Privacy Policy — win4ds

Throughout this Policy, the following terms carry the meanings set out below:

win4ds acts as the Data Controller for all Personal Data collected through the win4ds platform. win4ds is an internationally licensed online betting operator serving players primarily based in Indonesia. All data Processing activities described in this Policy are conducted under win4ds's operating license and in accordance with the data protection standards required by that license.

win4ds appoints Data Processors only under written contracts that impose data protection obligations no less stringent than those set out in this Policy. win4ds remains responsible for ensuring that all Data Processors handle your Personal Data in accordance with applicable requirements.

win4ds collects the minimum Personal Data necessary to provide its services securely and in compliance with its licensing obligations. The categories of data we collect are set out below:

3.1 Identity & Contact Data

• Full legal name, date of birth, and nationality.
• Email address and phone number (including WhatsApp number if provided).
• Residential address (city, province, postal code — Indonesia).
• Government-issued photo ID number (KTP number for Indonesian residents, passport number for other nationalities).

3.2 Financial Data

• Bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, or other supported Indonesian banks.
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, or LinkAja accounts linked to your Player Account.
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method references — all denominated in IDR (Rp).
• Source-of-funds documentation provided in response to AML review requests.

3.3 Gaming & Behavioural Data

• Betting and wagering history, including game type, stake amounts, outcomes, and session duration.
• Responsible gaming tool settings you have activated (deposit limits, session limits, self-exclusion status).
• Bonus eligibility status, wagering requirement progress, and promotion redemption history.
• Customer support interaction records, including chat transcripts and email correspondence.

3.4 Technical & Device Data

• IP address and approximate geolocation (country and city level) at the time of each login and transaction.
• Device type, operating system, browser type and version, and screen resolution.
• Session timestamps, page navigation paths, and feature interaction logs.
• Cookie identifiers and similar tracking technologies as described in Clause 9.

3.5 Verification Documents

• Scanned or photographed copies of identity documents submitted during KYC verification (KTP, passport, or equivalent).
• Proof-of-address documents (utility bill, bank statement, or equivalent issued within the last three months).
• Selfie or liveness-check images submitted through the KYC verification workflow.

win4ds collects Personal Data through the following channels:

win4ds processes your Personal Data only where a lawful basis exists. The primary purposes and their corresponding legal bases are set out in the table below:

6.1 Principle of Minimum Disclosure. win4ds does not sell, rent, or trade your Personal Data to any third party for their own commercial purposes. Data is shared externally only where necessary to deliver the win4ds service or to meet a legal obligation, and only with parties bound by appropriate data protection commitments.

6.2 Categories of Authorised Recipients. Your Personal Data may be disclosed to the following categories of third party:

• KYC and identity verification providers: Contracted third-party services that verify the authenticity of identity documents and perform age, PEP (Politically Exposed Person), and sanctions-list checks required under win4ds's licensing conditions.
• Payment gateways and banking partners: Indonesian bank transfer processors and e-wallet platforms (including those facilitating OVO, DANA, GoPay, ShopeePay, and LinkAja transactions) necessary to execute your deposit and withdrawal instructions.
• Fraud prevention and AML technology providers: Specialist vendors that supply risk-scoring, device intelligence, and transaction monitoring tools that help protect the platform and its players.
• Responsible gaming tool providers: Third-party platforms that power self-exclusion registries or problem gambling support referral pathways.
• Cloud infrastructure and hosting providers: Secure, enterprise-grade infrastructure partners on whose servers win4ds platform data is stored and processed.
• Legal, regulatory, and law enforcement authorities: Where win4ds is legally required to disclose data in response to a valid court order, regulatory inspection, or law enforcement request, or where disclosure is necessary to prevent or report fraud, money laundering, or other criminal activity.
• Professional advisers: Lawyers, auditors, and insurers who require access to limited data in the course of providing professional services to win4ds, subject to strict confidentiality obligations.

6.3 Business Transfers. In the event that win4ds undergoes a merger, acquisition, asset sale, or restructuring, your Personal Data may be transferred to the acquiring entity as part of that transaction. win4ds will notify affected Players via the registered email address prior to any such transfer taking effect and will ensure the receiving entity is bound by privacy obligations at least equivalent to those in this Policy.

7.1 Active Accounts. While your Player Account remains open and active, win4ds retains all Personal Data necessary to provide the service, comply with legal obligations, and resolve disputes. Gaming and transaction history is retained for the lifetime of the account to enable accurate audit trails and bonus eligibility assessments.

7.2 Closed Accounts. Following account closure — whether initiated by you or by win4ds — Personal Data is retained for a minimum of five (5) years from the date of closure. This retention period reflects win4ds's AML record-keeping obligations and the standard limitation period for potential legal claims. KYC documents are retained for the same minimum period.

7.3 Deletion Requests. You may request erasure of your Personal Data (see Clause 10). Where erasure is technically and legally possible — i.e., where no legal obligation requires continued retention — win4ds will delete or anonymize the relevant data within 30 days of a verified request. Where a legal retention obligation applies, win4ds will inform you of the specific obligation and the date on which deletion will occur once that obligation expires.

7.4 Anonymization. Where full erasure is not possible within the retention period, win4ds may anonymize Personal Data so that it can no longer be linked to any identifiable individual. Anonymized data may be retained indefinitely for statistical and product improvement purposes.

win4ds applies a layered technical and organisational security framework to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the win4ds platform, including login sessions, payment flows, and document uploads.
• Encryption at rest for all sensitive Personal Data and financial records stored on win4ds servers.
• Role-based access controls (RBAC) ensuring that only authorised win4ds personnel with a documented business need can access specific categories of Personal Data.
• Multi-factor authentication (MFA) required for all win4ds staff accessing production systems containing Personal Data.
• Continuous intrusion detection and security monitoring across all platform infrastructure, with automated alerting and incident response procedures in place.
• Regular penetration testing and third-party security audits conducted at least annually by independent security specialists.
• Secure document disposal protocols for KYC documents that have passed the mandatory retention period.

Despite these measures, no online system can guarantee absolute security. In the event of a data breach that is likely to result in a material risk to your rights or interests, win4ds will notify affected Players without undue delay via the registered email address and will take all reasonable steps to mitigate the impact of the breach.

9.1 What We Use. The win4ds platform uses cookies and similar tracking technologies (local storage, session tokens, and pixel tags) to enable core platform functionality, maintain your login session, remember your preferences, and collect aggregate analytics data about how the platform is used.

9.2 Categories of Cookies. The cookies deployed on win4ds fall into the following categories:

9.3 Managing Cookies. You can control non-essential cookies through your browser settings. Disabling strictly necessary cookies will prevent you from logging into your Player Account. Please note that clearing all cookies will log you out of an active session and reset your stored preferences.

win4ds recognises and respects the following data subject rights. To exercise any of these rights, contact us at [email protected] with the subject line "Privacy Request — [Right Type]". We will respond within 30 days of receiving a verified request.

The win4ds platform is strictly intended for adults aged 21 and over. win4ds does not knowingly collect Personal Data from any individual under the age of 21. If win4ds becomes aware that a Player Account has been registered by or used by a person under 21 years of age, the account will be suspended immediately, all balances will be held pending investigation, and any Personal Data relating to the minor will be deleted as swiftly as compliance obligations allow.

If you are a parent or guardian and believe that a person under 21 in your care has registered an account on win4ds, please contact us immediately at [email protected] with the subject line "Underage Account Report" and we will investigate and take appropriate action within 24 hours of a verified report.

12.1 Transfer Necessity. As an internationally licensed platform, win4ds may transfer Personal Data to servers and Data Processors located outside Indonesia. This may occur when using cloud infrastructure providers, KYC verification vendors, or fraud-prevention technology partners whose data processing infrastructure is hosted in jurisdictions outside Indonesia.

12.2 Transfer Safeguards. win4ds ensures that any international transfer of Personal Data is subject to appropriate safeguards. These include contractual clauses in Data Processor agreements that impose data protection obligations equivalent to those in this Policy, selection of processors that operate in jurisdictions with recognized data protection standards, and technical measures such as end-to-end encryption for data in transit.

12.3 No Indiscriminate Transfer. Personal Data is not transferred internationally beyond what is necessary for the specific service functions described in Clause 5. win4ds does not transmit bulk Player databases to jurisdictions without adequate data protection frameworks.

13.1 Right to Update. win4ds reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, platform features, or data Processing practices. The "Last Updated" date at the top of this page reflects the most recent revision.

13.2 Notification of Material Changes. Where an amendment materially affects your privacy rights or the way win4ds Processes your Personal Data, win4ds will notify you via the registered email address at least fourteen (14) days before the revised Policy takes effect. For changes required by immediate legal or regulatory obligation, the notice period may be shortened, and the effective date will be clearly stated in the notification.

13.3 Continued Use. Your continued use of the win4ds platform after the effective date of any amendment constitutes your acknowledgment of the revised Policy. If you do not accept the revised terms, you should stop using the platform and may request account closure in accordance with the win4ds Terms & Conditions.

For all privacy-related enquiries, data subject rights requests, or complaints regarding the way win4ds handles your Personal Data, please contact the win4ds support team using the details below:

win4ds aims to resolve all privacy complaints directly and promptly. If you are not satisfied with our response, you have the right to escalate your complaint to the data protection supervisory authority in the jurisdiction in which win4ds holds its gaming license or, where applicable, to a consumer protection body in Indonesia.