Privacy Policy — q1221

q1221 ("we", "us", "our") operates the online gaming platform accessible at https://q1221.one (the "Platform"). We are committed to protecting the privacy and personal data of every individual who accesses, registers on, or otherwise interacts with the Platform. This Privacy Policy sets out in clear, plain terms what personal data we collect, why we collect it, how we use and protect it, and what rights you have in relation to it.

This Policy applies to all users of the Platform, including registered Players and unregistered visitors browsing the site. It covers data collected through the Platform's website, any associated mobile-optimised interfaces, customer support channels (live chat and email), and any promotional communications you receive from q1221.

By accessing the Platform or registering an Account, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform immediately. This Privacy Policy is to be read alongside our Terms & Conditions, which are available at q1221.one/terms-conditions.

For the purposes of this Privacy Policy, the following terms carry the meanings defined below:

• "Personal Data" means any information that identifies or can reasonably be used to identify a living natural person, directly or indirectly, including but not limited to a name, identification number, location data, email address, phone number, or IP address.
• "Processing" means any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
• "Controller" means q1221, the entity that determines the purposes and means of processing Personal Data collected through the Platform.
• "Processor" means any third-party service provider that processes Personal Data on behalf of q1221, under a binding data processing agreement, for specific and limited purposes.
• "Player" or "you" means any registered account holder or unregistered visitor who accesses or uses the Platform.
• "KYC Data" means the identity verification documentation and associated Personal Data submitted by a Player for the purpose of Know Your Customer verification, including government-issued identification, proof of address, and payment method confirmation.
• "Cookies" means small text files placed on your device by the Platform to facilitate session management, analytics, and personalisation.
• "Sensitive Data" means Personal Data warranting enhanced protection, including financial account details, identity document numbers, and any data that could reveal information about a person's health, beliefs, or other protected characteristics.

q1221 collects Personal Data in the following categories. We collect only the minimum data necessary for each stated purpose:

We do not knowingly collect special category data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, biometric data used for identification, or health data beyond what is strictly necessary for responsible gaming assessments requested by the Player themselves.

q1221 collects Personal Data through the following methods:

• Direct Submission: Data you provide when registering an Account, completing KYC verification, making a deposit or withdrawal request, contacting support, or responding to a promotional offer.
• Automated Technical Collection: Data collected automatically when you access the Platform, including IP address, device identifiers, browser characteristics, and session-level behavioural data, via server logs, cookies, and similar tracking technologies.
• Payment Processors: Transaction confirmation data received from local bank systems (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI, OCBC NISP) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to verify and reconcile deposit and withdrawal transactions.
• KYC Verification Partners: Where q1221 uses a regulated third-party identity verification service to authenticate KYC documents, that partner may return verification status data to q1221. We do not receive raw document images back from the partner beyond what you originally submitted.
• Fraud Prevention Partners: Aggregated risk-scoring signals from our fraud-prevention service providers, used solely to detect and prevent account takeover, multi-account abuse, and financial fraud on the Platform.

q1221 uses the Personal Data we hold for the following purposes. Each use is tied to a specific legal basis described in Clause 6:

1. Account Management: Creating, maintaining, and administering your Player account, including processing login authentication, account preferences, and responsible gaming settings.
2. Identity & Age Verification: Confirming that you are at least 21 years of age and are the legitimate owner of the payment methods associated with your account, as required by our responsible gaming obligations and anti-money-laundering procedures.
3. Payment Processing: Facilitating deposits and withdrawals via your chosen Indonesian bank or e-wallet, verifying transaction ownership, and reconciling balances.
4. Fraud & Security: Detecting, investigating, and preventing fraudulent activity, account takeover, multi-account abuse, money-laundering, and other prohibited conduct as defined in our Terms & Conditions.
5. Responsible Gaming: Monitoring account activity to identify potential problem gambling patterns, applying player-requested limits and self-exclusion orders, and providing mandatory responsible gaming interventions where warranted.
6. Customer Support: Responding to your enquiries, resolving disputes, processing complaints, and maintaining a record of support interactions for quality assurance and regulatory audit purposes.
7. Platform Personalisation: Tailoring your experience on the Platform — including game recommendations, promotional offers, and content display — based on your gaming history and stated preferences, where you have not opted out of personalisation.
8. Promotional Communications: Sending you promotional offers, bonus announcements, seasonal promotions (including those tied to Idul Fitri, Ramadhan, and Indonesian Independence Day), and product updates, where you have provided valid marketing consent.
9. Analytics & Improvement: Aggregating and analysing usage data to understand how Players navigate the Platform, identify technical issues, and improve the overall product experience.
10. Legal & Regulatory Compliance: Meeting our obligations under applicable international gaming regulations, anti-money-laundering frameworks, and any lawful request from a competent regulatory authority.

q1221 processes Personal Data on the following legal grounds, consistent with internationally recognised data protection principles:

• Contractual Necessity: Processing required to perform our contract with you — i.e., operating your account, processing payments, and delivering the gaming services you have subscribed to.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including anti-money-laundering obligations, KYC verification mandates, and responsible gaming regulatory requirements imposed by our international gaming licence.
• Legitimate Interests: Processing carried out in pursuit of q1221's legitimate business interests, including fraud detection, Platform security, product analytics, and customer support quality assurance — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, informed, specific, and unambiguous consent — primarily for marketing communications and for any non-essential personalisation features. You may withdraw consent at any time without penalty, as described in Clause 11.

q1221 may share your Personal Data with the following categories of recipients, always under appropriate contractual safeguards:

• Payment Processors: Local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), to the extent necessary to process your deposit and withdrawal transactions.
• KYC & Identity Verification Vendors: Regulated third-party identity verification services engaged to authenticate KYC documents. These vendors act as Processors under binding data processing agreements and are prohibited from using your data for any purpose beyond identity verification on q1221's behalf.
• Fraud Prevention & Security Providers: Specialist fraud-detection and cybersecurity firms that assist q1221 in identifying and preventing prohibited conduct on the Platform.
• Game Studio Partners: Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive anonymised session identifiers necessary to deliver certified game content. These partners do not receive your full name, national ID, or financial account details.
• Regulatory Authorities: Competent gaming regulatory authorities, law enforcement agencies, or courts, where disclosure is required by law, a valid regulatory order, or a court judgment. q1221 will, where legally permissible, notify you of such a disclosure request prior to complying.
• Professional Advisers: External legal counsel, auditors, and compliance consultants engaged to advise q1221 on regulatory matters, subject to professional confidentiality obligations.
• Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of q1221's business, your Personal Data may be transferred to the successor entity. You will be notified of any such transfer and of any material changes to privacy practices that result from it, with at least 30 days' advance notice.

q1221 uses cookies and similar tracking technologies to deliver a functional, secure, and personalised Platform experience. The following categories of cookies are in use:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication tokens, security cookies, and load-balancing identifiers. They cannot be disabled without breaking core Platform functionality.
• Analytical / Performance Cookies: Used to measure how Players navigate the Platform — which pages are visited most, where errors occur, and how quickly pages load. Data collected is aggregated and anonymised where possible. These cookies help q1221 continuously improve Platform performance.
• Functional Cookies: Remember your preferences — such as your last-visited game category, preferred deposit method, and language or display settings — to deliver a more personalised browsing experience on return visits.
• Marketing / Targeting Cookies: Used only where you have given explicit consent. These cookies track your interaction with promotional content and allow q1221 to deliver more relevant offers. You may withdraw consent for marketing cookies at any time via your account preferences.

Most web browsers allow you to manage cookie preferences through their settings. Disabling strictly necessary cookies will impair your ability to log in and use core Platform features. Disabling analytical or marketing cookies will not affect your ability to use the Platform but may result in less personalised promotional content.

q1221 does not use cross-site tracking technologies to monitor your behaviour on third-party websites not affiliated with the Platform.

q1221 retains Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable regulatory obligations. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents reconstruction of the original data. Where anonymisation is not technically feasible, data is securely destroyed using industry-standard methods.

q1221 implements a multi-layered security framework to protect Personal Data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your browser and our servers is encrypted using TLS 1.2 or higher. Our Platform is served exclusively over HTTPS.
• Encryption at Rest: Sensitive Personal Data and financial records stored in our databases are encrypted using AES-256 or equivalent encryption standards.
• Access Controls: Access to Personal Data within q1221 is restricted on a strict need-to-know basis. Staff access is governed by role-based permissions, and all access to sensitive data is logged and audited.
• Two-Factor Authentication: Administrative access to data management systems requires multi-factor authentication.
• Penetration Testing: q1221 engages independent security firms to conduct periodic penetration testing of the Platform's infrastructure and web application layer.
• Incident Response: q1221 maintains a documented data breach response procedure. In the event of a confirmed data breach that poses a risk to your rights and freedoms, we will notify affected Players without undue delay and in accordance with our regulatory obligations.

While q1221 takes all reasonable technical and organisational measures to secure your data, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. You are responsible for keeping your account password confidential and for using a strong, unique password that is not shared across other services.

As a Player whose Personal Data is processed by q1221, you have the following rights:

• Right of Access: You may request a copy of all Personal Data q1221 holds about you, along with information about how it is used and with whom it has been shared.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data we hold. For registration details, many fields can be updated directly within 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 purpose for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where processing is unlawful. This right is subject to overriding legal obligations — for example, AML regulations require us to retain certain financial records for a minimum period regardless of an erasure request.
• Right to Restrict Processing: You may request that q1221 temporarily restrict the processing of your Personal Data in certain circumstances — for example, where you contest the accuracy of the data or have objected to processing pending a determination of q1221's legitimate grounds.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, and is carried out by automated means, you may request that your Personal Data be provided to you in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on q1221's legitimate interests at any time. You may also object to processing for direct marketing purposes at any time, with no requirement to provide justification — q1221 will cease marketing communications immediately upon receipt of a valid objection.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
• Right Not to be Subject to Automated Decisions: q1221 does not make any decisions with legal or similarly significant effects on Players based solely on automated processing of Personal Data without human review. Where automated systems flag an account for investigation (e.g., fraud detection), a human review is conducted before any material account action is taken.

If q1221 becomes aware that Personal Data has been collected from an individual under 21 years of age, we will take immediate steps to delete that data and close the associated account, regardless of whether a deposit has been made. Any balance held in such an account will be dealt with in accordance with our Terms & Conditions and applicable regulatory guidance.

If you believe that a minor has registered an account on the Platform, please contact our support team immediately via live chat or email. Reports of underage access are treated as a high-priority matter and investigated without delay.

q1221 operates internationally, and your Personal Data may be transferred to and processed in countries other than Indonesia. These countries may not have data protection laws equivalent in scope to those you may be accustomed to. Where such transfers occur, q1221 ensures that appropriate safeguards are in place to protect your data, including:

• Standard contractual clauses approved by recognised data protection regulators, incorporated into agreements with all Processors located outside Indonesia.
• Binding corporate rules or equivalent data transfer mechanisms for transfers within q1221's group of related entities.
• Transfer only to jurisdictions that have been assessed as providing an adequate level of data protection, or to organisations that have agreed to equivalent contractual protections.

You may request details of the specific transfer mechanisms in place for any particular international transfer of your data by contacting our support team as described in Clause 16.

The Platform may contain references to third-party game studios and payment service providers whose services are integrated into the q1221 Platform. Where game content is delivered within an embedded interface on the Platform, the game studio (e.g., Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) may collect anonymised technical data directly from your device for the purpose of game delivery and integrity verification.

q1221 is not responsible for the privacy practices of these third-party studios beyond the contractual obligations imposed in our data processing agreements with them. We encourage you to review the privacy policies of any third-party service provider whose products you interact with directly, where those services are provided outside the q1221 Platform environment.

q1221 reviews this Privacy Policy at least annually and may update it at any time to reflect changes in our data practices, applicable law, or regulatory guidance. The date of the most recent revision is displayed at the top of this page and in the "Last Updated" notice below the table of contents.

Where changes are material — meaning they significantly alter how we collect, use, or share your Personal Data, or meaningfully affect your privacy rights — q1221 will provide at least 14 days' advance notice via a prominent notice on the Platform homepage and, where reasonably practicable, via email to the address associated with your registered Account.

Your continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request Account closure as described in our Terms & Conditions.

For any questions, concerns, or requests relating to this Privacy Policy or q1221's data practices, please contact our support team through the following channels:

• Live Chat: Available 24/7 directly on the Platform. This is the fastest channel for urgent data concerns. Average response time under 2 minutes during peak WIB hours.
• Email: [email protected] (plain text — not a clickable link). Please include "Privacy Request" in the subject line. Responses within 5 business days for data rights requests.

Support is available in both English and Bahasa Indonesia. Our team can assist with access requests, correction requests, erasure requests, marketing opt-outs, and any other matter relating to your Personal Data.

If you are not satisfied with q1221's response to a privacy concern, you have the right to escalate the matter to the relevant supervisory authority in your jurisdiction. q1221 will cooperate fully with any lawful investigation conducted by a competent data protection authority.

q1221's registered business correspondence address is available to verified Account holders upon written request submitted via the email address above.