Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by dewi46 through our website, mobile-optimized platform, customer support channels, and any other services we provide. dewi46 operates as an online sports betting and casino platform serving primarily Indonesian players, and we are committed to complying with applicable data protection laws and international privacy standards.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of dewi46 services. In the event of any conflict between this Privacy Policy and the Terms & Conditions regarding privacy matters, this Privacy Policy shall prevail.

dewi46 reserves the right to update or modify this Privacy Policy at any time without prior notice. Changes will be effective immediately upon posting on our website. The "Last Updated" date at the top of this page indicates when the policy was last revised. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

2. Information We Collect

2.1 Personal Information You Provide

When you register an account with dewi46, you provide us with personal information including:

• Identity Information: Full legal name, date of birth, gender, nationality, Indonesian national ID number (KTP), and place of birth.
• Contact Information: Email address, phone number, residential address (street, city, province, postal code), and preferred communication language.
• Account Credentials: Username, password (stored in encrypted form), security questions and answers, and PIN codes for additional security.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet information (OVO, DANA, GoPay, ShopeePay, LinkAja account details), payment card information (if applicable), transaction history, deposit and withdrawal records.
• KYC Verification Documents: Copies of your Indonesian national ID (KTP), selfie photographs holding your ID, proof of address documents (utility bills, bank statements), and any additional documentation requested for enhanced verification.
• Communication Records: Customer support chat transcripts, email correspondence, WhatsApp messages, feedback forms, and complaint submissions.

2.2 Information Automatically Collected

When you access and use dewi46 services, we automatically collect certain technical and usage information:

• Device Information: Device type (desktop, mobile, tablet), operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address, advertising ID), and mobile network information.
• Connection Information: IP address, internet service provider (ISP), approximate geographic location (city and country level based on IP), time zone, and connection type (WiFi, mobile data).
• Usage Data: Pages visited, features used, games played, bets placed, time spent on site, click patterns, navigation paths, referral sources, search queries within our site, and timestamps of all activities.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, pixel tags, and similar tracking technologies that help us understand user behavior, remember preferences, and improve service quality.
• Betting and Gaming Data: Betting history, favorite games, win/loss records, session duration, preferred payment methods, bonus usage patterns, and risk profile indicators.

2.3 Information from Third Parties

dewi46 may receive information about you from third-party sources including:

• Payment Processors: Transaction verification data from BCA, BRI, BNI, Mandiri, and other Indonesian banks; e-wallet providers (OVO, DANA, GoPay); and payment gateway partners.
• Identity Verification Services: Verification reports from KYC service providers, fraud prevention databases, and credit reference agencies (where permitted by law).
• Game Providers: Gaming session data, game outcomes, and player behavior metrics from third-party software providers like Pragmatic Play, Evolution Gaming, NetEnt, and others.
• Marketing Partners: Information about how you arrived at dewi46 through affiliate marketing programs or advertising campaigns (subject to your consent where required).

3. How We Use Your Information

dewi46 uses your personal information for the following purposes:

3.1 Account Management and Service Provision

• Creating and maintaining your dewi46 account
• Verifying your identity and age (21+ requirement) through KYC procedures
• Processing deposits, withdrawals, and other financial transactions
• Providing access to sports betting, casino games, and lottery services
• Managing your betting history, account balance, and transaction records
• Administering bonuses, promotions, and loyalty program benefits
• Enabling customer support services via live chat, email, and WhatsApp

3.2 Legal and Regulatory Compliance

• Complying with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Detecting and preventing fraud, money laundering, and other illegal activities
• Enforcing our Terms & Conditions and investigating violations
• Responding to legal requests from law enforcement and regulatory authorities
• Maintaining records required by gaming licenses and financial regulations
• Implementing responsible gaming measures including self-exclusion and deposit limits

3.3 Platform Improvement and Analytics

• Analyzing user behavior to improve website functionality and user experience
• Identifying and fixing technical issues, bugs, and performance problems
• Conducting market research and understanding player preferences
• Developing new features, games, and betting markets based on user demand
• Optimizing payment processing times and success rates
• Testing new features through A/B testing and user feedback

3.4 Marketing and Communications

• Sending promotional offers, bonus notifications, and special campaigns (with your consent)
• Providing personalized recommendations based on your betting history and preferences
• Notifying you about new games, features, and platform updates
• Sending important account notifications, security alerts, and service announcements
• Conducting customer satisfaction surveys and feedback requests

3.5 Security and Fraud Prevention

• Monitoring transactions for suspicious activity and fraudulent patterns
• Detecting account takeover attempts and unauthorized access
• Preventing bonus abuse, collusion, and other forms of gaming the system
• Implementing device fingerprinting and behavioral analytics for security
• Protecting against DDoS attacks, hacking attempts, and data breaches

4. Legal Basis for Processing (GDPR Compliance)

For users in jurisdictions covered by the General Data Protection Regulation (GDPR) or similar privacy laws, dewi46 processes your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (providing betting services, processing transactions, managing your account).
• Legal Obligation: Processing is required to comply with legal obligations including KYC/AML regulations, tax reporting, and gaming license requirements.
• Legitimate Interest: Processing is necessary for our legitimate business interests (fraud prevention, platform security, service improvement) balanced against your privacy rights.
• Consent: For marketing communications and certain tracking technologies, we obtain your explicit consent which you may withdraw at any time.

5. How We Share Your Information

dewi46 does not sell your personal information to third parties. However, we may share your information with the following categories of recipients:

5.1 Service Providers and Business Partners

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals.
• KYC Verification Services: Third-party identity verification providers to confirm your identity and age.
• Game Providers: Software developers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, etc.) to enable game access and track gameplay.
• Customer Support Tools: Live chat software providers and customer relationship management (CRM) platforms to deliver support services.
• Cloud Hosting Providers: Secure server hosting companies to store your data safely and ensure platform availability.
• Analytics Providers: Website analytics services to understand user behavior and improve our platform (data is anonymized where possible).

5.2 Legal and Regulatory Authorities

We may disclose your information to law enforcement agencies, regulatory bodies, tax authorities, or courts when required by law or in response to valid legal requests, including:

• Complying with court orders, subpoenas, or legal processes
• Responding to government investigations or regulatory inquiries
• Reporting suspicious transactions under AML regulations
• Cooperating with law enforcement in criminal investigations
• Protecting dewi46's legal rights and defending against legal claims

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor company. We will notify you via email or prominent notice on our website before your information is transferred and becomes subject to a different privacy policy.

6. Data Security Measures

dewi46 implements industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmission between your device and our servers uses SSL/TLS encryption (minimum 256-bit encryption). Sensitive data at rest (passwords, financial information) is encrypted using AES-256 or equivalent standards.
• Secure Authentication: Passwords are hashed using bcrypt or similar algorithms. Two-factor authentication (2FA) is available for enhanced account security.
• Access Controls: Personal data is accessible only to authorized dewi46 employees who require it to perform their job functions. Access is granted based on role-based permissions and logged for audit purposes.
• Network Security: Firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) protect our infrastructure from external attacks.
• Regular Security Audits: Third-party security firms conduct periodic penetration testing and vulnerability assessments to identify and remediate weaknesses.
• Employee Training: All dewi46 staff undergo regular security awareness training and are bound by confidentiality agreements.
• Data Backup: Regular automated backups ensure data can be recovered in case of system failure or disaster.

While we implement robust security measures, no internet transmission or electronic storage system is 100% secure. You acknowledge and accept the inherent security risks of transmitting information over the internet. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify dewi46 if you suspect unauthorized access.

7. Data Retention

dewi46 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Data Type	Retention Period	Reason
Account Information	Duration of account + 7 years after closure	Legal compliance (AML, tax, gaming regulations)
Transaction Records	7 years from transaction date	Financial regulations and tax reporting
KYC Documents	7 years after account closure	AML compliance and regulatory requirements
Betting History	5 years from bet settlement	Dispute resolution and audit trail
Customer Support Records	3 years from last contact	Service improvement and complaint handling
Marketing Consent	Until consent withdrawn + 1 year	GDPR compliance and proof of consent
Website Usage Logs	12 months	Security monitoring and analytics

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with data protection laws and our internal data retention policies. Anonymized data that cannot be linked back to you may be retained indefinitely for statistical analysis and research purposes.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request a copy of the personal information dewi46 holds about you. You can access most of your account information directly through your account dashboard. For additional information not available through the dashboard, please contact customer support.

8.2 Right to Rectification

You have the right to correct inaccurate or incomplete personal information. You can update your contact details, address, and communication preferences through your account settings. For corrections to KYC documents or other verified information, please contact customer support with supporting documentation.

8.3 Right to Erasure ("Right to Be Forgotten")

You have the right to request deletion of your personal information in certain circumstances. However, this right is not absolute. dewi46 may be required to retain certain information for legal compliance (AML regulations, tax reporting, gaming license requirements) even after account closure. We will delete or anonymize information when legally permissible.

8.4 Right to Restrict Processing

You may request that dewi46 restrict processing of your personal information in certain situations, such as when you contest the accuracy of the data or object to processing. During the restriction period, we will store your information but not actively process it except with your consent or for legal claims.

8.5 Right to Data Portability

Where technically feasible, you have the right to receive your personal information in a structured, commonly used, and machine-readable format (e.g., CSV, JSON) and to transmit that data to another service provider. This right applies to information you provided to dewi46 based on consent or contract.

8.6 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes at any time. You can opt out of marketing communications by clicking the "unsubscribe" link in emails, adjusting your communication preferences in your account settings, or contacting customer support. You may also object to processing based on legitimate interests by explaining your specific situation.

8.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of processing that occurred before withdrawal. To withdraw consent for marketing communications, use the unsubscribe mechanism in emails or contact customer support.

8.8 Exercising Your Rights

To exercise any of these privacy rights, please contact dewi46 customer support via:

• Email: [email protected]
• Live Chat: Available 24/7 through your account dashboard
• WhatsApp: +62 812-3456-7890

We will respond to your request within 30 days. We may request additional information to verify your identity before processing certain requests. There is no fee for exercising your rights unless your request is manifestly unfounded or excessive.

9. Cookies and Tracking Technologies

dewi46 uses cookies and similar tracking technologies to enhance your experience, analyze site usage, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you on subsequent visits.

9.1 Types of Cookies We Use

• Essential Cookies: Necessary for website functionality (login sessions, security, load balancing). These cannot be disabled without breaking core features.
• Functional Cookies: Remember your preferences (language, currency, display settings) to provide a personalized experience.
• Analytics Cookies: Help us understand how users interact with our site (pages visited, time spent, navigation patterns) to improve our services.
• Marketing Cookies: Track your activity across websites to deliver relevant advertisements and measure campaign effectiveness (used only with your consent).

9.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Note that disabling cookies may limit certain features of dewi46 and affect your user experience. To manage cookies, adjust settings in your browser (Chrome, Firefox, Safari, Edge) under Privacy or Security settings.

10. International Data Transfers

dewi46 primarily serves Indonesian players, but our infrastructure and service providers may be located in various countries. When we transfer your personal information outside Indonesia, we implement appropriate safeguards to ensure your data remains protected, including:

• Standard Contractual Clauses (SCCs) approved by data protection authorities
• Ensuring recipients are located in jurisdictions with adequate data protection laws
• Requiring service providers to implement equivalent security measures
• Obtaining your explicit consent where required by law

11. Children's Privacy

dewi46 services are strictly intended for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected information from someone under 21, we will immediately delete that information and close the associated account. Parents or guardians who believe their child has provided information to dewi46 should contact us immediately.

12. Third-Party Websites

The dewi46 website may contain links to third-party websites, social media platforms, or external services. This Privacy Policy applies only to dewi46 and does not cover third-party sites. We are not responsible for the privacy practices or content of external websites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

dewi46 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Updating the "Last Updated" date at the top of this page
• Sending an email notification to your registered email address
• Displaying a prominent notice on our website or in your account dashboard

Your continued use of dewi46 services after changes are posted constitutes acceptance of the updated Privacy Policy. If you disagree with any changes, you may close your account by contacting customer support.

14. Contact Information and Complaints

If you have questions, concerns, or complaints regarding this Privacy Policy or dewi46's data practices, please contact us:

• Data Protection Officer: [email protected]
• Customer Support (General Inquiries): [email protected]
• Live Chat: Available 24/7 through your account dashboard
• WhatsApp: +62 812-3456-7890
• Postal Address: dewi46 Privacy Department, [Complete address would be listed here in production]

We will investigate all privacy complaints and respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority or supervisory body.

15. Consent and Acknowledgment

By creating an account with dewi46, depositing funds, or using our services, you acknowledge that you have read, understood, and agree to the collection, use, disclosure, and storage of your personal information as described in this Privacy Policy. If you do not agree with any aspect of this policy, you must immediately cease using dewi46 services and close your account.