Privacy Policy

In this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"), including but not limited to a name, identification number, location data, or online identifier.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this context, rtp110.
• "Data Processor" means any third party that processes Personal Data on behalf of rtp110 under a written data processing agreement.
• "Platform" means the rtp110 website at rtp110.cam and all associated interfaces.
• "User" / "You" means any individual who accesses or uses the Platform.
• "KYC" means Know Your Customer — the identity and age verification process required under rtp110's international gaming license.
• "Cookies" means small text files placed on your device by the Platform to enable certain functionality and to collect usage data.
• "AML" means Anti-Money Laundering — the legal and regulatory framework requiring financial service providers to monitor and report suspicious transactions.

2.1 rtp110 acts as the Data Controller for all Personal Data collected through the Platform. rtp110 operates under an international offshore gaming license and is not subject to Indonesian domestic data protection legislation. However, rtp110 voluntarily applies data protection principles consistent with internationally recognized standards.

2.2 All data protection inquiries, access requests, and complaints should be directed to rtp110's designated Data Protection contact via the email address provided in Section 15 of this policy.

3.1 rtp110 collects the following categories of Personal Data from Users:

3.2 rtp110 does not intentionally collect special category data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data beyond what is incidentally visible in a KTP photograph). If you voluntarily disclose such information during support interactions, it will be treated with the highest level of confidentiality and will not be processed beyond the immediate support context.

4.1 Directly from You. The majority of the Personal Data rtp110 holds is provided directly by you during the registration process, the KYC verification process, deposit and withdrawal setup, and any communications you initiate with our support team.

4.2 Automatically. When you access the Platform, rtp110's servers automatically record certain Technical Data and Behavioral Data via server logs, session tracking technology, and first-party cookies. This data is collected regardless of whether you are logged in to a registered account.

4.3 From Third-Party Service Providers. rtp110 may receive supplementary data from the following categories of third-party service providers:

• KYC / Identity Verification Partners: External identity verification services may provide enhanced identity confirmation data where automated document verification is employed;
• Payment Processors: Indonesian bank gateways and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) confirm transaction status and provide relevant transaction metadata to rtp110's payment systems;
• Fraud Detection Networks: rtp110 participates in international gaming fraud intelligence sharing programs. Where a User's account is flagged by an external fraud network, rtp110 may receive a notification to that effect.

5.1 rtp110 processes your Personal Data for the following purposes, each supported by a legitimate legal basis:

5.2 Where rtp110 relies on your consent as the legal basis for processing (specifically for promotional communications), you may withdraw that consent at any time by updating your communication preferences in your account settings or by contacting support. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

6.1 rtp110 does not sell, rent, or otherwise transfer your Personal Data to third parties for their independent commercial use. Data is shared only in the following circumstances and only to the extent necessary for the stated purpose:

• Licensed Game Studios: Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive a pseudonymous player identifier and session token to facilitate game delivery. They do not receive your full identity or financial data;
• Payment Processors and Banking Partners: BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction-specific data strictly necessary to execute deposit and withdrawal instructions;
• KYC Verification Service Providers: Identity document data and selfie photographs are shared with rtp110's contracted KYC partners for the purpose of age and identity verification only. These partners are bound by confidentiality and data processing agreements;
• Fraud Prevention and Security Partners: Technical identifiers (IP address, device fingerprint) may be shared with fraud prevention networks operating within the online gaming industry;
• Legal and Regulatory Authorities: rtp110 will disclose Personal Data to law enforcement, regulators, or other public authorities where required to do so by applicable law, a court order, or a valid regulatory demand. rtp110 will notify the affected User of such a disclosure where legally permitted to do so.

6.2 All third-party Data Processors are selected carefully, are bound by written data processing agreements, and are required to implement security measures consistent with rtp110's own standards. rtp110 remains responsible for the processing activities carried out by its Data Processors on its behalf.

7.1 rtp110's servers and those of certain Data Processors are located outside of Indonesia. By using the Platform, you acknowledge that your Personal Data will be transferred to, stored in, and processed in jurisdictions outside Indonesia, including the jurisdiction in which rtp110 holds its international gaming license.

7.2 Where Personal Data is transferred internationally, rtp110 implements appropriate safeguards to protect your data, including contractual protections in agreements with Data Processors and technical security measures equivalent to those applied to data stored domestically.

7.3 rtp110 does not transfer Personal Data to jurisdictions that rtp110 has identified as offering inadequate data security standards, except where strictly required by legal obligation and with appropriate protective measures in place.

8.1 rtp110 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal or regulatory obligations. The following retention schedule applies:

• Account and Identity Data: Retained for the lifetime of the account and for a period of five (5) years following permanent account closure, to comply with AML and gaming license record-keeping requirements;
• Financial Transaction Records: Retained for seven (7) years from the date of each transaction, consistent with standard financial record-keeping practice;
• KYC Documents (copies of identity documents): Retained for the period mandated by rtp110's licensing jurisdiction, typically five (5) years post-account closure;
• Gaming Activity Logs: Retained for five (5) years to support responsible gaming monitoring, dispute resolution, and regulatory audit requirements;
• Support Communications: Retained for three (3) years from the date of the last communication in a support thread;
• Marketing Preferences and Promotional Activity Data: Retained for the duration of opt-in consent and deleted within thirty (30) days of opt-out or account closure, whichever is earlier;
• Technical and Behavioral Data (anonymous analytics): Aggregated and anonymized after thirteen (13) months and retained indefinitely in anonymized form.

8.2 Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized in accordance with rtp110's data destruction policy.

9.1 rtp110 implements a multi-layered security architecture to protect Personal Data against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Transport Security: All data in transit is protected by TLS 1.2 or higher (256-bit AES encryption). The Platform enforces HTTPS on all pages and subdomains;
• Data at Rest Encryption: Sensitive Personal Data and financial records stored in rtp110's databases are encrypted at rest using industry-standard encryption algorithms;
• Access Controls: Access to Personal Data is granted on a strict need-to-know basis. All internal access is logged, monitored, and subject to regular review. Multi-factor authentication is required for all administrative access;
• Network Security: rtp110's infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and DDoS mitigation services;
• Security Audits: rtp110 conducts periodic third-party security assessments and penetration tests to identify and remediate vulnerabilities before they can be exploited;
• Incident Response: rtp110 maintains a documented data breach response procedure. In the event of a confirmed data breach affecting User Personal Data, affected Users will be notified within 72 hours of rtp110 becoming aware of the breach, to the extent permitted by applicable law.

10.1 rtp110 uses cookies and similar tracking technologies on the Platform for the purposes described below. By continuing to use the Platform, you consent to the use of cookies in accordance with this policy.

10.2 Types of Cookies Used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They maintain your login session, remember your language and currency preferences, and ensure secure navigation between pages. These cookies cannot be disabled without impairing Platform functionality;
• Performance and Analytics Cookies: These cookies collect aggregated, anonymized data about how Users interact with the Platform — which pages are most visited, average session duration, and navigation paths. This data helps rtp110 improve the user experience. No personally identifiable information is collected through these cookies;
• Functional Cookies: These cookies remember choices you have made on the Platform (such as your preferred deposit method or notification settings) to provide a more personalized experience;
• Security Cookies: These cookies support fraud prevention and security functions, including detecting suspicious login attempts and verifying that you are a human user rather than an automated script.

10.3 rtp110 does not use third-party advertising cookies or behavioral tracking cookies for the purpose of serving targeted advertisements on or off the Platform. rtp110 does not participate in cross-site tracking networks.

10.4 Managing Cookies: You may configure your browser to refuse all or certain types of cookies, or to alert you when a cookie is being set. Please note that disabling strictly necessary cookies will prevent you from logging in to your account and using core Platform features. Browser-level cookie management instructions are available in your browser's help documentation.

11.1 rtp110 recognizes and upholds the following rights with respect to your Personal Data, consistent with internationally recognized data protection principles:

• Right of Access: You have the right to request confirmation of whether rtp110 holds Personal Data about you and, if so, to receive a copy of that data in a structured, commonly used format. Access requests will be fulfilled within 30 days;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data held by rtp110. Corrections to identity or financial data may require supporting documentation;
• 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, or where processing is unlawful. This right is subject to rtp110's legal retention obligations — data required for AML, licensing compliance, or active dispute resolution cannot be deleted before the mandatory retention period expires;
• Right to Restrict Processing: You may request that rtp110 restrict processing of your Personal Data in certain circumstances, such as while the accuracy of data is being verified or while an objection to processing is being assessed;
• Right to Data Portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you have the right to receive your Personal Data in a portable format and to request its transfer to another data controller;
• Right to Object: You have the right to object at any time to processing of your Personal Data where rtp110 relies on legitimate interest as the legal basis. rtp110 will cease processing unless it can demonstrate compelling legitimate grounds that override your interests;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing.

11.2 To exercise any of the above rights, please submit your request in writing to rtp110's support team at the contact address provided in Section 15. rtp110 may need to verify your identity before processing a data subject request to prevent unauthorized disclosure of another person's data.

12.1 The Platform is strictly restricted to individuals aged 21 years and older. rtp110 does not knowingly collect Personal Data from individuals under the age of 21. The KYC process is specifically designed to verify that all registered Users meet the minimum age requirement before any real-money activity is permitted.

12.2 If rtp110 becomes aware that Personal Data has been collected from a person under 21 years of age — whether through a successful KYC failure detection, a third-party report, or any other means — rtp110 will immediately suspend the associated account, delete all Personal Data collected in connection with that account, and return any deposited funds to the originating payment method.

12.3 Parents and guardians who have reason to believe that a minor has registered on the Platform are encouraged to contact rtp110 immediately at the support contact in Section 15. rtp110 takes all such reports seriously and will act upon them promptly.

13.1 The Platform may from time to time reference or display content from third-party game studios (such as Pragmatic Play, Evolution Gaming, and Pocket Games Soft) within embedded game frames. These game frames operate under the privacy policies of the respective studios and are subject to those studios' own data handling practices with respect to gameplay data collected directly within the game frame.

13.2 rtp110 is not responsible for the privacy practices of third-party game studios or any other third party whose services are accessed through the Platform. Users are encouraged to review the privacy policies of relevant game studios if they have concerns about how in-game data is handled.

13.3 rtp110's Privacy Policy applies solely to data collected by rtp110 through the Platform. It does not govern data collection by third parties accessed via any links or integrations within the Platform.

14.1 rtp110 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, changes to applicable law or licensing requirements, or improvements to our security measures. The revised policy will be published on this page with an updated "Last Updated" date.

14.2 Where changes to the Privacy Policy are material — meaning they significantly affect your rights or the manner in which rtp110 processes your Personal Data — rtp110 will provide advance notice to registered Users via the email address associated with their account at least 14 days before the changes take effect.

14.3 Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy. If you do not accept the revised policy, you may request account closure in accordance with the Terms & Conditions.

15.1 For any questions, concerns, or requests relating to this Privacy Policy or rtp110's handling of your Personal Data — including the exercise of any of the rights described in Section 11 — please contact our Data Protection team using the details below:

15.2 rtp110 is committed to resolving all privacy-related complaints promptly and fairly. Upon receipt of a complaint, rtp110 will acknowledge it within 5 business days (WIB) and provide a substantive response within 30 calendar days. Where a complaint cannot be resolved within this timeframe, rtp110 will notify you of the expected resolution date.

15.3 rtp110's support team is available via live chat on the Platform, with native Indonesian-speaking agents on shift 24 hours a day, 7 days a week, across all Indonesian time zones (WIB, WITA, and WIT). Live chat is available for general inquiries; formal data subject requests and complaints should be submitted in writing via email to ensure a documented record.