Privacy Policy — qq338 Data Commitment

This Privacy Policy ("Policy") describes how qq338 ("qq338", "we", "us", "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you", "your", "Player") who access or use the qq338 online gaming platform at https://qq338.ws and all associated sub-domains and mobile interfaces.

qq338 is committed to handling your personal data with the highest standards of transparency, integrity, and security. This Policy is written in plain, professional English so that every Player — whether based in Jakarta, Surabaya, Bali, Medan, or anywhere else across the Indonesian archipelago — can clearly understand how their information is managed.

By registering an account, depositing funds, placing wagers, or otherwise using any part of the qq338 platform, you acknowledge that you have read, understood, and accepted this Privacy Policy in full. This Policy should be read in conjunction with qq338's Terms & Conditions, which govern the overall contractual relationship between you and qq338.

If you do not agree with any part of this Policy, you must discontinue use of the qq338 platform immediately and contact support to arrange account closure.

For the purposes of applicable data protection law, qq338 acts as the data controller in respect of the personal data it processes about Players. As data controller, qq338 determines the purposes for which and the means by which your personal data is processed.

qq338 operates under an international gaming license and is subject to the data protection obligations imposed by the licensing jurisdiction's applicable law. While Indonesian domestic law continues to evolve in the area of personal data protection, qq338 voluntarily applies internationally recognized data protection standards — including principles broadly aligned with the General Data Protection Regulation (GDPR) framework — to all personal data it processes, regardless of where the data subject is located.

For all data protection inquiries and formal requests, the qq338 Data Protection contact is reachable at:

• Email: support at qq338 dot ws (subject line: "Data Protection Request")
• Live Chat: Available 24/7 on the qq338 platform — select "Data & Privacy" from the support menu.
• Response commitment: All data protection requests acknowledged within 48 hours; substantively resolved within 30 calendar days.

qq338 collects personal data through three primary channels: information you provide directly, information generated through your use of the platform, and information received from third parties in connection with payment processing and identity verification. The specific categories are as follows:

3.1 Data You Provide Directly

3.2 Data Generated by Your Use of the Platform

• Transaction records: Deposit amounts, withdrawal amounts, wager amounts, game outcomes, bonus claims, and wallet balance history — all denominated in IDR.
• Gaming activity logs: Game sessions entered, bet types placed (sports, togel (Indonesia's traditional numbers lottery), slot gacor, live casino), session start/end times in WIB, and RNG outcome records.
• Device and technical data: IP address, device type (mobile/desktop), operating system, browser type and version, screen resolution, and session duration.
• Behavioral and navigation data: Pages visited within qq338, features accessed, promotional offers viewed, and in-platform search queries — collected solely for fraud detection and platform optimization purposes.
• Location data: Country and approximate city-level location inferred from IP address (e.g., Jakarta, Surabaya, Bali) — used for regulatory geo-fencing and fraud prevention. qq338 does not collect precise GPS location data.

3.3 Data Received from Third Parties

• Payment processor confirmations: Transaction reference numbers, payment status (success/pending/failed), and account name matching data received from Indonesian banking partners and e-wallet providers.
• Identity verification services: Where qq338 uses an automated KYC screening service to cross-reference submitted identity documents against fraud and sanctions databases, the result of that check (pass/refer/fail) is retained in association with your account record.
• Game providers: Aggregated session data from licensed game providers (Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft, and others) in the form of standardized transaction logs — used to reconcile wallet balances and resolve any disputed game outcomes.

qq338 uses the personal data described in Section 3 for the following specific, defined purposes. We do not use your data for any purpose that is incompatible with the purposes listed below without first obtaining your explicit consent:

• Account creation and management: To register your player account, authenticate your identity at login (including OTP verification), maintain your wallet balance, and provide access to all qq338 Services.
• Transaction processing: To process deposits from and withdrawals to your nominated IDR bank account or e-wallet, credit winnings, apply bonus funds, and maintain an accurate transaction history within your account dashboard.
• KYC and regulatory compliance: To verify your identity and age (21+ requirement), screen against applicable sanctions lists, satisfy our anti-money-laundering obligations, and comply with the terms of qq338's international gaming license.
• Fraud prevention and platform security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, bonus abuse, collusion, and any other form of Prohibited Conduct as defined in the qq338 Terms & Conditions.
• Customer support: To respond to your inquiries, resolve complaints, manage account disputes, and maintain a record of all support interactions for quality assurance and audit purposes.
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling behavior, enforce self-imposed limits and self-exclusion requests, and contact players where qq338's responsible gaming systems identify a potential concern — in accordance with our Responsible Gaming policy.
• Platform improvement: To analyze aggregated, anonymized usage data and identify opportunities to improve the qq338 platform, fix technical issues, and optimize the user experience for players across Indonesia.
• Legal and regulatory obligations: To comply with lawful orders from competent courts or regulatory authorities, respond to legal proceedings, and protect qq338's legitimate legal interests.
• Promotional communications (with consent only): Where you have opted in to receive marketing communications, to send you information about qq338 promotions, bonuses, seasonal offers (such as Idul Fitri or Indonesian Independence Day specials), and new product launches. You may opt out at any time.

qq338 processes your personal data only where a lawful basis for doing so exists. The following table sets out the legal basis relied upon for each major processing activity:

qq338 does not sell your personal data. We share personal data with third parties only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose:

• Payment processors and banking partners: We share your name, payment account details, and transaction amount with the Indonesian bank or e-wallet provider you use (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, DANA, GoPay, ShopeePay, LinkAja) solely to execute deposit and withdrawal instructions. These parties are independent data controllers for the transactions they process under their own applicable privacy terms.
• Licensed game providers: We share a pseudonymous player session token (not your real name or contact details) with our licensed game providers (including Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft, and Microgaming) to facilitate game sessions and settle results in real time. Game providers receive no payment data or KYC documents.
• KYC and screening service providers: Where qq338 uses an automated identity verification or sanctions screening provider, your submitted identity documents and/or identity data are shared with that provider solely for the purpose of conducting the verification check. All such providers are contractually bound to process this data only for the specified purpose and to maintain equivalent security standards.
• IT infrastructure and hosting providers: qq338's platform is hosted on secure data center infrastructure. The hosting provider processes server-level data (including log files containing IP addresses) as a data processor acting under qq338's instructions. Hosting providers do not have access to player account data beyond what is required to maintain server operation.
• Legal and regulatory authorities: qq338 may disclose personal data where required to do so by a valid court order, regulatory directive, subpoena, or other lawful legal process. Where legally permissible, qq338 will notify the affected Player of such a disclosure request prior to compliance.
• Corporate transactions: In the event of a merger, acquisition, or sale of qq338's business or assets, Player data may be transferred to the acquiring entity as part of that transaction. Affected Players will be notified in advance of any such transfer, and the acquiring entity will be required to honor the terms of this Privacy Policy.

qq338 uses cookies and similar local storage technologies on its platform. Cookies are small text files placed on your device by your browser when you visit the qq338 website. They serve a number of important functions as described in the table below:

qq338 does not deploy advertising cookies, social media tracking pixels, cross-site behavioral tracking cookies, or any cookie technology that shares your browsing data with advertising networks or social platforms. The qq338 platform contains no third-party advertising.

You may manage cookie preferences for functional and analytics categories within your qq338 account settings. Disabling strictly necessary or security cookies by adjusting your browser settings may result in platform login failures or reduced security protection — qq338 cannot guarantee platform functionality under those conditions.

qq338 retains personal data only for as long as is necessary to fulfill the purpose for which it was collected, or as required by applicable law and our licensing obligations. The following retention periods apply:

• Active account data: Retained for the full duration of your account's active status plus a minimum of five (5) years following account closure, in accordance with anti-money-laundering record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later — as required under applicable anti-money-laundering and counter-terrorism-financing regulations.
• Transaction records: All deposit, withdrawal, wager, and bonus transaction records are retained for a minimum of five (5) years from the date of the transaction to support audit, regulatory, and dispute resolution requirements.
• Support communications: Live chat transcripts and email correspondence are retained for three (3) years from the date of the interaction, or for the duration of any unresolved complaint, whichever is later.
• Marketing consent records: Records of your opt-in consent to receive marketing communications are retained for the lifetime of your account plus two (2) years following account closure, as evidence of lawful marketing activity.
• Technical and security logs: Server access logs, IP address logs, and fraud detection system event logs are retained for twelve (12) months, after which they are securely deleted unless retained as evidence in connection with an active security investigation.
• Data following account closure: Upon voluntary account closure, qq338 will anonymize or delete all personal data that is not subject to a mandatory retention obligation within ninety (90) days of the closure date. Data subject to mandatory retention (primarily KYC and transaction records) will be retained in a restricted, access-controlled archive for the applicable retention period and then permanently deleted.

qq338 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include but are not limited to:

• Encryption in transit: All data transmitted between your browser or mobile device and the qq338 platform is encrypted using 256-bit TLS (Transport Layer Security). Our domain enforces HTTPS-only connections; unencrypted HTTP requests are automatically redirected.
• Encryption at rest: Personal data stored in qq338's databases — including KYC documents, financial records, and account credentials — is encrypted at rest using AES-256 symmetric encryption.
• Password hashing: Player passwords are never stored in plaintext. qq338 uses industry-standard adaptive hashing algorithms (bcrypt or equivalent) with per-account salts. Even qq338's own system administrators cannot retrieve your plaintext password.
• OTP two-factor authentication: All withdrawal requests and sensitive account changes (password reset, registered payment method update) require OTP verification to the registered Indonesian mobile number before the action is executed.
• Access controls: Access to personal data within qq338's internal systems is granted on a strict need-to-know basis. All staff with access to personal data operate under binding confidentiality obligations. Access privileges are reviewed quarterly.
• Intrusion detection and monitoring: qq338's infrastructure is monitored continuously for anomalous access patterns, unauthorized login attempts, and data exfiltration indicators using automated intrusion detection systems and 24/7 security operations oversight.
• Regular security assessments: qq338 conducts periodic security assessments and penetration tests of its platform. Identified vulnerabilities are prioritized and remediated in accordance with a formal vulnerability management program.
• Data breach response: In the event of a confirmed personal data breach, qq338's incident response plan requires containment within two (2) hours, internal notification within twenty-four (24) hours, and affected-player notification within seventy-two (72) hours of the breach being identified.

As a qq338 player, you hold the following rights in respect of your personal data. These rights may be exercised at any time by contacting qq338's support team using the contact details in Section 14:

To exercise any of the above rights, contact qq338 support with the subject line "Data Rights Request — [Your Account Username]". qq338 will respond within thirty (30) calendar days. Where a request is complex or numerous, this period may be extended by a further sixty (60) days, in which case qq338 will notify you of the extension and the reason within the initial thirty-day period.

qq338 will not charge a fee for handling data rights requests unless a request is manifestly unfounded or excessive — in which case qq338 reserves the right to charge a reasonable administrative fee or decline to act on the request, with written reasons provided.

qq338 is strictly an adults-only platform. Players must be at least 21 years of age to register an account, deposit funds, or place any wager on the qq338 platform. This requirement applies to all players regardless of their location within Indonesia or internationally.

qq338 does not knowingly collect, process, or retain personal data belonging to individuals under the age of 21. Age verification is conducted as part of the KYC process, which requires submission of a valid government-issued identity document (such as an Indonesian KTP or passport) confirming date of birth. Where the identity document submitted indicates that the account holder is under 21 years of age, the account will be immediately suspended and any funds held will be returned via the depositing payment channel.

If qq338 discovers — whether through the KYC process, a support inquiry, or any other means — that an account is held by or has been used by a person under the age of 21, qq338 will:

• Immediately suspend the account and block all further access.
• Delete all personal data associated with the account as promptly as permitted by applicable law — acknowledging that certain records may be subject to mandatory retention obligations.
• Return any net deposited funds (less any amounts that cannot legally be returned) to the depositing payment source.
• Report the incident to the relevant licensing authority as required by qq338's licensing conditions.

If you are a parent or guardian and believe that a minor in your care has registered an account with qq338, please contact our support team immediately at support at qq338 dot ws with the subject line "Minor Account Report". All such reports are handled with absolute priority and strict confidentiality.

qq338 operates as an internationally licensed platform. As a result, personal data collected from players in Indonesia may be transferred to, stored in, and processed in countries outside Indonesia — specifically in the jurisdictions where qq338's infrastructure is hosted and where its licensing authority is located.

When qq338 transfers personal data internationally, it ensures that appropriate safeguards are in place to protect your data in the receiving jurisdiction. These safeguards include:

• Contractual protections: Data processing agreements with all international data processors that include data protection clauses equivalent in effect to standard contractual clauses recognized under leading international data protection frameworks.
• Equivalent security standards: International processing partners are required to maintain technical and organizational security measures at least equivalent to those described in Section 9 of this Policy.
• Purpose limitation: International processors are strictly prohibited from using transferred data for any purpose other than the specific contracted service they provide to qq338.
• Data minimization in transfer: Only the minimum data necessary for the international processing activity is transferred — for example, pseudonymous session tokens rather than real names are shared with game providers, regardless of where those providers are located.

By registering and using qq338, you acknowledge that your personal data may be transferred to and processed in international jurisdictions as described in this section, and you consent to such transfers where required by applicable law.

qq338 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, platform features, applicable law, or licensing obligations. The "Last Updated" date at the top of this page will be revised whenever a material change is made.

When material changes are made to this Policy — particularly changes that affect the purposes for which your data is used, the categories of third parties with whom it is shared, or your data rights — qq338 will notify registered players by posting a prominent notice on the platform homepage and, where practicable, sending an email notification to your registered address.

Your continued use of the qq338 platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any change to this Policy, you must cease using the platform and contact support to arrange account closure.

qq338 recommends that all players review this Privacy Policy periodically — at minimum once every six months — to remain informed of how their personal data is managed. Previous versions of this Privacy Policy are available on request from the qq338 support team.

If you have any questions, concerns, or formal complaints regarding this Privacy Policy or qq338's handling of your personal data, or if you wish to exercise any of your data rights as described in Section 10, please contact qq338's Data Protection team through any of the following channels:

• Email: support at qq338 dot ws — use the subject line "Data Protection Request" or "Privacy Complaint" as appropriate. Our team aims to acknowledge all data-related emails within 48 hours.
• Live Chat: Available directly on the qq338 platform, 24 hours a day, 7 days a week — including all Indonesian public holidays such as Idul Fitri, Nyepi, and Indonesian Independence Day (17 August). Select "Data & Privacy" from the support menu to route your inquiry to the appropriate team.
• Support hours: 00:00 – 24:00 WIB, every day of the year.

For formal privacy complaints, please provide the following information in your submission to help qq338 investigate and resolve your complaint efficiently:

• Your qq338 account username.
• A clear description of the data processing activity you are concerned about.
• The specific right you wish to exercise or the specific outcome you are seeking.
• Any supporting documentation or evidence relevant to your complaint.

qq338 commits to acknowledging all formal privacy complaints within twenty-four (24) hours and providing a substantive written response within thirty (30) calendar days. If you are not satisfied with qq338's response to your complaint, you have the right to escalate the matter to a competent supervisory authority or seek independent legal advice in your jurisdiction.