Where you have given consent, these cookies track your engagement with promotional content and allow us to measure the effectiveness of marketing campaigns. We do not use third-party advertising networks that track you across other websites.

10.2 Managing Cookies

You can control and manage cookies through your browser settings. Most modern browsers allow you to view, delete, and block cookies. Please note that disabling essential cookies will impair core platform functionality, including the ability to log in and place bets. Instructions for managing cookies are available in the help documentation of your specific browser.

11. Your Privacy Rights

As an rvp1 member, you hold the following rights with respect to your Personal Data. We are committed to honoring these rights promptly and without undue delay:

• Right of Access: You have the right to request a copy of all Personal Data rvp1 holds about you, along with information about how it is processed. We will respond to access requests within 30 days;
• Right to Rectification: If any of your Personal Data is inaccurate or incomplete, you have the right to request that we correct or update it. You can update basic profile information directly through your account settings;
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to overriding legal obligations (e.g., we cannot erase financial records we are legally required to retain);
• Right to Restriction of Processing: In certain circumstances (e.g., while a dispute over data accuracy is resolved), you may request that we temporarily restrict the processing of your data;
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you have the right to receive your Personal Data in a structured, machine-readable format and to request that it be transmitted to another service provider where technically feasible;
• Right to Object: You have the right to object to processing based on legitimate interests (including profiling) and to processing for direct marketing purposes. Marketing objections will be actioned immediately upon receipt;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact our Data Protection Team using the details in Section 15. We may need to verify your identity before processing your request. We will respond within 30 calendar days. In complex cases, this period may be extended by a further 60 days, in which case we will notify you of the extension and the reasons for it.

12. Children's Privacy

rvp1 strictly prohibits the use of its platform by anyone under 21 years of age. We do not knowingly collect Personal Data from individuals under the age of 21. Our registration process includes age verification steps and KYC procedures specifically designed to identify and reject underage applicants.

If we become aware that Personal Data belonging to a person under the age of 21 has been collected, we will take immediate steps to delete that data and close the associated account. If you believe a minor may be using an rvp1 account, please contact our support team immediately so we can investigate and act accordingly.

13. International Data Transfers

rvp1 operates infrastructure and engages service providers across multiple international jurisdictions. As a result, your Personal Data may be transferred to and processed in countries outside Indonesia. When such transfers occur, rvp1 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that applied within Indonesia, including:

• Contractual clauses with data processors that require equivalent data protection standards;
• Use of service providers located in jurisdictions with adequacy determinations or recognized data protection frameworks;
• Internal data transfer policies that require all group entities to apply consistent privacy standards.

By using the rvp1 platform, you acknowledge that your Personal Data may be transferred internationally for the purposes described in this Policy. If you have questions about the specific countries to which your data may be transferred, please contact our Data Protection Team.

14. Changes to This Privacy Policy

rvp1 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, platform features, or applicable laws. When we make changes, we will:

• Update the "Effective Date" at the top of this Policy;
• Post a prominent notice on the rvp1 platform for at least 14 days;
• Send an email notification to all registered members for material changes;
• Maintain an archive of prior versions of this Policy, available upon request.

Your continued use of the rvp1 platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your data.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way rvp1 handles your Personal Data, please contact our Data Protection Team through the following channels:

• Email: [email protected] — please mark your subject line as "Privacy Request" for prompt routing;
• Live Chat: Available 24/7 through the rvp1 platform — ask to be connected to the Data Protection Team;
• In-App Messaging: Submit a privacy inquiry directly through your member account dashboard.

Our Indonesian-speaking support agents are available around the clock and will direct your privacy inquiry to the appropriate team. We aim to acknowledge all privacy requests within 2 business days and resolve them fully within 30 calendar days.