Privacy Policy — dwv99

dwv99 ("we", "us", "our", or "the Company") is committed to protecting the privacy and personal data of every individual who accesses or uses the dwv99 platform at https://dwv99.ws (the "Platform"). This Privacy Policy describes in detail how we collect, use, store, share, and protect personal data relating to registered Members and visitors, and explains the rights that you hold in respect of that data.

This Privacy Policy applies to all users of the dwv99 Platform, including individuals who browse the site without registering an account, individuals who register but have not yet made a deposit, and fully active Members who use the full range of dwv99 services including slots, live casino, sportsbook betting, and togel (Indonesia's traditional numbers lottery).

By accessing the Platform or registering an account, you confirm that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not consent to this Privacy Policy, you must cease using the Platform immediately.

This Privacy Policy should be read in conjunction with the Terms & Conditions and the Responsible Gaming Policy, both of which are incorporated by reference into this document. In the event of any conflict between this Privacy Policy and the Terms & Conditions on a matter of data privacy, this Privacy Policy shall prevail.

For the purposes of this Privacy Policy, the data controller — the entity that determines the purposes and means of processing your personal data — is the Company that owns and operates the dwv99 Platform. The Company is incorporated under the laws of its jurisdiction of registration and holds an internationally recognised gaming licence that governs its operations.

As data controller, the Company is responsible for ensuring that all personal data processing activities carried out on the Platform comply with applicable data protection law and the principles set out in this Privacy Policy.

For any queries relating to the Company's identity as data controller, or to obtain the Company's registered details, please contact the compliance team at [email protected]. The compliance team will respond to verified data controller enquiries within five business days.

dwv99 collects personal data across several categories, each serving a specific and documented operational purpose. The table below provides a comprehensive overview of the categories of personal data we collect and the primary purpose for which each category is collected.

dwv99 does not collect special categories of personal data (as defined under international data protection standards) such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where a government-issued identity document submitted for KYC purposes incidentally contains such information, in which case that information is not extracted, recorded, or processed separately.

dwv99 collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact the support team, respond to a survey, or opt in to a promotion, you actively provide personal data to dwv99.
• Automatically through your use of the Platform: When you browse or interact with the dwv99 Platform, technical and usage data is collected automatically via server logs, cookies, and similar tracking technologies. This data is collected regardless of whether you are logged into your account.
• From third-party service providers: dwv99 may receive personal data about you from payment processors (for deposit and withdrawal confirmation), identity verification providers (for KYC checks), and fraud-screening services. Data received from these sources is used solely for the stated purpose and is not combined with marketing data.
• From publicly available sources: In the course of AML screening, the Company may cross-reference your details against publicly available watchlists, sanctions databases, or politically exposed persons (PEP) registries. This is a compliance obligation and is not used for commercial profiling.

dwv99 processes personal data only where a lawful basis for doing so exists. The principal purposes for which we process personal data, together with the corresponding legal basis, are as follows:

• Contract performance: Processing your identity, contact, financial, and transaction data is necessary to create and manage your account, process deposits and withdrawals, and provide access to games and betting markets. Without this processing, the contractual relationship between you and dwv99 cannot be established or maintained.
• Legal obligation: Processing your identity and financial data for KYC verification and AML screening is required by the Company's compliance obligations under internationally applicable anti-money laundering and counter-terrorism financing regulations.
• Legitimate interests: Processing technical and usage data for fraud detection, duplicate account prevention, platform security, and platform improvement serves the legitimate interests of dwv99 and of our Member community, provided those interests are not outweighed by your privacy rights.
• Consent: Processing your contact data and marketing preferences to send you promotional offers, bonus notifications, and seasonal promotions (including during Ramadhan, Idul Fitri, and Indonesian Independence Day) is carried out on the basis of your freely given, informed, and revocable consent. You may withdraw this consent at any time.
• Vital interests / responsible gaming: In limited circumstances, dwv99 may process gameplay and financial data to fulfil responsible gaming obligations — for example, to identify patterns that may indicate problem gambling — in the vital interests of the Member concerned.

dwv99 does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only with the categories of recipients described below, and only to the extent necessary for the stated purpose:

• Payment service providers: To process your deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, OVO, DANA, GoPay, ShopeePay, LinkAja, or USDT networks, we share your name, account number, and transaction details with the relevant payment provider. These providers process your data solely as our data processor, under contractual obligations of confidentiality.
• Identity verification providers: To complete KYC checks, copies of your identity documents and biographic data are transmitted to our identity verification partner. This partner processes your data solely for the purpose of verifying your identity and returning a verification decision to dwv99.
• Fraud prevention and AML screening services: Transaction and technical data may be shared with fraud prevention platforms and sanctions screening services. These services help us identify suspicious activity, prevent bonus abuse, and comply with AML/CTF obligations.
• Game studios and software providers: When you play a game provided by a third-party studio (such as Pragmatic Play, Evolution Gaming, PG Soft, NetEnt, Microgaming, or Spribe), your session data — including wager amounts and game outcomes — is processed by that studio's servers. These studios are licensed and audited providers operating under strict data handling obligations.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory mandate, dwv99 will disclose personal data to the relevant authority. We will notify you of any such disclosure where we are legally permitted to do so.
• Corporate successors: In the event of a merger, acquisition, or sale of substantially all of the Company's assets, personal data held by dwv99 may be transferred to the acquiring entity, subject to equivalent privacy protections.

The dwv99 Platform serves members across Indonesia — from Jakarta and Surabaya to Medan, Bandung, Bali, Semarang, and beyond — and is operated by a Company incorporated outside Indonesia. As a result, your personal data will necessarily be transferred to and processed in jurisdictions outside Indonesia.

dwv99 takes the following safeguards to protect your personal data when it is transferred internationally:

• All data transfers to third-party processors (payment providers, KYC providers, game studios) are governed by contractual data processing agreements that impose data protection standards equivalent to those applied by dwv99 directly.
• Server infrastructure used to store and process dwv99 Member data is housed in data centres that hold recognised security certifications (such as ISO 27001) and are protected by physical and logical access controls.
• All international data transfers are conducted over encrypted connections (256-bit SSL/TLS) and no personal data is transmitted via unencrypted channels.

By registering an account on dwv99, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Indonesia as described in this clause, subject to the safeguards described above.

dwv99 retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, subject to any applicable legal or regulatory retention requirement. The following retention periods apply as general guidelines:

• Account and identity data: Retained for a minimum of five years following permanent account closure, in compliance with AML record-keeping obligations.
• KYC documents: Retained for a minimum of five years following account closure or the completion of the relevant transaction, whichever is later.
• Transaction records: Retained for a minimum of five years from the date of the transaction, for audit and dispute resolution purposes.
• Gameplay data: Retained for a minimum of three years from the date of the relevant session, for dispute resolution and responsible gaming monitoring purposes.
• Support communications: Retained for two years from the date of the last communication, for quality assurance and dispute resolution purposes.
• Technical and usage data: Retained for up to 12 months from collection, after which it is anonymised or deleted.
• Marketing preference data: Retained until you withdraw consent for marketing communications, after which it is deleted or flagged as opted-out within 30 days.

At the end of the applicable retention period, personal data is securely deleted from active systems and any backup copies are overwritten in accordance with our data destruction policy. Data that has been anonymised — i.e., stripped of all personally identifiable information — may be retained indefinitely for aggregate statistical analysis.

dwv99 implements a layered technical and organisational security framework designed to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Key security measures include:

• Encryption: All data transmitted between your device and the Platform is protected by 256-bit SSL/TLS encryption. Data stored on our servers — including KYC documents, financial records, and account credentials — is encrypted at rest using AES-256.
• Access controls: Access to Member personal data is restricted to authorised personnel on a strict need-to-know basis. All internal access is logged, monitored, and subject to regular review. Privileged access accounts are protected by multi-factor authentication.
• Intrusion detection: The dwv99 platform infrastructure is monitored 24/7 by automated intrusion detection and prevention systems. Anomalous access patterns trigger immediate alerts to the security team.
• Third-party audits: The Platform undergoes regular independent security assessments, including penetration testing and vulnerability scanning, conducted by certified external security firms.
• Staff training: All personnel with access to Member data receive mandatory data protection and security training as part of their onboarding and on an annual refresher basis.
• Incident response: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, dwv99 will notify affected Members via the email address registered to their account within 72 hours of the breach being identified, to the extent that the law permits.

dwv99 uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage objects) to operate the Platform, remember your preferences, detect fraud, and understand how the Platform is used. By using the Platform, you consent to the use of cookies as described in this clause.

The cookies used by dwv99 fall into the following categories:

• Strictly necessary cookies: These cookies are essential for the Platform to function. They enable you to log in to your account, maintain your session, and navigate between pages securely. These cookies cannot be disabled without impairing the Platform's core functionality.
• Functional cookies: These cookies remember your preferences — such as your preferred deposit method, language settings, and game lobby layout — to personalise your experience on the Platform. They are set only with your consent.
• Analytical cookies: These cookies collect anonymised data about how Members use the Platform — such as which pages are visited most frequently and where users encounter errors. This data is used to improve the Platform's design and content. It is not used to identify individual users.
• Security cookies: These cookies support our fraud detection and duplicate account prevention systems by storing a device fingerprint and session identifier that help us identify unusual login patterns or concurrent sessions from multiple geographic locations.

dwv99 does not use third-party advertising cookies or permit third-party ad networks to place tracking cookies on the Platform. The only third-party cookies present on the Platform are those set by our integrated game studio providers (such as Pragmatic Play and Evolution Gaming) as part of their game delivery infrastructure, subject to their own privacy policies.

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in to your dwv99 account.

dwv99 respects your rights as a data subject. Subject to applicable law and our legitimate interests as a regulated platform operator, you hold the following rights in respect of your personal data:

To exercise any of the above rights, submit your request in writing to [email protected] from the email address registered to your dwv99 account, stating clearly which right you wish to exercise and the specific data concerned. We will acknowledge your request within two business days and respond fully within 30 days. Where your request is complex, we may extend this period by a further 30 days, in which case we will notify you of the extension.

Please note that certain rights are subject to exceptions. For example, we are required by law to retain KYC and transaction records for a minimum of five years after account closure; a request for erasure of such data will be declined to the extent necessary to fulfil this obligation, and you will be informed accordingly.

The dwv99 Platform is strictly intended for adults aged 21 years and over. We do not knowingly collect or process personal data from individuals under the age of 21. Age verification is a mandatory step in the account registration process, and KYC verification requires submission of a government-issued identity document confirming that the Member is at least 21 years of age.

If we become aware that personal data has been collected from an individual under the age of 21 — whether as a result of a false declaration at registration or any other means — we will immediately suspend the relevant account, void all wagers placed during the underage period, return any deposits (net of any winnings derived from those deposits), and permanently delete the personal data of the underage individual in accordance with our data retention policy.

With your explicit consent, dwv99 may send you promotional communications regarding bonuses, new game releases, sportsbook promotions (including BRI Liga 1 match specials, Timnas Indonesia tournament coverage, EPL accumulators, and Champions League markets), seasonal offers tied to Indonesian cultural events such as Ramadhan, Idul Fitri, and Indonesian Independence Day, and other platform updates. Marketing communications may be sent via email to the address registered to your account.

You may withdraw your consent to receive marketing communications at any time by:

• Clicking the unsubscribe link included in any marketing email sent by dwv99;
• Updating your communication preferences in your account settings; or
• Contacting the support team at [email protected] and requesting removal from all marketing lists.

Withdrawal of marketing consent will be processed within 30 days of your request. Please note that withdrawing marketing consent does not affect the lawfulness of any processing carried out prior to withdrawal, and does not prevent dwv99 from sending you transactional communications relating to your account — such as deposit confirmations, withdrawal notifications, KYC verification updates, and security alerts — which are sent on the basis of contract performance rather than consent.

The dwv99 Platform may contain links to third-party websites or services — for example, links to payment provider portals or game studio landing pages — for informational or transactional purposes. dwv99 does not control the privacy practices of third-party websites and is not responsible for the content or privacy policies of any external site.

When you navigate away from the dwv99 Platform to a third-party site, this Privacy Policy no longer applies. You should review the privacy policy of any third-party site you visit to understand how that site collects and processes your personal data. dwv99 does not accept any liability for the privacy practices of third-party sites linked from the Platform.

If you believe that a third-party link on the Platform is directing you to a site that engages in unsafe or unlawful data practices, please report it to [email protected] so that we can review and, where appropriate, remove the link.

dwv99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the scope of services offered on the Platform. The most current version of this Privacy Policy will always be available at https://dwv99.ws/privacy-policy. The "Last Updated" date displayed at the top of this page will be revised whenever a substantive change is made.

Where a proposed amendment materially affects your rights or the purposes for which your personal data is processed, dwv99 will notify registered Members via the email address associated with their account at least 14 days before the amended policy takes effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Privacy Policy.

If you do not agree with an amendment to this Privacy Policy, you must cease using the Platform prior to the effective date of the amendment and contact the support team to request account closure. Any personal data held at the time of closure will be retained for the minimum periods required by law, as described in the Data Retention section above, after which it will be securely deleted.

If you have any questions, concerns, or complaints about this Privacy Policy, about how dwv99 processes your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Protection team using the details below. Our support team is available 24 hours a day, 7 days a week, including during Ramadhan, Idul Fitri, and Indonesian Independence Day (17 August).

• Email: [email protected]
• Support Hours: 24/7 — WIB (UTC+7)
• Subject Line for Data Requests: Use "DATA REQUEST — [Your Username]" for faster routing to the compliance team.
• Response Time: Acknowledgement within 2 business days; full response within 30 days.

For formal legal or regulatory notices relating to data protection, please send written correspondence to the Company's registered address, available upon request from the compliance team. All formal notices should be clearly marked "Data Protection — Legal Notice" to ensure timely routing.