luvvya Privacy Policy

This Privacy Policy applies to all personal data collected by luvvya through the website https://luvvya.cam and any associated mobile applications, platforms, or services (collectively, "the Platform"). By registering an account and using luvvya, you acknowledge that you have read, understood, and consented to the collection, use, and disclosure of your personal data as described in this Privacy Policy.

This Privacy Policy should be read in conjunction with luvvya's Terms & Conditions, which govern your use of the Platform. Where there is a conflict between this Privacy Policy and the Terms & Conditions, the Terms & Conditions shall prevail with respect to the subject matter of the conflict.

luvvya reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will notify registered Members via email and update the "Last Updated" date at the top of this page. Your continued use of the Platform after such changes constitutes acceptance of the revised Privacy Policy.

luvvya is the data controller responsible for the collection, processing, storage, and protection of your personal data. For the purposes of this Privacy Policy, "luvvya," "we," "us," and "our" refer to the entity operating the Platform at https://luvvya.cam.

As the data controller, luvvya determines the purposes and means of processing your personal data and is responsible for ensuring compliance with applicable data protection laws and regulations, including those applicable in Indonesia and internationally recognised data protection principles.

luvvya collects the following categories of personal data from Members and visitors to the Platform:

3.1 Account Registration Data

• Full legal name (as it appears on your government-issued identification document)
• Date of birth (to verify you meet the minimum age requirement of 21 years)
• Gender
• Email address
• Mobile telephone number
• Residential address (city, province, postal code)
• Preferred username and password (password is stored in encrypted form only)
• Preferred currency (IDR is the default and only accepted currency)

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (National Identity Card / KTP, passport, or driver's licence)
• Proof of address documents (utility bill, bank statement, or official correspondence)
• Proof of payment method ownership (bank account statement showing account holder name)
• Facial verification photograph (where required for enhanced verification)

3.3 Financial & Transaction Data

• Bank account details (account holder name, bank name, account number) for deposits and withdrawals
• E-wallet account identifiers (for OVO, DANA, GoPay, ShopeePay, LinkAja transactions)
• Deposit and withdrawal transaction history, including amounts, dates, and payment method used
• Betting and gaming activity, including wagers placed, game types, win/loss records, and Account balance fluctuations

3.4 Technical & Device Data

• IP address and geolocation data (to verify Indonesian residency and detect fraudulent access)
• Device type, operating system, browser type and version
• Screen resolution, language settings, and time zone (WIB, WITA, or WIT)
• Session duration, pages visited, and referral source
• Cookies and tracking identifiers (see Section 8 for full details)

3.5 Communications & Support Data

• Chat logs and email correspondence with luvvya customer support
• Survey responses, feedback submissions, and promotional opt-in preferences
• Complaint or dispute records, including any evidence submitted in support of a claim

luvvya collects personal data through the following methods:

1. Direct Submission: When you register an account, submit KYC documents, update your profile, make a deposit or withdrawal request, or contact customer support, you provide personal data directly to luvvya.
2. Automated Collection: When you visit or interact with the Platform, we automatically collect technical data through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device information, browsing behaviour, and session activity.
3. Payment Processors: When you deposit or withdraw funds, luvvya receives confirmation data from payment processors (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI, OVO, DANA, GoPay, ShopeePay, LinkAja) including transaction amounts, timestamps, and account holder verification status.
4. Third-Party Sources: In limited circumstances, luvvya may obtain data from third-party fraud prevention services or identity verification providers to supplement KYC checks and detect suspicious activity. Such data is used solely for security and compliance purposes.

luvvya processes your personal data for the following purposes:

5.1 Account Management & Service Delivery

• To create, maintain, and authenticate your luvvya Account
• To process deposits, withdrawals, and internal account transfers
• To enable you to place bets, play games, and access all services offered on the Platform
• To display your Account balance, transaction history, and betting records
• To provide customer support and respond to your enquiries

5.2 Legal Compliance & Security

• To verify your identity, age (21+ requirement), and residential address through KYC procedures
• To comply with anti-money laundering (AML) regulations and detect suspicious financial activity
• To prevent fraud, multi-accounting, bonus abuse, collusion, and other prohibited conduct
• To enforce luvvya's Terms & Conditions and investigate disputes or suspected breaches
• To respond to lawful requests from Indonesian regulatory authorities, law enforcement agencies, or courts

5.3 Marketing & Promotions (With Your Consent)

• To send you promotional offers, bonus notifications, and newsletters by email or SMS (you may opt out at any time)
• To personalise marketing content based on your gaming preferences and activity history
• To conduct customer satisfaction surveys and gather feedback to improve the Platform

5.4 Platform Improvement & Analytics

• To analyse aggregate usage patterns and identify popular game types, peak activity times, and Member preferences
• To test new features, optimise Platform performance, and improve user experience
• To detect technical issues, monitor system uptime, and ensure service reliability

5.5 Responsible Gaming

• To implement and monitor deposit limits, loss caps, session time controls, and self-exclusion requests
• To identify patterns of behaviour that may indicate problem gambling and offer support resources
• To comply with responsible gaming obligations under internationally recognised standards

luvvya does not sell, rent, or lease your personal data to third parties for marketing purposes. We only share your data with the following categories of recipients, and only to the extent necessary:

6.1 Payment Processors

To process deposits and withdrawals, we share your name, bank account number, e-wallet identifier, and transaction amount with the relevant payment provider (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI, OVO, DANA, GoPay, ShopeePay, LinkAja). These processors handle your financial data in accordance with their own privacy policies and Indonesian banking regulations.

6.2 Game Providers & Platform Partners

To deliver live casino, slots, and other games on the Platform, we share limited technical data (Member ID, session ID, bet amounts) with game studio providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. These providers do not receive your real name, contact details, or financial account information.

6.3 Identity Verification & Fraud Prevention Services

To complete KYC verification and detect fraudulent activity, we may share your identification documents, address proof, and device data with third-party verification services. These providers are contractually obligated to use your data solely for verification purposes and to delete it after processing is complete.

6.4 Legal & Regulatory Authorities

luvvya may disclose your personal data to Indonesian government agencies, law enforcement authorities, or courts where required by law, such as in response to a valid subpoena, court order, or regulatory investigation. We will notify you of such disclosures unless prohibited by law.

6.5 Business Transfers

In the event of a merger, acquisition, sale of assets, or other corporate restructuring involving luvvya, your personal data may be transferred to the successor entity, subject to the same privacy protections outlined in this Privacy Policy.

luvvya partners with the following Indonesian payment processors to facilitate secure deposits and withdrawals:

• Local Banks: BCA (Bank Central Asia), BRI (Bank Rakyat Indonesia), BNI (Bank Negara Indonesia), Mandiri, CIMB Niaga, Bank Permata, BSI (Bank Syariah Indonesia)
• E-Wallets: OVO, DANA, GoPay, ShopeePay, LinkAja

When you initiate a deposit or withdrawal, you are redirected to the payment processor's secure interface (in the case of bank transfers) or authorise the transaction through the e-wallet app. luvvya does not directly handle or store your full bank account credentials, debit card numbers, or e-wallet passwords.

Payment processors may collect additional data required for transaction processing, such as transaction timestamps, device fingerprints, and IP addresses. Each processor operates under its own privacy policy, which governs how your data is handled during the payment process. luvvya recommends that you review the privacy policies of BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja to understand how your financial data is protected.

luvvya uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and deliver personalised content. A cookie is a small text file stored on your device that allows the Platform to recognise you on subsequent visits.

8.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function correctly. These cookies enable core features such as account login, session management, and secure transactions. You cannot disable essential cookies without losing access to the Platform.
• Performance Cookies: Collect anonymous data on how Members use the Platform, including page load times, error messages, and navigation paths. This data helps us identify technical issues and improve site performance.
• Functional Cookies: Remember your preferences, such as language settings, preferred odds format, and display preferences, to provide a more personalised experience.
• Marketing Cookies: Track your activity across the Platform to deliver targeted promotional content and measure the effectiveness of marketing campaigns. These cookies are only set if you have consented to marketing communications.

8.2 Managing Cookies

You can manage or delete cookies through your browser settings. Most browsers allow you to block all cookies, accept only certain cookies, or receive a notification before a cookie is set. Please note that disabling essential cookies will prevent you from using certain features of the Platform, including account login and transaction processing.

To learn more about cookies and how to manage them, visit www.allaboutcookies.org (external educational resource).

8.3 Third-Party Tracking

luvvya does not permit third-party advertisers or data brokers to place tracking cookies on the Platform. Game providers (such as Pragmatic Play and Evolution Gaming) may use their own cookies within the game iframe to deliver game content, but these cookies do not track your activity outside the game session.

luvvya employs industry-standard technical and organisational measures to protect your personal data from unauthorised access, accidental loss, alteration, or disclosure:

• 256-bit SSL Encryption: All data transmitted between your device and luvvya's servers is encrypted using 256-bit Secure Sockets Layer (SSL) technology, the same encryption standard used by financial institutions worldwide.
• Secure Data Storage: Personal data is stored on secure servers located in certified data centres with restricted physical and network access. Access to Member data is limited to authorised luvvya personnel who require it to perform their job functions.
• Password Protection: Member passwords are hashed and salted using cryptographic algorithms. luvvya does not store passwords in plain text and cannot retrieve your original password. If you forget your password, you must reset it through a secure password recovery process.
• Two-Factor Authentication (2FA): luvvya offers optional two-factor authentication to add an extra layer of security to your Account. We strongly recommend enabling 2FA to protect against unauthorised login attempts.
• Regular Security Audits: luvvya conducts periodic security assessments and vulnerability scans to identify and address potential threats to the Platform's security infrastructure.
• Employee Training: All luvvya staff with access to Member data receive training on data protection principles and are bound by confidentiality agreements.

luvvya retains your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Account Data: Retained for the duration of your Account's active status and for a period of 7 years after Account closure to comply with Indonesian financial record-keeping requirements and international anti-money laundering standards.
• Transaction Records: Deposit, withdrawal, and betting transaction records are retained for a minimum of 7 years from the date of the transaction for tax, audit, and regulatory compliance purposes.
• KYC Documents: Identity verification documents are retained for 7 years after Account closure to comply with KYC and AML regulatory obligations.
• Support Communications: Chat logs and email correspondence with customer support are retained for 3 years to resolve disputes, monitor service quality, and train support staff.
• Marketing Data: If you have opted in to marketing communications, your contact details and communication preferences are retained until you withdraw consent or your Account is closed, whichever comes first.

After the applicable retention period expires, luvvya will securely delete or anonymise your personal data so that it can no longer be associated with you as an individual.

Under applicable data protection laws, you have the following rights regarding your personal data:

1. Right of Access: You have the right to request a copy of all personal data luvvya holds about you. We will provide this information in a structured, commonly used, and machine-readable format within 30 days of your request.
2. Right to Rectification: If any personal data we hold about you is inaccurate, incomplete, or outdated, you have the right to request that we correct or update it. You can update most Account information directly through your Account dashboard.
3. Right to Erasure (Right to be Forgotten): You may request that luvvya delete your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent. Please note that we may be required to retain certain data to comply with legal obligations (e.g., transaction records for tax purposes).
4. Right to Restriction of Processing: You have the right to request that we restrict how we process your data in specific situations, such as when you contest the accuracy of the data or object to the processing.
5. Right to Object: You have the right to object to the processing of your personal data for marketing purposes at any time. You can opt out of marketing emails by clicking the "unsubscribe" link at the bottom of any promotional email, or by contacting support.
6. Right to Data Portability: You have the right to receive your personal data in a portable format and to request that we transmit it directly to another service provider, where technically feasible.
7. Right to Withdraw Consent: Where processing is based on your consent (such as marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Rights Request." We will respond to your request within 30 calendar days. For security purposes, we may ask you to verify your identity before processing your request.

luvvya is strictly for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If you are under 21, you are not permitted to register an account, access the Platform, or use any of luvvya's services.

If luvvya becomes aware that we have inadvertently collected personal data from an individual under 21 years of age, we will immediately delete that data from our systems and permanently close the associated Account. Any deposits made by an underage individual will be returned to the source account, and all winnings will be forfeited.

Parents and guardians who believe their child may have provided personal data to luvvya should contact [email protected] immediately so that we can take appropriate action.

luvvya primarily stores and processes your personal data within secure data centres that adhere to internationally recognised security standards. In some cases, your data may be transferred to, or accessed from, jurisdictions outside of Indonesia for the purposes of technical infrastructure management, fraud prevention, or KYC verification.

Where personal data is transferred internationally, luvvya ensures that such transfers are protected by appropriate safeguards, including:

• Standard contractual clauses approved by international data protection authorities
• Binding corporate rules for intra-group transfers
• Certification under recognised data protection frameworks

luvvya will not transfer your personal data to any jurisdiction where such transfer is prohibited by Indonesian law or where adequate data protection safeguards cannot be implemented.

luvvya reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. When we make material changes to this Privacy Policy, we will:

1. Update the "Last Updated" date at the top of this page
2. Notify registered Members via email to the address associated with their Account
3. Display a prominent notice on the Platform homepage for a period of at least 30 days

Your continued use of the Platform after the effective date of any changes to this Privacy Policy constitutes your acceptance of the revised policy. If you do not agree to the changes, you must stop using the Platform and contact [email protected] to request Account closure.

We encourage you to review this Privacy Policy periodically to stay informed about how luvvya protects your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or luvvya's data protection practices, please contact our Data Protection team through the following channel:

For urgent security matters involving suspected unauthorised access to your Account or a data breach, please indicate "URGENT — SECURITY" in the subject line of your email.

luvvya is committed to addressing all privacy concerns and data rights requests in a timely, transparent, and professional manner. Your privacy is important to us, and we welcome your feedback on how we can continue to improve our data protection practices.