Privacy Policy — svip11

Throughout this Privacy Policy, the following terms carry the meanings set out below:

• "svip11", "we", "us", "our" — the operating entity behind the svip11 platform accessible at https://svip11.pro, licensed under an international gaming jurisdiction.
• "Platform" — the svip11 website, mobile-optimised views, and all associated gaming services including sportsbook, live casino, and slot products.
• "Player", "you", "your" — any natural person who registers an Account on the Platform or browses the Platform without registration.
• "Personal Data" — any information that identifies or could reasonably be used to identify you as a natural person, including your name, email address, Indonesian mobile number, device identifiers, and financial account details.
• "Processing" — any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, erasure, or destruction.
• "Controller" — the entity that determines the purposes and means of processing Personal Data; svip11 acts as Controller in respect of all player data collected through the Platform.
• "Processor" — a third party that processes Personal Data on svip11's behalf under a binding data processing agreement, such as a KYC verification provider or payment gateway.
• "KYC" — Know Your Customer; the identity and age-verification process required before withdrawal processing, in accordance with anti-money-laundering (AML) obligations.
• "Cookie" — a small text file placed on your device by the Platform to maintain session state, remember preferences, or collect anonymous analytics data.
• "Applicable Law" — the laws and regulations of the jurisdiction in which svip11 holds its international gaming licence, together with any data protection obligations imposed thereby.

svip11 collects Personal Data through several channels. The categories and specific data points collected are described below.

2.1 Registration Data

When you create an Account, we collect: full legal name, date of birth, gender, residential address in Indonesia (including city — e.g., Jakarta, Surabaya, Bandung, Bali, Medan), email address, Indonesian mobile phone number, and your chosen username. This information is mandatory; without it we cannot create or maintain your Account.

2.2 Identity Verification (KYC) Data

To comply with our AML obligations and to verify that you are at least 21 years of age, we collect copies of government-issued identification documents, which for Indonesian residents typically means a Kartu Tanda Penduduk (KTP) or valid Indonesian passport. We may also request a selfie photograph taken alongside the identity document, and proof of ownership of the payment method used for deposits.

2.3 Financial Data

When you make a deposit or withdrawal, we collect the details of the payment method used, including bank account details for transfers via BCA, BRI, BNI, Mandiri, CIMB Niaga, or Bank Permata, and e-wallet account identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja. We do not store full debit or credit card numbers on our servers; card data is handled exclusively by our PCI-DSS compliant payment processors.

2.4 Transaction and Gaming Data

We maintain a complete record of all deposits, withdrawals, bonus credits, bet placements, game rounds, and Account balance changes. This data is essential for accurate account management, dispute resolution, and regulatory reporting under our gaming licence.

2.5 Technical and Device Data

When you access the Platform, our servers automatically record certain technical information, including your IP address, browser type and version, operating system, device type, screen resolution, referring URL, pages visited, time spent on each page, and session duration. This data is collected automatically and is used primarily for security monitoring and aggregate analytics.

2.6 Communications Data

If you contact our support team via live chat or email, we retain a record of that correspondence, including the content of your messages, any attachments you submit, and the date and time of each interaction. This data is used to resolve your query and to improve our customer service quality.

2.7 Marketing Preferences

Where you have provided your consent, we record your marketing opt-in status and preferences, including which communication channels (email, SMS) you have agreed to receive promotional messages through.

svip11 uses the Personal Data it collects for the following specific purposes:

We do not use automated decision-making processes that produce legal or similarly significant effects for Players without human oversight. Responsible gaming risk assessments that may restrict account activity are reviewed by trained staff before any action is taken.

svip11 processes your Personal Data only where a valid legal basis exists. The applicable legal bases are:

• Contractual Necessity: Processing of Registration Data, Financial Data, and Transaction Data is necessary to perform our contract with you — specifically, to create and maintain your Account and to provide the gaming and payment services you have requested.
• Legal Obligation: Processing for KYC identity verification, AML monitoring, and regulatory reporting is required by the laws and regulations applicable under our international gaming licence.
• Legitimate Interests: Processing of Technical and Device Data for platform security, fraud prevention, and aggregate analytics is carried out on the basis of svip11's legitimate interest in operating a secure and well-functioning platform, provided that interest is not overridden by your fundamental rights and freedoms.
• Consent: Processing of your data for marketing communications (promotional emails and SMS) is carried out solely on the basis of your prior, freely given, specific, and informed consent. You may withdraw this consent at any time as described in Clause 9.

svip11 does not sell your Personal Data. We share it only in the following limited circumstances, and only to the extent strictly necessary for the stated purpose:

5.1 Payment Processors

To process deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), we share the minimum necessary financial and identity data with our contracted payment gateway partners. All such partners are bound by data processing agreements that prohibit use of your data for any purpose beyond completing your transaction.

5.2 KYC Verification Partners

To verify your identity and age, we may share copies of your identity documents with a specialist third-party identity verification service. These partners operate under strict data processing agreements and are prohibited from retaining or using your documents beyond the immediate verification purpose.

5.3 Game Studio Providers

When you play a game provided by a third-party studio — such as Pragmatic Play, Evolution Gaming, Pocket Games Soft (PG Soft), Spribe, or Microgaming — a session token and anonymous player identifier are shared with that studio to facilitate game delivery. Your full name and payment details are never shared with game studios.

5.4 Regulatory and Law Enforcement Authorities

svip11 may disclose Personal Data to competent regulatory bodies, law enforcement agencies, or courts of law where required by Applicable Law, by court order, or by the conditions of our gaming licence. Such disclosures are logged and carried out only to the minimum extent legally required.

5.5 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of svip11's business, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material change to this Privacy Policy that results from it.

svip11 uses cookies and similar technologies (including local storage and session storage) on the Platform for the following purposes:

Strictly Necessary cookies cannot be disabled, as they are essential for Platform security and login functionality. All other cookie categories may be managed through your browser's cookie settings. Note that disabling Functional cookies may affect your experience on the Platform, such as requiring you to re-enter your preferences on each visit.

svip11 does not use third-party advertising cookies or cross-site tracking pixels.

svip11 retains your Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by our legal and regulatory obligations. Specific retention periods are outlined below:

• Account and Registration Data: Retained for the duration of your Account and for 5 years following Account closure, in line with standard AML record-keeping requirements.
• KYC Documents: Retained for a minimum of 5 years from the date of submission, as required under AML regulations applicable to our gaming licence.
• Transaction and Gaming Records: Retained for 5 years from the date of each transaction or game round, to support regulatory reporting, dispute resolution, and auditing requirements.
• Customer Support Communications: Retained for 3 years from the date of the most recent interaction in a support thread.
• Technical and Device Logs: Retained for up to 12 months for security monitoring and fraud detection purposes.
• Marketing Consent Records: Retained for the duration of your marketing opt-in and for 3 years following any opt-out, to evidence your consent history.

At the end of the applicable retention period, Personal Data is securely deleted or anonymised such that it can no longer be attributed to an identifiable individual. Anonymised aggregate data may be retained indefinitely for statistical and product development purposes.

svip11 implements a comprehensive set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption on all data in transit between your device and svip11 servers.
• AES-256 encryption for sensitive Personal Data stored at rest, including KYC document files and financial account identifiers.
• Role-based access controls (RBAC) limiting staff access to Personal Data strictly to those with a documented operational need.
• Multi-factor authentication (MFA) required for all internal svip11 staff accessing production systems containing player data.
• Intrusion detection systems (IDS) and real-time security monitoring to identify and respond to suspicious access patterns.
• Regular independent security audits and penetration testing of the Platform infrastructure, conducted at least annually.
• Incident response procedures enabling svip11 to identify, contain, and notify affected Players of any Personal Data breach within the timeframe required by Applicable Law.

As a data subject, you hold the following rights in respect of your Personal Data held by svip11. To exercise any of these rights, contact our support team via live chat or by email at [email protected].

• Right of Access: You may request a copy of the Personal Data svip11 holds about you at any time. We will provide this in a structured, commonly used format within 10 business days of receiving your verified request.
• Right to Rectification: If any of your Personal Data is inaccurate or incomplete, you have the right to request that it be corrected. Name corrections require documentary evidence and are subject to KYC re-verification.
• 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, or where you withdraw consent and no other legal basis applies. Note that deletion requests may not be fulfilled where retention is required by our AML obligations or gaming licence regulations.
• Right to Restriction of Processing: You may request that we restrict the processing of your data in certain circumstances — for example, while a dispute about accuracy is being resolved.
• Right to Data Portability: You may request that your Account and transaction data be provided in a machine-readable format (JSON or CSV) suitable for transfer to another service provider, where technically feasible.
• Right to Object: You may object to processing carried out on the basis of svip11's legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Marketing Consent: You may withdraw your consent to receive marketing communications at any time via your Account Settings or by contacting support. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

svip11 does not charge a fee for handling data subject requests made in good faith. We may ask you to verify your identity before processing a request to ensure your data is not disclosed to an unauthorised party.

The svip11 Platform is strictly for adults aged 21 and over. We do not knowingly collect Personal Data from individuals under the age of 21. Our registration process includes mandatory age declaration, and all Accounts are subject to KYC age verification before withdrawal processing.

If svip11 becomes aware that Personal Data has been collected from a person under 21 years of age, that Account will be closed immediately, all funds will be handled in accordance with our Terms & Conditions, and all associated Personal Data will be securely deleted or anonymised without undue delay.

The svip11 Platform integrates with various third-party service providers to deliver gaming content, process payments, and verify player identities. Each category of third-party provider is described below, together with the scope of data they receive:

11.1 Game Content Providers

Games on the Platform are supplied by studios including Pragmatic Play, Evolution Gaming, Microgaming, Spribe, Pocket Games Soft (PG Soft), NetEnt, and Habanero. These studios receive only an anonymised session token to authenticate the game session. No personally identifiable information is transmitted to game studios beyond what is technically necessary to establish and maintain the gaming session.

11.2 Payment Service Providers

Payment gateways processing bank transfers and e-wallet transactions receive the financial account details and player name necessary to complete the transaction. All payment partners are contractually prohibited from retaining this data beyond the period required for transaction completion and their own legal compliance obligations.

11.3 Identity Verification Services

Our KYC partner receives copies of identity documents and may perform biometric liveness checks. These providers are certified under internationally recognised identity verification standards and operate under binding data processing agreements with svip11.

11.4 Analytics Providers

svip11 uses anonymised, aggregate analytics tools to understand how players navigate the Platform and to identify areas for improvement. No personally identifiable information is shared with analytics providers; all data is aggregated and anonymised before transmission.

svip11 is not responsible for the privacy practices of independent third-party websites that may be linked to from general web searches. This Privacy Policy applies only to the svip11 Platform.

svip11 is operated by an internationally licensed entity and its infrastructure may involve the transfer of Personal Data to servers or service providers located outside Indonesia. Where such transfers occur, svip11 ensures that appropriate safeguards are in place to protect your Personal Data to a standard at least equivalent to that required under Applicable Law.

Safeguards used for international transfers include: binding contractual clauses incorporated into all data processing agreements with third-party providers; selection of providers operating in jurisdictions with an adequate level of data protection as recognised by international standards; and technical encryption measures that protect data in transit regardless of the country through which it travels.

svip11 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, changes in Applicable Law, or improvements to the Platform. When material changes are made, we will notify registered Players by email to the address on record, or via a prominent in-Platform notification, at least 7 days before the revised Policy takes effect.

The "Last updated" date shown at the top of this page indicates when the current version entered into force. We recommend reviewing this Policy periodically. Your continued use of the Platform following notification of an updated Policy constitutes your acknowledgement of the revised terms. If you do not accept a revised Policy, you must cease using the Platform and may request Account closure in accordance with Clause 14 of our Terms & Conditions.

Previous versions of this Privacy Policy are available on request by contacting our support team.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your Personal Data by svip11, please contact our Data Protection team through the following channels:

• Live Chat: Available 24/7 directly from any page on the Platform. Indonesian-speaking agents are available at all times.
• Support Email: [email protected] (plain text — not a clickable link). Target response time: within 4 business hours (WIB, UTC+7).

Data subject requests — including access, rectification, erasure, and portability requests — are handled within 10 business days of receipt of a verified request. There is no charge for submitting a data subject request.

If you are not satisfied with svip11's response to a privacy concern, you may escalate your complaint to the relevant data protection authority in the jurisdiction of our gaming licence. Details of the relevant supervisory authority are available on request.