Privacy Policy

1. Introduction & Scope

kwin77 ("we," "us," "our") operates the online betting platform accessible at https://kwin77.cam (the "Platform"). We respect your privacy and are committed to handling your personal data responsibly, transparently, and in accordance with internationally recognised data-protection principles.

This Privacy Policy applies to all personal information collected when you visit our website, create a kwin77 account, make deposits or withdrawals, place bets, contact our customer support team, or interact with the Platform in any other way. It applies equally to players located in Indonesia and to users accessing kwin77 from other jurisdictions.

By creating an account or continuing to use the Platform, you confirm that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, you should discontinue use of the Platform and contact us to arrange account closure.

2. Definitions

• "Personal Data" — Any information that identifies or can reasonably be used to identify you as a natural person, including name, national identity number (KTP), email address, phone number, IP address, and financial account details.
• "Processing" — Any operation performed on Personal Data, including collection, recording, storage, use, transmission, erasure, or destruction.
• "Controller" — kwin77 in its capacity as the entity that determines the purposes and means of processing your Personal Data.
• "Processor" — Any third-party service provider that processes Personal Data on our behalf under a binding data-processing agreement.
• "Consent" — A freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
• "KYC" (Know Your Customer) — Identity and address verification procedures required by our anti-money-laundering compliance obligations.

3. Data We Collect

kwin77 collects Personal Data that is necessary and proportionate to provide our services. The table below summarises the categories of data we process:

Category	Examples	Mandatory?
Identity Data	Full legal name, date of birth, KTP / passport number, selfie photograph	Yes — KYC
Contact Data	Email address, Indonesian mobile number, residential address	Yes
Financial Data	Bank account number (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP), e-wallet ID (OVO, DANA, GoPay, ShopeePay), transaction history	Yes — payments
Betting & Gaming Data	Wager history, game preferences, session duration, win/loss records	Yes — service delivery
Technical Data	IP address, device type, browser, operating system, time-zone (WIB default)	Automatic
Usage Data	Pages visited, click paths, session length, referral source	Automatic
Communications Data	Live-chat transcripts, support tickets, email correspondence	When you contact us
Marketing Preferences	Opted-in channels, promotional history, bonus claim records	Optional

We do not collect sensitive personal data (such as racial or ethnic origin, religious beliefs, health data, or biometric data) unless you voluntarily provide such information in support-channel communications, in which case we handle it with additional safeguards.

4. How We Collect Data

4.1 Data You Provide Directly

We collect Personal Data that you voluntarily submit when you register an account, complete the KYC verification process, make deposits or withdrawal requests, contact our customer support team (via live chat, WhatsApp, or email), respond to surveys, or claim promotions.

4.2 Data Collected Automatically

When you access the Platform, our servers automatically log Technical Data and Usage Data. This includes your IP address, the device and browser you are using, pages you visit, and how you navigate between sections. We use industry-standard analytics tools to aggregate and analyse this information.

4.3 Data from Third Parties

In certain circumstances, we receive Personal Data from external sources, including:

• Payment processors and Indonesian banks — transaction confirmation data from BCA, BRI, BNI, Mandiri, CIMB Niaga, and e-wallet providers (OVO, DANA, GoPay, ShopeePay) to verify deposits and process withdrawals.
• Identity verification providers — third-party KYC platforms may confirm the authenticity of your identity documents.
• Fraud-detection services — risk-scoring systems that flag suspicious account activity.
• Analytics partners — aggregated, pseudonymised data on platform performance.

5. Purpose of Processing

kwin77 processes your Personal Data for the following specific purposes:

• Account creation and authentication — to establish and maintain your kwin77 account, verify your identity, and authenticate logins securely.
• Service delivery — to enable betting, gaming, deposits, withdrawals, and access to all Platform features.
• KYC and regulatory compliance — to satisfy our Anti-Money Laundering (AML) and Know Your Customer obligations, including age verification (21+ requirement) and source-of-funds checks.
• Payment processing — to execute and record all financial transactions in Indonesian Rupiah (IDR) via local banking and e-wallet channels.
• Customer support — to respond to inquiries, resolve disputes, and provide multilingual (including Indonesian-language) assistance.
• Responsible gaming — to monitor betting behaviour, enforce self-exclusion and deposit-limit tools, and identify potential problem-gambling patterns.
• Security and fraud prevention — to detect, prevent, and investigate unauthorised access, bonus abuse, multi-accounting, and other fraudulent activity.
• Personalisation and marketing — to deliver relevant promotions, loyalty-program updates, and tailored content, subject to your marketing preferences.
• Platform improvement — to analyse usage patterns, fix bugs, conduct A/B testing, and enhance the overall user experience.

6. Legal Basis for Processing

kwin77 processes your Personal Data on one or more of the following legal grounds:

• Contractual necessity — processing required to fulfil our obligations under the User Agreement you accepted upon registration (e.g., operating your account, processing bets and payments).
• Legal obligation — processing required to comply with applicable laws and regulations, including AML obligations and age-verification requirements.
• Legitimate interests — processing in pursuit of kwin77's legitimate business interests (fraud prevention, platform security, service improvement), provided those interests are not over ridden by your rights and interests.
• Consent — where we rely on your explicit consent for specific processing activities, such as direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing & Disclosure

kwin77 does not sell, rent, or trade your Personal Data to any third party for their own marketing purposes. We may share your data only in the following limited circumstances:

7.1 Service Providers (Processors)

We engage trusted third-party processors who act exclusively on our behalf under binding data-processing agreements that prohibit independent use of your data. These include payment gateway operators, cloud infrastructure providers, KYC verification vendors, customer support software providers, and fraud detection platforms.

7.2 Financial Institutions

To execute deposits and withdrawals, we share necessary transaction details with the relevant Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP) and e-wallet providers (OVO, DANA, GoPay, ShopeePay). Only the minimum information required to complete the transaction is transmitted.

7.3 Regulatory and Law Enforcement Authorities

We may disclose Personal Data to governmental bodies, law enforcement agencies, or regulators when required to do so by law, court order, or binding regulatory directive. In such cases, we will disclose only the information strictly required and, where legally permissible, will notify you.

7.4 Business Transfers

In the event of a merger, acquisition, asset sale, or corporate restructuring involving kwin77, your Personal Data may be transferred to the successor entity. We will notify affected users via email or a prominent notice on the Platform before any such transfer takes effect, and the successor will be bound by the terms of this Privacy Policy.

8. Data Retention

We retain your Personal Data only for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required by law. The following retention periods apply:

• Active account data — retained for the duration of your account's existence and updated as information changes.
• Transaction and betting records — retained for a minimum of five (5) years from the date of the transaction, in line with standard financial record-keeping obligations.
• KYC documents — retained for a minimum of five (5) years following account closure or the last transaction, whichever is later.
• Customer support communications — retained for three (3) years from the date of the last interaction.
• Marketing consent records — retained until you withdraw consent, plus an additional one (1) year for audit purposes.
• Technical and usage logs — retained for twelve (12) months, after which they are aggregated or anonymised.

Upon expiry of the applicable retention period, we securely delete or irreversibly anonymise your Personal Data so that it can no longer be associated with you.

9. Security Measures

kwin77 employs a comprehensive, layered security framework to protect your Personal Data against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• TLS / SSL encryption — all data transmitted between your browser and our servers is encrypted using Transport Layer Security (TLS 1.2 or higher).
• Encryption at rest — sensitive data stored on our servers, including financial account details and KYC documents, is encrypted using AES-256.
• Access controls — Personal Data is accessible only to authorised kwin77 personnel with a documented need-to-know, enforced through role-based access controls and multi-factor authentication.
• Regular security audits — we conduct periodic internal reviews and engage independent third-party auditors to test our systems for vulnerabilities.
• Fraud monitoring — automated systems continuously monitor for suspicious login attempts, unusual transaction patterns, and other indicators of account compromise.
• Incident response — in the event of a confirmed data breach affecting your Personal Data, we will notify you without undue delay and take immediate remedial action.

While we implement industry-leading safeguards, no online platform can guarantee absolute security. You are also responsible for protecting your own account credentials and should immediately contact our support team if you suspect unauthorised access.

10. Your Rights

As a user of kwin77, you have the following rights with respect to your Personal Data. To exercise any of these rights, please contact our support team at [email protected] with the subject line "Privacy Rights Request." We will respond within 30 days.

• Right of Access — you may request a copy of the Personal Data we hold about you, together with information about how it is processed.
• Right to Rectification — you may request correction of any inaccurate or incomplete Personal Data we hold.
• Right to Erasure — you may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restriction — you may request that we restrict processing of your data in certain circumstances, such as while a dispute regarding accuracy is being resolved.
• Right to Data Portability — where processing is based on your consent or contractual necessity, you may request your data in a structured, commonly used, machine-readable format.
• Right to Object — you may object to processing based on our legitimate interests, including direct marketing. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent — where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

11. Cookies & Tracking Technologies

kwin77 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and gather analytics data. Cookies are small text files stored on your device by your browser. The categories of cookies we use are as follows:

• Strictly necessary cookies — essential for the Platform to function. They enable authentication, session management, and security features. These cannot be disabled without impairing Platform functionality.
• Functional cookies — remember your preferences such as language, preferred deposit method, and interface settings to improve your experience across sessions.
• Analytics cookies — collect aggregated, pseudonymised data about how users navigate the Platform, enabling us to identify performance bottlenecks and improve usability.
• Marketing cookies — used, with your consent, to deliver relevant promotions and measure the effectiveness of our campaigns.

You can manage cookie preferences through your browser settings. Disabling certain cookie categories may affect Platform functionality. Most browsers allow you to refuse cookies, delete existing cookies, or receive a warning before a cookie is stored.

12. Minors & Age Restriction

kwin77 services are strictly intended for adults aged 21 and over. We do not knowingly collect, process, or retain Personal Data belonging to individuals under the age of 21. All account registrations require age confirmation, and KYC verification includes mandatory date-of-birth verification.

If we become aware that Personal Data has been collected from a person under 21 without verified parental consent, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on our Platform, please contact us immediately at [email protected].

13. Policy Changes

kwin77 reserves the right to update this Privacy Policy at any time to reflect changes in our data-processing practices, applicable laws, or Platform features. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page;
• Display a prominent notice on the Platform for at least 14 days; and
• Send a notification to your registered email address for changes that materially affect your rights.

Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this page periodically to stay informed about how we protect your data.

14. Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data-processing practices, please contact our Data Protection team:

We take all privacy concerns seriously and will investigate your complaint thoroughly. If you are not satisfied with our response, you may escalate your complaint to the relevant data-protection authority in your jurisdiction.