Privacy Policy — dewi19

1 Definitions

Throughout this Privacy Policy, the following terms carry the meanings defined below:

• "Platform" — The dewi19 website at https://dewi19.cam, all associated subdomains, and any mobile-optimized interfaces operated by dewi19.
• "Company" / "We" / "Us" / "Our" — dewi19, the operator of the Platform, including its officers, employees, agents, and authorized processors.
• "Player" / "You" / "Your" — Any individual who registers an account, browses, or otherwise interacts with the Platform.
• "Personal Data" — Any information that identifies or could reasonably identify a living individual, including name, date of birth, email address, payment details, device identifiers, and IP address.
• "Processing" — Any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• "Third Party" — Any individual, company, or organization that is not the Player or dewi19, including payment processors, game studios, and analytics providers.
• "KYC" — Know Your Customer; the identity and age-verification process required to unlock full account functionality and withdrawal rights.

2 Data We Collect

dewi19 collects the following categories of Personal Data from Players and Platform visitors:

2.1 Account Registration Data

• Full legal name
• Date of birth (used to verify the 21+ age requirement)
• Email address
• Mobile phone number
• City and province of residence within Indonesia (e.g., Jakarta, Surabaya, Bandung, Bali, Medan)
• Chosen username and hashed password

2.2 Identity Verification (KYC) Data

• Government-issued photo identification (National Identity Card / KTP, passport)
• Proof of address (utility bill, bank statement, or official correspondence)
• Proof of payment method ownership (bank account or e-wallet confirmation)
• Selfie or live photograph where required for enhanced verification

2.3 Financial Transaction Data

• Bank account details for deposits and withdrawals (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata)
• E-wallet account identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Transaction amounts, timestamps, and reference numbers
• Deposit and withdrawal history in Indonesian Rupiah (IDR/Rp)

2.4 Gaming Activity Data

• Bet history, game session logs, wager amounts, and outcomes
• Sports betting selections across BRI Liga 1, EPL, La Liga, Serie A, Bundesliga, Champions League, and other markets
• Game preferences and frequency of play across product categories including slots, live casino, and togel (Indonesia's traditional numbers lottery)
• Responsible gaming tool usage (deposit limits, self-exclusion requests, session time-outs)

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session duration, pages visited, and click-path data
• Cookie identifiers and similar tracking technologies (see Clause 7)

2.6 Communications Data

• Records of live chat conversations with our support team
• Email correspondence and support tickets
• Feedback, complaints, and survey responses

3 How We Collect Data

dewi19 collects Personal Data through the following channels:

• Direct submission: Information you provide when completing the registration form, submitting KYC documents, making deposits or withdrawal requests, or contacting our support team.
• Automated collection: Technical and device data collected automatically when you access the Platform, via cookies, server logs, and similar technologies.
• Third-party payment processors: Transaction confirmation data received from Indonesian banking partners and e-wallet providers when you deposit or withdraw funds.
• Game platform providers: Gaming activity logs transmitted by our game studio partners (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft) as part of their standard integration.
• Identity verification services: Results of automated or manual identity checks conducted via our KYC service providers.

4 Legal Basis for Processing

dewi19 processes your Personal Data on one or more of the following legal grounds:

5 How We Use Your Data

dewi19 uses the Personal Data we collect for the following specific purposes:

5.1 Account Operations

We use your registration information to create, maintain, and secure your account. This includes processing login requests, resetting passwords, and maintaining the integrity of the one-account-per-player policy described in our Terms & Conditions.

5.2 Payment Processing

Your bank account details, e-wallet identifiers, and transaction history are used exclusively to process deposits and withdrawals in Indonesian Rupiah (IDR/Rp) through your nominated payment channels. We do not store full bank account numbers in plaintext; sensitive financial data is tokenized and encrypted at rest.

5.3 Regulatory Compliance

KYC documentation and transaction records are retained to fulfil our obligations under applicable anti-money-laundering (AML) and counter-terrorism-financing (CTF) frameworks. We may be required to disclose certain data to regulatory or law enforcement authorities upon receipt of a lawful order.

5.4 Responsible Gaming

Gaming activity data — including bet frequency, session duration, and stake levels — is analyzed to identify Players who may be exhibiting signs of problem gambling. Where such indicators are detected, our responsible gaming team may proactively contact the Player or apply protective measures consistent with the tools described on our Responsible Gaming page.

5.5 Customer Support

Communications data is used to resolve support inquiries, handle complaints, and improve the quality of our Indonesian-speaking customer support service. Support interactions are recorded and retained for quality assurance and dispute resolution purposes.

5.6 Marketing & Promotions

Where you have opted in to receive marketing communications, we may send you promotional offers, bonus notifications, and updates relevant to your gaming preferences. You may withdraw consent for marketing communications at any time by updating your account preferences or contacting our support team. Withdrawal of marketing consent does not affect any other processing activity.

5.7 Platform Security & Fraud Prevention

Technical and device data — including IP addresses, session logs, and device fingerprints — are used to detect unauthorized access, identify duplicate account creation, and prevent bonus abuse, collusion, and money laundering. Suspicious activity may result in account restriction pending investigation.

6 Data Sharing

dewi19 does not sell or rent your Personal Data to third parties. We share data only in the following limited and controlled circumstances:

6.1 Payment Processors

We share necessary transaction data with Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to facilitate deposits and withdrawals. These providers process data under their own privacy policies and are independently responsible for their data handling practices.

6.2 Game Studio Partners

Your gaming activity data is shared with integrated game studio providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft) solely to the extent necessary to deliver game functionality, verify bet outcomes, and support dispute resolution. Game studios act as data processors under our instruction and are contractually prohibited from using your data for any other purpose.

6.3 Identity Verification Providers

KYC documents and personal identification data are transmitted to our identity verification service partners for automated or manual review. These providers are bound by strict data processing agreements and industry-standard security requirements.

6.4 Legal & Regulatory Disclosure

We may disclose Personal Data to law enforcement agencies, regulatory authorities, or courts where we are legally required to do so by a valid legal order, subpoena, or regulatory directive. Where permitted by law, we will notify affected Players of such disclosures.

6.5 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of dewi19's business assets, Player data may be transferred to the acquiring entity as part of that transaction. We will notify affected Players in advance of any such transfer and provide an opportunity to close their account if they do not wish their data to be transferred.

7 Cookies & Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They allow the website to recognize your device on subsequent visits and remember certain preferences or session information. dewi19 uses both first-party cookies (set by our own domain) and third-party cookies (set by our service partners).

7.2 Types of Cookies We Use

• Essential cookies: Required for the Platform to function. These include session authentication tokens, security cookies, and load-balancing identifiers. The Platform cannot operate without these cookies.
• Functional cookies: Remember your preferences — such as language settings and previously used payment methods — to improve your experience on return visits.
• Analytics cookies: Collect aggregated, anonymized data about how Players use the Platform (pages visited, features used, session duration) to help us improve functionality and user experience.
• Security cookies: Detect fraudulent activity and protect against unauthorized account access, including bot-detection and multi-device login monitoring.

7.3 Managing Cookies

You may configure your browser to block or delete cookies at any time. Please note that disabling essential cookies will impair or entirely prevent access to the Platform. Instructions for managing cookies are available in the help documentation for all major browsers. Where applicable law requires it, we will seek your consent before placing non-essential cookies on your device.

8 Data Retention

dewi19 retains Personal Data for the minimum period necessary to fulfil the purpose for which it was collected, subject to the following specific retention periods:

• Account and registration data: Retained for the duration of the active account relationship, plus a minimum of five (5) years following account closure, to meet AML record-keeping obligations.
• KYC documents: Retained for a minimum of five (5) years following the completion of the business relationship, in line with standard AML/CTF regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity logs: Retained for a minimum of three (3) years to support dispute resolution and responsible gaming monitoring.
• Customer support communications: Retained for a minimum of two (2) years from the date of the final communication in each support thread.
• Marketing preferences: Retained until you withdraw consent or close your account, whichever occurs first.
• Technical and device logs: Retained for a maximum of twelve (12) months, after which they are aggregated and anonymized.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized so that it can no longer be linked to any individual.

9 Data Security

dewi19 implements a comprehensive suite of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, or disclosure. Our security framework includes:

• 256-bit SSL/TLS encryption on all data transmitted between your device and our servers;
• Encryption at rest for all sensitive data stored in our database systems, including financial details and KYC documents;
• Role-based access controls limiting internal access to Personal Data to only those employees and contractors whose roles require it;
• Multi-factor authentication for all internal systems that store or process Player data;
• Regular penetration testing and security audits conducted by independent third-party cybersecurity specialists;
• Incident response procedures to detect, contain, and notify affected Players of any data breach within a reasonable timeframe.

While dewi19 takes every reasonable precaution to protect your data, no security system is completely impenetrable. You are also responsible for maintaining the confidentiality of your own account credentials. If you suspect your account has been compromised, contact our support team immediately at the email address in Clause 14.

10 Your Privacy Rights

As a Player on the dewi19 Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, contact us using the details in Clause 14. We will respond to all verified requests within 30 days.

Please note that certain rights may be limited where exercising them would conflict with our legal obligations — for example, we cannot delete KYC records that we are legally required to retain for AML purposes. We will always explain any such limitations clearly when responding to your request.

11 Minors & Age Restriction

The dewi19 Platform is strictly intended for adults aged 21 years and over. 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, make any deposit, or access any gaming Services on the Platform.

Where dewi19 discovers or has reasonable grounds to believe that Personal Data has been collected from a person under the age of 21, we will take the following steps without undue delay:

• Immediately suspend the associated account and halt any pending transactions;
• Delete all Personal Data associated with the underage account to the extent permitted by law;
• Refund any real-money deposits made, net of any amounts required to be reported or withheld under applicable AML regulations.

We encourage parents and guardians to make use of parental-control software to prevent minors from accessing online gaming platforms. If you believe a minor has accessed or registered on dewi19, please contact us immediately at the email address in Clause 14.

12 International Data Transfers

dewi19's primary player base is located in Indonesia, and we process the majority of Personal Data within secure data center infrastructure serving the Southeast Asian region. However, some of our third-party service providers — including game studio partners and identity verification providers — may process data in jurisdictions outside Indonesia.

Where such transfers occur, dewi19 takes steps to ensure that appropriate safeguards are in place to protect your Personal Data, including:

• Contractual data processing agreements with all third-party processors that impose data protection standards equivalent to those described in this Privacy Policy;
• Requiring recipient entities to implement technical security measures consistent with our own standards, including encryption at rest and in transit;
• Periodic review of the data protection practices of key third-party partners.

By registering an account on dewi19 and accepting this Privacy Policy, you acknowledge and consent to the international transfer of your Personal Data under the safeguards described in this clause.

13 Policy Amendments

dewi19 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or business operations. When material changes are made, we will notify Players by:

• Updating the "Effective Date" displayed at the top of this page;
• Sending an email notification to your registered email address; and/or
• Displaying a prominent notice on the Platform at the time of your next login.

Your continued use of the Platform after receiving notification of a material change constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you must cease using the Platform and may request account closure by contacting our support team.

We recommend that you review this Privacy Policy periodically to stay informed of how dewi19 is protecting your Personal Data.

14 Contact Us

If you wish to exercise any of your privacy rights, have a question about this Privacy Policy, or wish to raise a concern about how dewi19 handles your Personal Data, please contact our Data Protection team using the details below. We aim to respond to all privacy-related inquiries within 30 days of receipt.

For concerns related to responsible gaming, deposit limits, or self-exclusion, please refer to our dedicated Responsible Gaming page. For a full overview of your rights and obligations as a dewi19 player, see our Terms & Conditions.