Privacy Policy Superbola – Indonesian Member Data Protection

Superbola ("we", "Platform") is fully committed to protecting the privacy of every individual who uses our services. This Privacy Policy transparently explains how we collect, use, store, and protect your personal data when you use the Superbola platform at superbola.vu.

This document applies to all platform users, including unregistered visitors, active members, and former members whose accounts have been closed but whose data remains within the retention period required by regulations.

By using the Superbola platform, you confirm that you have read and understood this policy. We encourage you to read this document thoroughly and contact our support team if anything is unclear.

Superbola collects various types of personal data necessary to operate our services safely and effectively. Below are details of the data we collect and its purposes:

2.1 Data You Provide Directly

• Identity information: Full name, date of birth, gender, national ID or passport number.
• Contact information: Email address, phone number, residential address.
• Financial information: Bank account number, account holder name, registered e-wallet accounts.
• Verification documents (KYC): ID card/driver's license/passport photo and a verification selfie for identity verification.

2.2 Automatically Collected Data

• Technical data: IP address, device type, operating system, browser name and version.
• Usage data: Pages visited, session duration, games played, bet amounts and frequency.
• Location data: Approximate location based on IP address (no GPS or precise location used).
• Cookies and session data: Login session information, display preferences, and in-platform navigation history.

Superbola uses your personal data only for legitimate and transparent purposes. Below is the complete list of how we use your data:

• Identity verification and account security — ensuring only you can access your account, preventing fraud and duplicate accounts.
• Financial transaction processing — processing deposits, withdrawals, and bonus payments securely and accurately.
• Legal and regulatory compliance — fulfilling anti-money laundering (AML) obligations, suspicious transaction reporting, and age verification.
• Platform service improvement — analyzing usage patterns to improve features, performance, and the overall user experience.
• Service communications — sending transaction confirmations, account security notifications, and important policy updates.
• Customer support — identifying accounts and transaction history when you contact our support team.
• Abuse prevention — detecting unusual activity such as bot usage, collusion, or system manipulation.
• Promotional communications (only with your consent) — to inform you of relevant bonus offers and promotions.

Superbola processes your personal data on valid legal grounds. Depending on the type of data and its purpose, the legal bases we rely on include:

• Contract performance — processing is necessary to provide the services you requested when registering and using the platform.
• Legal obligation — certain processing is required under applicable anti-money laundering, taxation, or financial reporting regulations.
• Legitimate interest — processing for platform security, fraud prevention, and service improvement.
• Consent — for marketing communications and non-essential cookie usage, we request your explicit consent.

Superbola does not sell your data. However, in operating the platform, we need to share certain data with the following parties, who are bound by strict confidentiality agreements:

• Payment service provider — banks and payment gateways that process your deposit and withdrawal transactions.
• Game provider — companies such as Evolution Gaming and Pragmatic Play that provide gaming content on our platform. Data shared is limited to game session identification only.
• Identity verification services — KYC partners who assist in verifying the authenticity of your identity documents.
• Cloud infrastructure provider — hosting and database services that securely store platform data.
• Legal and regulatory authorities — if required by applicable law, court order, or directive from a competent authority.

Superbola retains your personal data only for as long as necessary for the relevant processing purposes or as required by applicable regulations. Below is our retention policy:

• Active account data — retained for as long as your account remains active and you continue using our services.
• Data after account closure — certain data such as transaction history and KYC documents is retained for up to 5 years after account closure in accordance with anti-money laundering legal obligations.
• Technical logs — server log data is retained for a maximum of 12 months and then automatically deleted.
• Support communication data — support conversation records and logs are retained for 2 years for training and dispute resolution purposes.

Once the retention period expires, data is securely deleted using deletion methods that ensure it cannot be recovered.

Your data security is our top priority. Superbola applies multiple layers of technical and organizational security to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• Encryption of data in transit — all data transmitted between your browser and our servers is encrypted using TLS 1.3 protocol with a 256-bit SSL certificate.
• Encryption of data at rest — sensitive data such as financial information and KYC documents is encrypted at rest in the database using AES-256.
• Role-based access control — only employees who require data access to perform their duties are granted permission, with strict activity monitoring in place.
• Two-factor authentication (2FA) — available to all member accounts as an additional security layer that we strongly recommend.
• Regular security audits — our platform undergoes regular penetration testing and security audits by independent parties.
• Real-time threat monitoring — an active intrusion detection system monitors for suspicious activity 24 hours a day.

Superbola uses cookies and similar tracking technologies to enhance your platform experience. The following are the types of cookies we use:

8.1 Essential Cookies

These cookies are required for the platform's basic functions, such as maintaining your login session and remembering your security preferences. Essential cookies cannot be disabled as the platform will not function properly without them.

8.2 Functional Cookies

Saves your preferences such as selected language, display settings, and favorite games, so you don't need to reconfigure them every time you visit the platform.

8.3 Analytics Cookies

Helps us understand how members use the platform — which pages are visited most, which features are used most, and where experience bottlenecks occur. This data is used in aggregate and anonymized form to improve the platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the platform's functionality.

As a data subject, you hold a number of rights that you may exercise at any time. Superbola is committed to responding to every rights request within a maximum of 30 business days.

• Right of Access — You have the right to request a copy of any personal data we hold about you, along with information on how it is being used.
• Right of Correction — If your data is inaccurate or incomplete, you have the right to request an update or correction. Most profile data can be updated directly through your account settings.
• Right to Erasure — You have the right to request the deletion of your personal data. However, we may not be able to fulfill this request in full if the data is required for legal compliance.
• Right to Restriction of Processing — You have the right to request that we restrict the processing of your data in certain situations, such as when you dispute the accuracy of the data.
• Right to Data Portability — You have the right to receive your data in a structured, machine-readable format for transfer to another service.
• Right to Object to Processing — You have the right to object to the processing of your data for direct marketing purposes at any time without providing a reason.

To exercise these rights, contact the superbola support team via live chat within the platform. We will verify your identity before processing your request to ensure the security of your data.

Superbola may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable legal requirements, or new technologies we adopt.

Any material updates will be notified to you via the email address registered to your account and/or notifications displayed when you log in to the platform, at least 7 business days before the changes take effect.

For non-material changes — such as grammar corrections or clarifications that do not alter the substance of the policy — we will simply update the "Last Updated" date at the top of this page.

This document was last updated on January 1, 2026. Previous versions are available upon request from the Superbola support team if needed for reference purposes.