Privacy Policy

1. Introduction and Scope

This Privacy Policy describes how iyawin ("we", "us", "our") collects, uses, stores, protects, and discloses personal information obtained from users ("you", "your") of our website, mobile applications, and related services (collectively, the "Platform").

By creating an account, accessing our Platform, or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with any aspect of this Privacy Policy, you must not use the iyawin Platform.

This Privacy Policy applies to all users of iyawin, including registered players, visitors to our website, and individuals who interact with our customer support channels. It supplements but does not supersede our Terms & Conditions, which govern your use of the Platform.

2. Data Controller Information

iyawin acts as the data controller for personal information collected through our Platform. This means we determine the purposes and means of processing your personal data and are responsible for ensuring compliance with applicable data protection laws.

Data Controller Contact Details:

• Company Name: iyawin
• Email: [email protected]
• General Support Email: [email protected]
• Data Protection Officer: Available upon request through the privacy email address above

3. Information We Collect

iyawin collects various types of information to provide, maintain, improve, and personalize our services. The categories of personal information we collect include:

3.1 Information You Provide Directly

When you register an account or use our services, you voluntarily provide the following information:

• Account Registration Information: Full legal name, date of birth, gender, residential address, email address, phone number, username, password, and security questions.
• Identity Verification (KYC) Documents: Government-issued photo identification (Indonesian KTP, passport, driver's license), proof of address (utility bills, bank statements), proof of payment method (bank account details, e-wallet screenshots), and source of funds documentation for large transactions.
• Financial Information: Bank account details, e-wallet account information, payment card numbers (with middle digits encrypted), transaction history, deposit amounts, withdrawal amounts, and betting history.
• Communication Data: Content of live chat conversations, emails, WhatsApp messages, phone calls, and any other communications you have with our customer support team.
• Voluntary Information: Feedback, survey responses, contest entries, promotional communications preferences, and responsible gaming limit settings.

3.2 Information Collected Automatically

When you access and use the iyawin Platform, we automatically collect certain technical and behavioral information:

• Device Information: IP address, device type and model, operating system and version, browser type and version, screen resolution, device identifiers (IMEI, Android ID, IDFA), and mobile network information.
• Usage Information: Pages visited, features used, games played, bets placed, time spent on Platform, click patterns, navigation paths, referral sources, and access times.
• Location Data: Approximate geographic location derived from IP address to ensure compliance with jurisdictional restrictions and to prevent fraud.
• Cookies and Similar Technologies: Session cookies, persistent cookies, web beacons, pixel tags, and local storage data used to remember your preferences, authenticate your session, prevent fraud, and analyze Platform usage.

3.3 Information from Third-Party Sources

We may receive additional information about you from third-party sources to verify your identity, prevent fraud, and comply with regulatory requirements:

• Payment Processors: Transaction status, payment verification results, and fraud risk assessments from Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Identity Verification Services: Identity authentication results, document verification status, and fraud detection alerts from third-party KYC service providers.
• Responsible Gaming Databases: Self-exclusion status and problem gambling alerts from national and international gambling exclusion registries.
• Public Records: Information from publicly available sources to verify your identity and comply with anti-money laundering regulations.

4. How We Use Your Information

iyawin uses the personal information we collect for the following purposes:

4.1 Service Provision and Account Management

• Create and maintain your user account
• Process deposits, withdrawals, and other financial transactions
• Allow you to place bets and play games on the Platform
• Provide customer support and respond to your inquiries
• Send transactional communications (account confirmations, bet receipts, withdrawal notifications)
• Manage bonus and promotional offers you have claimed

4.2 Identity Verification and Fraud Prevention

• Verify your identity and age to comply with legal gambling age requirements (21+ in Indonesia)
• Conduct Know Your Customer (KYC) and anti-money laundering (AML) checks
• Detect and prevent fraudulent activities, account takeovers, and security breaches
• Identify and prevent creation of multiple accounts by the same individual
• Monitor for suspicious betting patterns, collusion, or bonus abuse

4.3 Legal and Regulatory Compliance

• Comply with applicable gambling laws, regulations, and licensing requirements
• Respond to legal requests, court orders, and government investigations
• Maintain records required by law for audit and regulatory purposes
• Report suspicious activities to financial crime authorities when legally required
• Enforce our Terms & Conditions and investigate violations

4.4 Responsible Gaming and Player Protection

• Monitor gameplay patterns for signs of problem gambling behavior
• Enforce deposit limits, loss limits, and self-exclusion requests
• Provide reality checks and cooling-off period reminders
• Identify vulnerable players who may benefit from responsible gaming interventions
• Maintain records of player interactions related to problem gambling support

4.5 Platform Improvement and Personalization

• Analyze usage patterns to improve Platform functionality and user experience
• Develop new features, games, and betting markets based on player preferences
• Personalize game recommendations and promotional offers based on your activity
• Test and optimize Platform performance, load times, and reliability
• Conduct data analytics and statistical analysis (using aggregated, anonymized data)

4.6 Marketing and Communications

• Send promotional offers, bonus announcements, and special event notifications (with your consent)
• Deliver targeted advertising on the Platform based on your interests and activity
• Conduct surveys and solicit feedback to improve our services
• Send newsletters and updates about new games, features, and services

Marketing Opt-Out: You can opt out of marketing communications at any time through your account settings or by clicking the unsubscribe link in any marketing email. Note that transactional communications (such as withdrawal confirmations) cannot be opted out of as they are essential to service provision.

5. Legal Basis for Processing

iyawin processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contract with you (Terms & Conditions) by providing gaming services, processing payments, and managing your account.
• Legal Obligation: Processing is required to comply with gambling regulations, anti-money laundering laws, age verification requirements, and other applicable legal obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security, Platform improvement, and responsible gaming measures, provided these interests are not overridden by your privacy rights.
• Consent: For marketing communications and certain optional data processing activities, we rely on your explicit consent, which you can withdraw at any time without affecting the lawfulness of processing based on consent before withdrawal.

6. Information Sharing and Disclosure

iyawin does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for legitimate business purposes:

6.1 Service Providers and Business Partners

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals.
• Identity Verification Services: Third-party KYC and AML compliance providers to verify your identity and prevent fraud.
• Game Providers: Software developers and game studios that provide slot games, live dealer tables, and other gaming content on our Platform.
• Cloud Hosting Services: Infrastructure providers that host our servers, databases, and backup systems.
• Customer Support Tools: Live chat software providers, email services, and CRM platforms used to deliver customer support.
• Analytics Providers: Services that help us analyze Platform usage and improve user experience (using anonymized data where possible).

All third-party service providers are contractually obligated to protect your personal information, use it only for the purposes specified by iyawin, and comply with applicable data protection laws.

6.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies, regulators, law enforcement, courts, or other authorities when:

• Required by law, court order, subpoena, or government investigation
• Necessary to comply with gambling licensing requirements or regulatory audits
• Required to report suspected money laundering or terrorist financing activities
• Necessary to protect our legal rights, property, or safety, or that of other users
• Required to enforce our Terms & Conditions or investigate violations

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets, bankruptcy, or other corporate restructuring, your personal information may be transferred to the successor entity as part of the business transaction, subject to the same privacy protections outlined in this Privacy Policy.

6.4 With Your Consent

We may share your information with other third parties when you provide explicit consent for specific purposes not covered in this Privacy Policy.

7. Data Security Measures

iyawin implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

7.1 Technical Safeguards

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL/TLS encryption, the same security standard used by banks and financial institutions.
• Encrypted Storage: Sensitive personal information (including passwords, financial data, and identity documents) is stored in encrypted databases with restricted access.
• Password Protection: User passwords are hashed using industry-standard cryptographic algorithms and are never stored in plain text.
• Two-Factor Authentication: Optional 2FA provides an additional security layer for account access and sensitive operations like withdrawals.
• Firewalls and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls and intrusion detection systems that monitor for suspicious activity 24/7.
• Regular Security Audits: We conduct periodic security assessments and penetration testing to identify and address vulnerabilities.

7.2 Organizational Safeguards

• Access Controls: Personal information is accessible only to authorized employees and contractors who require it to perform their job functions.
• Employee Training: All staff members receive training on data protection, privacy laws, and security best practices.
• Confidentiality Agreements: Employees and contractors are bound by confidentiality obligations regarding user data.
• Incident Response Plan: We maintain a documented data breach response plan to quickly identify, contain, and remediate security incidents.
• Vendor Management: Third-party service providers are vetted for security compliance and contractually obligated to maintain appropriate safeguards.

7.3 Limitations

While iyawin implements robust security measures, no system is completely invulnerable. You also have a responsibility to protect your account by using strong passwords, not sharing your credentials, logging out after each session, and promptly notifying us of any suspected unauthorized access.

8. Data Retention

iyawin retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal obligations:

Data Category	Retention Period	Reason
Account Information	Duration of account + 7 years	Legal compliance, audit requirements, dispute resolution
KYC Documents	Duration of account + 7 years	Anti-money laundering regulations, identity verification
Transaction History	Duration of account + 7 years	Financial regulations, tax compliance, fraud prevention
Betting History	Duration of account + 5 years	Dispute resolution, responsible gaming monitoring, legal defense
Customer Support Communications	Duration of account + 3 years	Quality assurance, dispute resolution, service improvement
Marketing Consent Records	Until consent is withdrawn + 2 years	Compliance with marketing laws, consent documentation
Self-Exclusion Records	Permanent	Player protection, regulatory compliance, preventing re-access

After the retention period expires, we securely delete or anonymize your personal information unless we are legally required to retain it longer (e.g., for ongoing legal proceedings or regulatory investigations).

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information. Indonesian residents and users in jurisdictions with comprehensive data protection laws have specific rights that iyawin respects:

9.1 Right of Access

You have the right to request a copy of the personal information iyawin holds about you. We will provide this information in a commonly used electronic format within 30 days of your verified request.

9.2 Right to Rectification

If your personal information is inaccurate or incomplete, you have the right to request corrections. You can update most information directly through your account settings, or contact our support team for assistance.

9.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal information in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected. However, we may be legally required to retain certain information for compliance, fraud prevention, or legal defense purposes.

9.4 Right to Restriction of Processing

You can request that we limit how we use your personal information in certain situations, such as when you contest the accuracy of the data or object to processing based on legitimate interests.

9.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.

9.6 Right to Object

You may object to processing of your personal information based on legitimate interests or for direct marketing purposes. If you object to marketing, we will cease such processing immediately.

9.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

9.8 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection team at [email protected] with your request. We will verify your identity and respond within 30 days. There is no fee for exercising your rights unless requests are manifestly unfounded or excessive.

10. Cookies and Tracking Technologies

iyawin uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience, analyze Platform usage, prevent fraud, and deliver personalized content.

10.1 Types of Cookies We Use

• Essential Cookies: Required for Platform functionality, including session management, authentication, and security. These cannot be disabled without affecting site operation.
• Performance Cookies: Collect anonymous usage data to help us understand how visitors interact with the Platform and identify areas for improvement.
• Functionality Cookies: Remember your preferences (language, currency, game filters) to provide a personalized experience across sessions.
• Marketing Cookies: Track your activity across websites to deliver relevant advertising and measure campaign effectiveness (only used with your consent).

10.2 Managing Cookies

You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies, though this may affect Platform functionality. To opt out of marketing cookies, use the cookie preference center available in your account settings.

11. International Data Transfers

iyawin operates servers and uses service providers located in various jurisdictions around the world. When you use our Platform, your personal information may be transferred to and processed in countries outside Indonesia, including jurisdictions that may not provide the same level of data protection as Indonesian law.

We ensure that international data transfers comply with applicable laws by implementing appropriate safeguards such as:

• Standard Contractual Clauses approved by data protection authorities
• Adequacy decisions recognizing equivalent data protection standards
• Binding corporate rules for transfers within our corporate group
• Your explicit consent for specific transfers

12. Children's Privacy

iyawin services are strictly intended for individuals aged 21 and older. We do not knowingly collect personal information from anyone under the age of 21. If we become aware that we have inadvertently collected personal information from a minor, we will take immediate steps to delete such information and terminate the account.

If you believe a minor has created an account on iyawin, please contact us immediately at [email protected] so we can investigate and take appropriate action.

13. Changes to This Privacy Policy

iyawin reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings. When we make material changes, we will notify you by:

• Posting a prominent notice on the Platform
• Sending an email to the address associated with your account
• Requiring you to review and accept the updated policy before continuing to use certain features

The "Last Updated" date at the top of this Privacy Policy indicates when it was most recently revised. Your continued use of the Platform after changes constitutes acceptance of the updated Privacy Policy.

14. Contact Information

If you have questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact us:

• Privacy Inquiries: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 on our website and mobile app
• WhatsApp: +62-812-3456-7890

We are committed to resolving privacy concerns promptly and transparently. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.