Privacy Policy

1 Definitions

For clarity and consistency throughout this Privacy Policy, the following terms carry the meanings assigned below:

• "yyry", "we", "us", or "our" refers to the operating entity that owns and manages the yyry Platform at https://yyry.cam.
• "Platform" means the yyry website, mobile-optimised pages, and any associated digital touchpoints operated by yyry.
• "Player", "you", or "your" means any individual who visits, registers on, or actively uses the Platform.
• "Personal Data" means any information that identifies or can reasonably be used to identify a natural person, including name, identification number, contact details, financial information, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, alteration, and deletion.
• "Data Controller" means yyry in its capacity as the entity that determines the purposes and means of processing Personal Data.
• "Third-Party Processor" means any external service provider that processes Personal Data on yyry's behalf, subject to contractual data-processing agreements.
• "Cookie" means a small text file placed on your device by the Platform to enable session management, preference storage, and analytics.

2 Data We Collect

yyry collects the minimum personal data necessary to deliver its services safely and compliantly. The categories of data we may hold about you are set out in the table below:

We do not collect or store full payment card numbers. Where card payment support is provided in the future, card data will be handled exclusively by PCI-DSS-compliant payment processors with no long-term storage by yyry.

3 How We Collect Your Data

3.1 Direct Collection

We collect Person al Data directly from you when you:

• Register for an yyry Account and complete the sign-up form with your name, email, phone number, date of birth, and address.
• Submit identity documents and proof of address during KYC verification.
• Make deposits or withdrawals, requiring you to link a bank account or e-wallet registered in your name.
• Contact our support team via live chat, email, or phone, providing context and personal details to resolve your query.
• Participate in promotions, surveys, or feedback forms that request your input.
• Adjust your account preferences, communication settings, or responsible gaming limits through your Account dashboard.

3.2 Automated Collection

Certain data is collected automatically when you interact with the Platform:

• Technical & Device Data: Your IP address, browser type, device model, operating system, screen resolution, and referring URL are logged by our web servers.
• Usage & Behavioral Data: We track pages viewed, session duration, game selections, bet placements, and navigation paths using cookies and analytics tools.
• Location Data: Your approximate geographic location is inferred from your IP address to ensure you are accessing the Platform from a permitted jurisdiction.

3.3 Third-Party Sources

We may receive supplementary data from trusted third parties to enhance security and compliance:

• KYC Verification Providers: Third-party identity verification services may confirm the validity of your submitted documents against government databases.
• Payment Processors: Bank transfer gateways and e-wallet APIs provide transaction confirmation data to reconcile deposits and withdrawals.
• Fraud Prevention Tools: Specialist security vendors may supply risk scores or flag suspicious activity patterns based on device fingerprinting and behavioral analytics.

4 Purpose of Data Processing

yyry processes your Personal Data for the following lawful purposes:

4.1 Account Management

To create, maintain, and administer your Player Account; authenticate your identity on login; and provide access to games, betting markets, and account history.

4.2 Transaction Processing

To process deposits via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja; handle withdrawal requests; apply bonus credits; and maintain accurate financial records.

4.3 Regulatory Compliance

To fulfill Know Your Customer (KYC), Anti-Money Laundering (AML), and Counter-Terrorism Financing (CTF) obligations; verify your age (21+) and identity; detect and prevent fraud; and respond to lawful requests from regulatory or law enforcement authorities.

4.4 Customer Support

To respond to your inquiries via live chat, email, or phone; resolve disputes or complaints; and provide 24/7 Indonesian-speaking and English-speaking assistance.

4.5 Platform Security

To detect and prevent unauthorised access, account takeover attempts, distributed denial-of-service (DDoS) attacks, payment fraud, bonus abuse, and other security threats.

4.6 Service Improvement

To analyse Platform usage patterns; identify technical issues or performance bottlenecks; test new features; and optimise user experience based on aggregated, anonymised data.

4.7 Responsible Gaming

To monitor your gaming behavior for signs of problem gambling; enforce deposit limits, loss limits, and self-exclusion requests; and provide access to responsible gaming tools and resources.

4.8 Marketing & Promotions (With Consent)

To send promotional emails, SMS, or push notifications about bonuses, tournaments, seasonal offers (Idul Fitri, Ramadhan, Independence Day), and VIP programme updates — only if you have explicitly opted in. You may withdraw consent at any time via your Account settings or by contacting support.

5 Legal Basis for Processing

yyry processes your Personal Data on one or more of the following legal grounds:

• Contractual Necessity: Processing is required to perform the contract between you and yyry (i.e., the Terms & Conditions you accepted upon registration). This includes account creation, payment processing, and service delivery.
• Legal Obligation: Processing is mandated by applicable law, including KYC/AML obligations, age verification requirements, and regulatory reporting duties.
• Legitimate Interests: Processing is necessary for yyry's legitimate business interests — such as fraud prevention, platform security, service improvement, and enforcement of responsible gaming policies — provided these interests do not override your fundamental rights and freedoms.
• Consent: For marketing communications and certain optional data uses, processing is based on your explicit, freely given consent. You may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

6 Data Sharing & Disclosure

yyry does not sell or rent your Personal Data to third parties. However, we may share limited data with the following categories of recipients under strict contractual safeguards:

6.1 Service Providers

Third-party processors who perform services on our behalf, including:

• Payment Processors: Indonesian bank gateways and e-wallet providers that facilitate deposit and withdrawal transactions.
• KYC Verification Vendors: Identity verification specialists who validate your documents against official records.
• Cloud Hosting Providers: Infrastructure partners that host our servers and databases in secure, access-controlled data centers.
• Customer Support Platforms: Live chat and ticketing systems that help us deliver efficient 24/7 support.
• Email & SMS Services: Communication platforms used to send transactional messages (deposit confirmations, withdrawal approvals, password resets) and marketing messages (with your consent).

All service providers are bound by data processing agreements that require them to process data only on yyry's instructions and maintain equivalent security standards.

6.2 Game Studios & Platform Providers

Casino game developers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) and sports betting data feeds receive minimal technical identifiers (session tokens, anonymised player IDs) necessary to deliver game content. They do not receive your personal identity, contact, or financial information.

6.3 Regulatory & Legal Authorities

We may disclose Personal Data to government agencies, law enforcement, or regulatory bodies when required by law or when necessary to:

• Comply with a valid subpoena, court order, or statutory obligation.
• Report suspicious transactions under AML/CTF legislation.
• Protect yyry's legal rights, enforce our Terms & Conditions, or defend against legal claims.
• Safeguard the security and integrity of the Platform and its users.

6.4 Business Transfers

In the event yyry undergoes a merger, acquisition, asset sale, or bankruptcy proceeding, your Personal Data may be transferred to the successor entity. You will be notified via email and/or a prominent notice on the Platform before any such transfer occurs.

7 Cookies & Tracking Technologies

yyry uses cookies and similar technologies to enhance platform functionality, security, and user experience. A cookie is a small text file stored on your device that helps the Platform recognise you across sessions.

7.1 Types of Cookies We Use

• Essential Cookies: Required for basic site functionality, including login authentication, session management, and secure transaction processing. These cannot be disabled without breaking core features.
• Security Cookies: Detect fraudulent login attempts, prevent DDoS attacks, and validate your device integrity. These protect both you and yyry from malicious activity.
• Performance Cookies: Collect anonymised data on page load times, error rates, and feature usage to help us identify and fix technical issues.
• Analytics Cookies: Track aggregate traffic patterns, popular games, and user flows to inform product decisions. Data is pseudonymised and not linked to personally identifiable information.
• Preference Cookies: Remember your language settings, theme choices, and other customisations for a smoother experience on return visits.

7.2 Managing Cookies

Most web browsers allow you to control cookies through their settings menu. You can configure your browser to block all cookies, accept only first-party cookies, or prompt you before storing any cookie. Be aware that blocking essential cookies will prevent you from logging in or placing bets.

For more information on cookie management, consult your browser's help documentation:

• Google Chrome: Settings → Privacy & Security → Cookies and other site data
• Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data
• Safari: Preferences → Privacy → Cookies and website data
• Microsoft Edge: Settings → Cookies and site permissions → Cookies and site data

7.3 Third-Party Cookies

Certain game studio integrations and payment gateways may set their own cookies. These are governed by the respective third party's privacy policy, not yyry's. We recommend reviewing those policies if you have concerns about third-party tracking.

8 Data Retention Periods

yyry retains Personal Data only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, and resolve disputes.

8.1 Active Account Data

While your Account remains active, we retain all associated Personal Data to enable ongoing service delivery, transaction history access, and customer support.

8.2 Closed Account Data

After you close your Account, yyry retains transaction records, KYC documents, and communications for a minimum of 5 years to satisfy regulatory record-keeping requirements under AML/CTF legislation. After this period, data is securely deleted or anonymised unless a longer retention is mandated by law or necessary for ongoing legal proceedings.

8.3 Marketing Data

If you opt out of marketing communications, your contact details are retained on a suppression list to ensure we do not inadvertently contact you again. This suppression list is kept indefinitely unless you request its removal and accept the risk of re-receiving marketing messages.

8.4 Technical & Usage Data

Logs, cookies, and analytics data are typically retained for 12–24 months, after which they are aggregated, anonymised, or deleted.

9 Data Security Measures

yyry employs industry-standard security controls to protect your Personal Data from unauthorised access, disclosure, alteration, and destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.3 (256-bit) protocols. Sensitive data at rest (passwords, financial details) is encrypted using AES-256 or equivalent algorithms.
• Access Controls: Only authorised yyry personnel with a legitimate business need can access Personal Data. All access is logged and audited regularly.
• Network Security: Firewalls, intrusion detection systems (IDS), and DDoS mitigation services protect our infrastructure from external attacks.
• Secure Development: Our engineering team follows secure coding practices, conducts regular code reviews, and patches vulnerabilities promptly.
• Third-Party Audits: Independent security firms periodically assess our systems through penetration testing and vulnerability scanning.
• Employee Training: All staff undergo mandatory data protection and security awareness training annually.
• Incident Response: In the unlikely event of a data breach, yyry maintains a formal incident response plan and will notify affected Players and relevant authorities as required by law.

10 Your Privacy Rights

As a Player, you hold the following rights concerning your Personal Data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Privacy Request".

10.1 Right of Access

You may request a copy of all Personal Data yyry holds about you. We will provide this in a structured, commonly used, machine-readable format (typically PDF or CSV) within 30 days of your request.

10.2 Right to Rectification

If any of your Personal Data is inaccurate or incomplete, you have the right to request correction. Most contact details and preferences can be updated directly through your Account settings; for KYC document updates, contact support.

10.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your Personal Data under certain circumstances, such as when the data is no longer necessary for its original purpose or you withdraw consent. However, yyry may retain data where required by law (e.g., 5-year AML retention) or necessary to defend legal claims.

10.4 Right to Restrict Processing

You may request that yyry limit how it uses your data while a dispute is resolved or while we verify the accuracy of contested data. During this period, data will be stored but not actively processed (except with your consent or for legal claims).

10.5 Right to Data Portability

You may request a copy of your Personal Data in a portable format to transfer to another service provider. This right applies only to data you directly provided to yyry and where processing is based on consent or contract.

10.6 Right to Object

You may object to processing based on legitimate interests (e.g., marketing profiling) or for direct marketing purposes. If you object to marketing, we will cease such processing immediately; for other objections, we will assess whether compelling legitimate grounds override your interests.

10.7 Right to Withdraw Consent

Where processing is based on consent (e.g., promotional emails), you may withdraw that consent at any time via Account settings or by clicking "unsubscribe" in any marketing email. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.

10.8 Right to Lodge a Complaint

If you believe yyry has processed your Personal Data unlawfully or violated your privacy rights, you may lodge a formal complaint with the relevant data protection authority in your jurisdiction. In Indonesia, this may be the Ministry of Communication and Informatics or successor regulatory body with data protection oversight.

11 Protection of Minors

yyry's services are strictly limited to individuals aged 21 years or older. We do not knowingly collect Personal Data from individuals under 21. If we discover that an underage individual has registered an Account or provided Personal Data, we will immediately close the Account, void all transactions, and delete the associated data (subject to any legal retention obligations).

Parents or guardians who believe a minor has provided Personal Data to yyry should contact [email protected] immediately. We take underage access seriously and will investigate all reports promptly.

12 Third-Party Links & Services

The yyry Platform may contain links to third-party websites, payment gateways, or social media pages (e.g., Facebook, Twitter, Telegram, WhatsApp) for informational or support purposes. This Privacy Policy applies only to data collected directly by yyry. Once you navigate to a third-party site, that site's privacy policy governs how your data is handled.

yyry is not responsible for the privacy practices or content of external websites. We encourage you to review the privacy policies of any third-party services you access through links on our Platform.

13 International Data Transfers

yyry operates an internationally licensed platform. Your Personal Data may be transferred to, stored on, and processed by servers located outside Indonesia, including within the European Economic Area (EEA), Singapore, or other jurisdictions with robust data protection frameworks.

Where data is transferred to a jurisdiction that does not provide an equivalent level of protection to Indonesian law, yyry implements appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by relevant data protection authorities.
• Binding Corporate Rules (BCRs) for intra-group transfers (if applicable).
• Certification under recognised data protection frameworks (e.g., EU-U.S. Data Privacy Framework, if applicable).

By using the Platform, you acknowledge and consent to such international transfers under these safeguards.

14 Amendments to This Privacy Policy

yyry reserves the right to update this Privacy Policy to reflect changes in our data practices, legal obligations, or service offerings. Material changes will be communicated via email to registered Players and/or a prominent notice on the Platform at least 14 days before the revised policy takes effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. Continued use of the Platform after the effective date constitutes your acceptance of the updated policy. If you do not agree with the changes, you must cease using the Platform and may request Account closure and data deletion (subject to legal retention requirements).

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your Personal Data.

15 Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how yyry handles your Personal Data, please contact us through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Privacy Requests: "Data Privacy Request" or "GDPR Request"
• Live Chat: Available 24/7 via the Platform (for general inquiries; formal privacy requests must be submitted via email for audit trail purposes)
• Response Time: We aim to respond to all privacy-related inquiries within 30 days, as required by data protection regulations. Complex requests may take up to 60 days; we will notify you if additional time is needed.
• Support Language: English and Indonesian (native Indonesian-speaking agents available 24/7)