svip5 Privacy Policy

1 Introduction

svip5 is an internationally licensed online gaming platform serving players across Indonesia and other eligible jurisdictions. We operate the svip5 platform at svip5.bio and are fully committed to protecting the privacy and security of every Member's personal data.

This Policy has been drafted in accordance with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, integrity, and confidentiality. We treat the protection of your personal data not merely as a legal obligation but as a core operational standard that underpins the trust our Members place in the svip5 brand.

If you have any questions about this Policy or about the way in which your personal data is handled, you may contact our Data Protection team at any time. Contact details are provided in Section 16 of this Policy.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, date of birth, contact details, financial details, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" means svip5 and the Operator entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of svip5 under a documented contractual arrangement.
• "KYC Data" means identity and address verification documentation collected as part of the mandatory Know Your Customer process.
• "Cookies" means small text files placed on your device by the svip5 platform to support session management, analytics, and security functions.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.

3 Data We Collect

svip5 collects Personal Data across several categories. The table below summarises the principal data types, the context in which they are collected, and the primary purpose for which each type is used.

We do not collect sensitive personal data — such as racial or ethnic origin, religious beliefs, health data, or biometric data — except where explicitly required by applicable anti-money-laundering or identity verification law and where we have a documented legal basis for doing so.

4 How We Collect Your Data

svip5 collects Personal Data through the following channels:

• Direct submission: Data you provide when completing the registration form, submitting KYC documentation, filling in payment details, contacting our support team, or completing any other platform form.
• Automated collection: Technical and device data collected automatically when you access the platform via your browser or mobile device — including IP address, session metadata, and cookie data.
• Third-party verification partners: Where identity verification cannot be completed from documents alone, we may receive supplementary data from our authorised KYC and anti-fraud service providers.
• Payment processors: Transaction confirmation and payment status data received from Indonesian banking partners and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) when you make a deposit or withdrawal.
• Responsible gaming tools: Data generated when you interact with self-exclusion, deposit limit, or session reminder features, which is retained to enforce your chosen restrictions.

5 Legal Basis for Processing

svip5 processes your Personal Data on one or more of the following legal bases, depending on the nature of the processing activity:

1. Contractual necessity: Processing is required to perform the contract between you and svip5 — including operating your account, processing deposits and withdrawals, and delivering gaming services.
2. Legal obligation: Processing is required to comply with applicable laws — including anti-money-laundering regulations, Know Your Customer obligations, and any reporting duties owed to relevant licensing or regulatory authorities.
3. Legitimate interests: Processing is necessary for svip5's legitimate business interests — including fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided those interests are not overridden by your fundamental rights and freedoms.
4. Consent: Where processing is not covered by the bases above — in particular, the sending of optional marketing communications — we will rely on your explicit consent, which you may withdraw at any time by adjusting your account notification preferences or contacting support.

6 How We Use Your Data

The Personal Data we collect is used for the following purposes, each of which is tied to a legal basis described in Section 5:

• Account creation and management: Registering your account, maintaining your profile, processing login events, and enabling account security features including two-factor authentication.
• Identity and age verification: Confirming that you are at least 21 years of age and that your identity documents are genuine, as required under our KYC obligations.
• Transaction processing: Facilitating deposits from and withdrawals to your verified Indonesian bank accounts and e-wallets, and maintaining an accurate transaction ledger.
• Fraud and financial crime prevention: Detecting, investigating, and preventing fraudulent activity, money laundering, and other financial crimes through automated risk-scoring systems and manual review where appropriate.
• Responsible gaming: Monitoring betting patterns for indicators of problem gambling, enforcing self-exclusion orders and deposit limits you have set, and fulfilling our duty-of-care obligations toward Members.
• Customer support: Investigating and resolving your enquiries, complaints, and disputes; maintaining records of support interactions for quality assurance and evidence purposes.
• Platform improvement and analytics: Analysing aggregated, anonymised usage data to understand how Members interact with the platform and to improve the quality and relevance of our services. Individual betting outcomes are not used for personalised profiling beyond what is necessary for responsible gaming monitoring.
• Marketing communications: Sending you information about promotions, bonuses, and platform features where you have opted in. You may opt out at any time. svip5 does not send unsolicited commercial messages to Members who have not opted in.
• Legal and regulatory compliance: Fulfilling our obligations under applicable gaming, financial, and data protection law, including responding to lawful requests from licensing authorities and law enforcement agencies.

7 Data Sharing & Disclosure

svip5 does not sell, rent, or disclose your Personal Data to third parties for their own commercial purposes. Data sharing is limited to the following categories of recipient, each of whom is bound by contractual confidentiality and data protection obligations:

• Identity verification and KYC providers: Authorised third-party services that process your identity documents and biometric data solely for the purpose of completing your account verification.
• Payment processors and banking partners: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) that require transaction data to process your deposits and withdrawals.
• Fraud prevention and security services: Specialised providers that analyse Technical and Device Data to detect suspicious activity, bot usage, and multi-accounting behaviour.
• Cloud infrastructure and hosting providers: Providers that host the svip5 platform infrastructure. All hosted data is encrypted and access-controlled. Hosting providers act as Data Processors under documented agreements.
• Regulatory and law enforcement authorities: Where svip5 is legally required to disclose data — for example, under anti-money-laundering reporting obligations or pursuant to a valid court order — we will comply with that legal obligation and, where permitted by law, notify you of the disclosure.
• Group companies: Where the svip5 Operator operates through affiliated entities, inter-group data sharing may occur for centralised compliance, fraud monitoring, and customer support functions, subject to the same data protection standards as this Policy.

In all cases, svip5 shares the minimum amount of data necessary to fulfil the purpose for which it is shared. We do not permit our Data Processors to use your Personal Data for any purpose beyond that which we have specified.

8 Cookies & Tracking Technologies

svip5 uses cookies and similar tracking technologies on the platform. Cookies are small data files stored on your device that help the platform function correctly, remain secure, and provide you with a consistent experience across sessions.

The categories of cookies used by svip5 are as follows:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication tokens that keep you logged in, security tokens that protect against cross-site request forgery, and load-balancing cookies. These cannot be disabled without preventing the platform from functioning.
• Performance and analytics cookies: Collect anonymised data about how Members navigate the platform — which pages are visited, how long sessions last, and where errors occur — to help svip5 identify and fix problems and improve usability.
• Functional cookies: Remember your preferences — such as language settings, time-zone display, and notification preferences — to provide a more personalised experience on return visits.
• Security cookies: Support fraud detection by recording device fingerprint data and flagging unusual login patterns, such as access from a previously unrecognised device or location.

svip5 does not use third-party advertising or behavioural tracking cookies. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair or prevent your ability to use the platform.

9 Data Retention

svip5 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following permanent account closure, as required by anti-money-laundering regulations applicable to international gaming operators.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, consistent with financial record-keeping obligations.
• Support and communications data: Retained for three (3) years from the date of the last interaction, or longer where the data forms part of an open dispute or regulatory investigation.
• Technical and device data (logs): Retained for twelve (12) months for routine security monitoring purposes, and for up to five years where a specific security incident or fraud investigation requires extended retention.
• Marketing preferences: Retained for the duration of your account or until you withdraw consent, whichever is earlier. Following withdrawal, opt-out records are retained indefinitely to ensure compliance with your marketing preferences.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

10 Data Security

svip5 employs a layered security architecture to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Our principal security measures include:

• Transport-layer encryption: All data transmitted between your device and the svip5 platform is encrypted using 256-bit TLS/SSL. Connections that do not meet the minimum TLS standard are rejected.
• Encryption at rest: Sensitive personal and financial data stored on svip5 servers is encrypted using AES-256 or equivalent standards. Encryption keys are managed separately from the encrypted data.
• Access control: Access to systems that process Personal Data is restricted to authorised personnel on a documented need-to-know basis. Access rights are reviewed regularly and revoked upon changes in staff role or employment status.
• Multi-factor authentication: Administrative access to sensitive data systems requires multi-factor authentication. We recommend that all Members also enable two-factor authentication on their svip5 accounts.
• Intrusion detection and monitoring: The svip5 platform is monitored continuously for suspicious access patterns, anomalous login behaviour, and potential security incidents. Automated alerts are triggered for high-risk events.
• Penetration testing and audits: svip5 conducts regular security assessments, including third-party penetration testing, to identify and remediate vulnerabilities before they can be exploited.

Despite the above measures, no internet-based system can guarantee absolute security. If you become aware of any suspected unauthorised access to your svip5 account, you must notify our support team immediately at [email protected].

11 Your Rights

As a Member of svip5, you have the following rights with respect to your Personal Data. To exercise any of these rights, please contact us using the details in Section 16. We will respond to all verified requests within a reasonable timeframe and without undue delay.

• Right of access: You may request a copy of the Personal Data svip5 holds about you, together with information about how it is used and with whom it is shared.
• Right to rectification: You may request that inaccurate or incomplete Personal Data held about you be corrected without undue delay.
• Right to erasure: In certain circumstances, you may request that svip5 delete your Personal Data. This right is subject to overriding legal retention obligations — for example, we are not able to erase KYC and transaction data during the mandatory anti-money-laundering retention period.
• Right to restriction of processing: You may request that svip5 restrict the processing of your data in certain circumstances — for example, where you contest the accuracy of the data or where you have objected to processing and a determination on that objection is pending.
• 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 a copy of your data in a structured, machine-readable format.
• Right to object: You may object to the processing of your Personal Data where svip5 relies on legitimate interests as the legal basis, and where your individual circumstances justify that objection. You may also object to direct marketing processing at any time, without providing reasons.
• 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 processing that occurred before withdrawal.

Please note that the exercise of certain rights may require svip5 to restrict or close your account where fulfilling the request would prevent us from meeting our legal obligations — for example, our obligation to retain KYC records for the minimum statutory period.

12 Children's Privacy

The svip5 platform is strictly intended for adults aged 21 and above. svip5 does not knowingly collect Personal Data from individuals under the age of 21. If we become aware that a person under 21 has provided Personal Data and registered an account, we will immediately close that account, delete the associated Personal Data, and reverse any transactions made from that account to the extent operationally and legally possible.

If you are a parent or guardian and believe that your child may have accessed or registered on the svip5 platform, please contact our support team immediately at [email protected]. We take underage access extremely seriously and will act on all such reports without delay.

13 Third-Party Links

The svip5 platform may reference third-party services — such as game studio providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) — in the context of describing available games and features. svip5 does not embed third-party tracking scripts from those providers on its informational pages, and this Privacy Policy does not cover the data practices of any third-party operator or service provider whose platform you may access independently.

If you navigate to any third-party website or service from the svip5 platform, you do so at your own discretion and under that third party's privacy policy. svip5 accepts no responsibility for the data handling practices of any external party.

14 International Data Transfers

As an internationally licensed platform, svip5 may process or store your Personal Data on servers located outside of Indonesia. Where such international transfers occur, svip5 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under recognised international data protection frameworks.

These safeguards may include: contractual clauses that bind the recipient to data protection standards equivalent to those set out in this Policy; transfers only to jurisdictions that maintain adequate data protection frameworks; and, where applicable, your explicit consent to the transfer.

By registering on svip5 and accepting this Policy, you acknowledge that your Personal Data may be transferred to and processed in jurisdictions outside Indonesia as described above, and you consent to such transfers for the purposes described in this Policy.

15 Amendments to This Policy

svip5 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will provide reasonable advance notice to active Members via the email address registered to your account and/or via a prominent notice on the platform. The revised Policy will be published on this page with an updated "Last Updated" date.

Your continued use of the svip5 platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the amended Policy, you must cease using the platform and may request account closure and withdrawal of any available balance prior to the effective date.

We encourage you to review this Policy periodically to remain informed of how svip5 protects your data. Archived versions of previous policies are available from our support team upon request.

16 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way in which svip5 handles your Personal Data, please contact our Data Protection team using the following details:

• Email: [email protected]
• Live Chat: Available 24/7 via the svip5 platform
• Response Time: We aim to acknowledge all privacy-related enquiries within 48 hours and to provide a full response within 14 calendar days. Complex requests may require additional time, in which case we will notify you of the expected timeline.

If you are not satisfied with our response to a privacy complaint, you may escalate the matter to the relevant data protection or gaming regulatory authority applicable to your jurisdiction. Our support team can provide guidance on the appropriate escalation route upon request.