Privacy Policy — rryy

1 Introduction

rryy ("we", "us", "our") operates an online betting platform serving customers primarily in Indonesia. We are committed to protecting your personal information and respecting your right to privacy. This Privacy Policy describes:

• What personal data we collect from users of the rryy platform.
• How we use, store, and protect that data.
• Your rights regarding your personal information.
• How to contact us with privacy-related questions or requests.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the platform. Where the Terms address contractual obligations, this Privacy Policy focuses specifically on data protection practices.

2 Data Controller

For the purposes of applicable data protection laws, rryy acts as the data controller for all personal information collected through the platform. This means rryy determines the purposes and means of processing your personal data and is responsible for ensuring compliance with relevant privacy regulations.

If you have questions about how rryy processes your data or wish to exercise your privacy rights, you can contact our Data Protection Officer at [email protected].

3 Information We Collect

rryy collects several categories of personal data to provide our services, comply with legal obligations, and ensure platform security. The types of information we collect include:

3.1 Account Registration Information

When you create an account on rryy, we collect:

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify you are at least 21 years of age)
• Indonesian National Identity Number (NIK) or passport number
• Email address (for account communication and verification)
• Mobile phone number (for account security and two-factor authentication)
• Residential address (for KYC verification and regulatory compliance)
• Username and password (for account access)

3.2 Identity Verification (KYC) Documents

To comply with anti-money laundering regulations and verify your identity before processing withdrawals, we collect:

• Copies of government-issued identification documents (KTP, passport)
• Proof of address documents (utility bills, bank statements dated within the last 3 months)
• Selfie photographs holding your ID document (when additional verification is required)
• Proof of payment method ownership (screenshots showing your name on BCA, BRI, BNI, Mandiri, or e-wallet accounts)

3.3 Financial and Transaction Data

We collect information related to your financial activity on the platform, including:

• Deposit and withdrawal transaction histories (amounts, dates, payment methods used)
• Bank account details and e-wallet account identifiers (for processing payouts)
• Betting history (stakes, odds, outcomes, timestamps)
• Bonus claims and rollover progress
• Balance fluctuations and account activity summaries

3.4 Technical and Usage Data

When you access rryy, we automatically collect certain technical information, including:

• IP address and approximate geographic location
• Device information (device type, operating system, browser type and version)
• Session duration and timestamps
• Pages viewed, features used, and clickstream data
• Referral source (how you found rryy)
• Connection type and internet service provider

3.5 Communications and Support Interactions

When you contact rryy customer support or communicate with us via email, live chat, or other channels, we collect and store:

• The content of your messages and inquiries
• Support ticket histories and resolution notes
• Feedback and survey responses
• Any attachments or documents you provide to support staff

4 How We Use Your Personal Data

rryy processes your personal information for the following purposes:

4.1 To Provide and Operate the Platform

• Create and manage your account
• Process deposits, withdrawals, and betting transactions
• Display your account balance, betting history, and transaction records
• Apply bonuses and promotional offers to your account
• Maintain accurate records of your gaming activity

4.2 To Verify Identity and Comply With Legal Obligations

• Conduct Know Your Customer (KYC) identity verification
• Verify that you are at least 21 years of age
• Comply with anti-money laundering (AML) regulations
• Detect and prevent fraud, money laundering, and other financial crimes
• Report suspicious activity to relevant authorities when legally required
• Respond to valid legal requests from law enforcement or regulatory bodies

4.3 To Ensure Platform Security and Prevent Abuse

• Detect and prevent unauthorized account access
• Identify multiple or duplicate accounts operated by the same individual
• Monitor for collusion, bonus abuse, and other violations of our Terms & Conditions
• Protect against technical attacks such as DDoS, SQL injection, and credential stuffing
• Investigate and resolve disputes related to account activity

4.4 To Communicate With You

• Send account-related notifications (deposit confirmations, withdrawal status updates, KYC requests)
• Provide customer support and respond to your inquiries
• Send promotional offers, bonus announcements, and platform updates (you may opt out of marketing communications at any time)
• Notify you of changes to our Terms & Conditions or Privacy Policy

4.5 To Improve Our Services

• Analyze platform usage patterns to identify popular games, features, and betting markets
• Conduct internal research and analytics to improve user experience
• Test new features and optimize platform performance
• Develop responsible gaming tools and interventions based on player behavior patterns

5 Legal Basis for Processing Your Data

Under applicable data protection laws, rryy must have a lawful basis for collecting and processing your personal information. We rely on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations to you under the Terms & Conditions (e.g., operating your account, processing transactions).
• Legal Obligation: Processing is required to comply with Indonesian and international laws, including KYC, AML, and financial crime prevention regulations.
• Legitimate Interests: Processing is necessary for rryy's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests do not override your fundamental rights and freedoms.
• Consent: For certain processing activities, such as sending marketing communications or using non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

6 Data Sharing & Third-Party Disclosure

rryy does not sell or rent your personal data to third parties for marketing purposes. However, we may share your information in the following limited circumstances:

6.1 Payment Processors and Financial Institutions

To process deposits and withdrawals, we share necessary payment information (account details, transaction amounts) with:

• Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata)
• E-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Third-party payment gateway services that facilitate transactions on our behalf

6.2 Identity Verification Partners

We work with specialized KYC verification providers to authenticate identity documents and perform AML screening. These partners receive copies of your ID documents and personal information solely for verification purposes and are contractually bound to protect your data.

6.3 Game Providers and Platform Partners

rryy integrates games from third-party providers including Pragmatic Play, Evolution Gaming, Spribe, NetEnt, Microgaming, and others. When you play a game, certain data (user ID, bet amounts, game outcomes) is shared with the relevant provider to operate the game. These providers process data under their own privacy policies and are bound by confidentiality obligations.

6.4 Legal and Regulatory Authorities

We may disclose your personal data to law enforcement agencies, regulatory bodies, or courts when:

• Required by law, regulation, or court order
• Necessary to report suspected money laundering or financial crime
• Needed to protect rryy's legal rights or comply with legal proceedings
• Required to respond to valid governmental requests or investigations

6.5 Business Transfers

In the event of a merger, acquisition, sale of assets, or corporate restructuring involving rryy, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

7 Data Retention Periods

rryy retains your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal and regulatory obligations. Specific retention periods include:

• Account and Profile Information: Retained for the duration of your active account plus 5 years after account closure (required by AML regulations).
• Transaction Records: Retained for a minimum of 7 years after the transaction date (required by financial regulations and tax law).
• KYC Documents: Retained for 5 years after account closure or the last transaction, whichever is later.
• Betting History: Retained for 3 years to support dispute resolution and responsible gaming monitoring.
• Communications and Support Tickets: Retained for 2 years after the last interaction.
• Technical Logs (IP addresses, session data): Retained for 90 days unless required for investigation of fraud or Terms violations.

After the applicable retention period expires, personal data is securely deleted or anonymized in accordance with our data disposal procedures. You may request early deletion of certain data categories; however, we cannot delete information that must be retained for legal or regulatory compliance.

8 Security Measures

rryy implements industry-standard technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security practices include:

8.1 Encryption

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• Encryption of sensitive data at rest in our databases
• Secure hashing of passwords (passwords are never stored in plain text)

8.2 Access Controls

• Strict role-based access controls limiting employee access to personal data on a need-to-know basis
• Multi-factor authentication (MFA) for administrative accounts and sensitive operations
• Regular access reviews and immediate revocation of access for departed employees

8.3 Infrastructure Security

• Secure, certified data centers with physical security controls
• Firewall protection and intrusion detection systems
• Regular security vulnerability scans and penetration testing
• DDoS mitigation and network monitoring

8.4 Incident Response

• Dedicated incident response team to address security breaches
• Data breach notification procedures compliant with applicable laws (affected users will be notified within 72 hours of a confirmed breach)
• Regular security audits conducted by independent third parties

While we employ robust security measures, no system is entirely immune to attack. We cannot guarantee absolute security but remain committed to maintaining the highest standards of data protection.

9 Your Privacy Rights

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

9.1 Right of Access

You have the right to request a copy of the personal data rryy holds about you. We will provide this information in a structured, commonly used, and machine-readable format within 30 days of your request.

9.2 Right to Rectification

If any of your personal information is inaccurate or incomplete, you have the right to request correction. You can update most account information directly through your account settings or by contacting support.

9.3 Right to Erasure ("Right to Be Forgotten")

You may request deletion of your personal data. However, this right is subject to legal retention requirements (e.g., AML regulations require us to retain transaction records for 7 years). We will delete all non-required data upon request and anonymize data that must be retained for compliance purposes.

9.4 Right to Restrict Processing

You may request that we limit how we use your data while you contest its accuracy, challenge the lawfulness of processing, or need the data preserved for legal claims.

9.5 Right to Data Portability

You have the right to receive your personal data in a portable format and transmit it to another service provider where technically feasible.

9.6 Right to Object

You may object to processing based on legitimate interests or direct marketing. Upon objection to marketing, we will immediately cease such processing. For other objections, we will assess whether our legitimate interests override your rights.

9.7 Right to Withdraw Consent

Where processing is based on consent (e.g., marketing communications, non-essential cookies), you may withdraw consent at any time. This does not affect the lawfulness of processing conducted before withdrawal.

9.8 How to Exercise Your Rights

To exercise any privacy right, contact our Data Protection Officer at [email protected] with the subject line "Privacy Rights Request". We will respond within 30 days and may request identity verification to prevent fraudulent requests.

10 Cookies & Tracking Technologies

rryy uses cookies and similar tracking technologies to provide, secure, and improve our platform. Cookies are small text files stored on your device that help us recognize you and remember your preferences.

10.1 Types of Cookies We Use

• Essential Cookies: Required for the platform to function (e.g., maintaining login state, processing transactions). These cannot be disabled.
• Performance and Analytics Cookies: Collect anonymous data on how users interact with rryy to help us improve the platform (e.g., Google Analytics).
• Functional Cookies: Remember your preferences such as language, region, and display settings.
• Targeting/Advertising Cookies: rryy does not currently use third-party advertising cookies. If this changes, you will be notified and given the option to opt out.

10.2 Managing Cookies

You can control and delete cookies through your browser settings. Note that disabling essential cookies may impair platform functionality. For more information on managing cookies, visit your browser's help documentation.

11 International Data Transfers

rryy's servers and data centers are located in jurisdictions outside Indonesia. When you use our platform, your personal data may be transferred to and processed in countries that may have different data protection laws than Indonesia. In all cases, we ensure that appropriate safeguards are in place, including:

• Standard contractual clauses approved by data protection authorities
• Data processing agreements with all third-party service providers
• Technical and organizational security measures equivalent to those described in this policy

By using rryy, you consent to the transfer of your data to these international locations under the protections described above.

12 Protection of Minors

rryy is an adults-only service. We do not knowingly collect personal information from individuals under the age of 21. All users must verify they are at least 21 years old during account registration. If we discover that we have inadvertently collected data from a minor, we will:

• Immediately suspend the account
• Delete all personal data associated with that account
• Return any deposited funds to the source payment method
• Report the incident to relevant authorities if legally required

Parents or guardians who believe their child has provided personal information to rryy should contact us immediately at [email protected].

13 Changes to This Privacy Policy

rryy reserves the right to update this Privacy Policy to reflect changes in our data practices, legal requirements, or platform features. When material changes are made, we will:

• Update the "Last Updated" date at the top of this document
• Notify registered users via email and/or a prominent notice on the homepage
• Provide a reasonable notice period (typically 14 days) before the updated policy takes effect

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. Your continued use of rryy after the effective date of an updated policy constitutes acceptance of the changes.

14 Contact Our Privacy Team

For questions, concerns, or requests regarding this Privacy Policy or how rryy handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 via the platform
• Response Time: We aim to respond to all privacy inquiries within 48 hours

If you are not satisfied with our response to a privacy concern, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.