Privacy Policy

Effective Date: January 1, 2026 | Last Updated: January 1, 2026

This Privacy Policy (the "Policy") describes how win37 ("we", "us", "our", or the "Company") collects, uses, stores, protects, and discloses personal information obtained from users (each, a "User", "you", or "your") of the win37 website located at https://win37.cam and its associated services (collectively, the "Service"). By accessing or using the win37 Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this Policy, you must not use the Service.

1. Introduction

win37 is an online betting and gaming platform serving Indonesian players through an English-language international interface. We provide sports betting, live casino games, slots, togel (Indonesian lottery), poker, Teen Patti, Andar Bahar, and other gaming products. In order to provide these services, we collect and process certain personal information about our Users.

This Privacy Policy is designed to help you understand:

• What personal information we collect and why we collect it
• How we use, store, and protect your personal information
• When and with whom we share your personal information
• What rights you have regarding your personal information
• How to contact us if you have privacy-related questions or concerns

This Policy should be read in conjunction with our Terms and Conditions, which govern your use of the win37 Service.

2. Information We Collect

win37 collects several categories of personal information from Users in order to provide, maintain, and improve the Service. The types of information we collect include:

2.1 Account Registration Information

When you create a win37 Account, we collect:

• Personal identifiers: Full legal name, date of birth, gender
• Contact information: Email address, mobile phone number, residential address (street, city, postal code, country)
• Account credentials: Username, password (stored in encrypted form)
• Preferred currency and language: Indonesian Rupiah (IDR), English language preference

2.2 Identity Verification (KYC) Information

As part of our Know Your Customer (KYC) compliance obligations under our international gaming license, we collect:

• Government-issued identification: Copies of your Indonesian National Identity Card (KTP), passport, or driver's license, including identification number, photograph, and expiration date
• Proof of address: Recent utility bills, bank statements, or government correspondence showing your current residential address
• Biometric data: Selfie photographs taken for facial verification purposes to confirm that the person holding the identification document matches the photograph on the document
• Payment method verification: Screenshots or documentation proving ownership of bank accounts (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) or e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja) used for deposits and withdrawals

2.3 Financial and Transaction Information

When you make deposits, place bets, or request withdrawals, we collect:

• Payment information: Bank account numbers, e-wallet account identifiers, payment method types, transaction amounts, and timestamps
• Transaction history: Records of all deposits, withdrawals, bets placed, winnings, losses, and bonus redemptions
• Balance information: Current Account Balance, available bonus funds, and wagering progress toward bonus requirements

We do not store full credit or debit card numbers on our servers. Payment processing is handled by third-party payment processors who maintain PCI-DSS (Payment Card Industry Data Security Standard) compliance.

2.4 Usage and Activity Information

We automatically collect information about how you use the win37 Service, including:

• Browsing activity: Pages visited, features used, time spent on pages, clickstream data, and navigation paths
• Betting activity: Games played, bet types, stake amounts, betting patterns, win/loss ratios, and session durations
• Device and technical information: IP address, browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution, language settings, time zone (typically WIB for Indonesian users)
• Geolocation data: Approximate geographic location derived from IP address to comply with jurisdictional restrictions
• Customer support interactions: Live chat transcripts, email correspondence, support ticket history, and feedback submitted through the Service

2.5 Cookies and Tracking Technologies

win37 uses cookies, web beacons, and similar tracking technologies to collect information about your interaction with the Service. For full details, see Section 6 (Cookies and Tracking Technologies).

2.6 Marketing and Communications Preferences

We collect information about your marketing preferences, including:

• Whether you have opted in to receive promotional emails, SMS messages, or push notifications
• Your engagement with marketing communications (open rates, click-through rates)
• Your interests and preferences for specific types of promotions or game categories

3. How We Use Your Personal Information

win37 uses the personal information we collect for the following purposes:

3.1 To Provide and Maintain the Service

• Create and manage your win37 Account
• Process deposits, withdrawals, and financial transactions
• Enable you to place bets and participate in games
• Calculate winnings, losses, and account balances
• Process bonus offers and promotional credits
• Provide customer support and respond to your inquiries

3.2 To Verify Your Identity and Prevent Fraud

• Conduct Know Your Customer (KYC) verification to confirm your identity, age, and address
• Prevent underage gambling (users must be 21 years or older)
• Detect and prevent fraudulent activity, money laundering, and account takeovers
• Identify duplicate accounts and enforce our one-account-per-person policy
• Monitor betting patterns for signs of collusion, cheating, or bonus abuse

3.3 To Comply with Legal and Regulatory Obligations

• Comply with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations
• Respond to lawful requests from law enforcement, regulators, and courts
• Maintain records required by our international gaming license
• Report suspicious transactions or activities to appropriate authorities

3.4 To Improve and Optimize the Service

• Analyze usage patterns to understand how Users interact with the platform
• Identify technical issues, bugs, and performance bottlenecks
• Test new features and optimize user experience
• Conduct internal research and analytics to improve game offerings and platform functionality

3.5 To Communicate with You

• Send transactional communications (deposit confirmations, withdrawal status updates, account alerts)
• Provide customer support via live chat, email, WhatsApp, and Telegram
• Send promotional offers, bonus notifications, and marketing communications (only if you have opted in)
• Notify you of changes to our Terms and Conditions, Privacy Policy, or Service features

3.6 To Promote Responsible Gaming

• Monitor betting behavior for signs of problem gambling
• Enforce deposit limits, session time limits, and self-exclusion requests
• Provide responsible gaming tools and resources
• Intervene if we detect patterns consistent with gambling addiction

3.7 Legal Basis for Processing (Indonesian Context)

win37 processes your personal information on the following legal bases:

• Contractual necessity: Processing is necessary to fulfill our contract with you (Terms and Conditions)
• Legal obligation: Processing is required to comply with AML, KYC, and other legal requirements
• Legitimate interests: Processing is necessary for fraud prevention, security, platform improvement, and business operations
• Consent: For marketing communications and certain cookies, we obtain your explicit consent

4. Data Retention

win37 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.

4.1 Active Account Data

While your Account remains active, we retain all personal information necessary to provide the Service, including registration details, KYC documents, transaction history, and betting activity.

4.2 Closed Account Data

After you close your Account, we retain certain information for the following periods:

• Transaction and financial records: 7 years (to comply with AML regulations and tax requirements)
• KYC and identity verification documents: 7 years (regulatory requirement)
• Customer support records: 5 years (for dispute resolution and quality assurance)
• Marketing communications records: Until you withdraw consent or request deletion

4.3 Legal Holds

If your Account is subject to a legal investigation, dispute, or regulatory inquiry, we may retain your personal information beyond the standard retention periods until the matter is resolved.

4.4 Anonymization

After the applicable retention period expires, we may anonymize your data (removing all personally identifiable information) and retain it for statistical analysis and research purposes. Anonymized data cannot be linked back to you and is not considered personal information.

5. Data Sharing and Disclosure

win37 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your personal information with the following categories of recipients:

5.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who perform services on our behalf, including:

• Payment processors: To facilitate deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, and LinkAja
• Game providers: Pragmatic Play, Evolution Gaming, Pocket Games Soft, NetEnt, Microgaming, Spribe (to deliver game content and track betting activity)
• Identity verification providers: To conduct automated KYC checks and document verification
• Cloud hosting providers: To store data on secure servers
• Customer support platforms: To manage live chat, email support, and ticketing systems
• Analytics and marketing platforms: To analyze usage patterns and deliver targeted marketing (subject to your consent)

All service providers are contractually required to handle your data in accordance with this Privacy Policy and applicable data protection laws. They are prohibited from using your data for their own purposes.

5.2 Legal and Regulatory Authorities

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

• Required by law, court order, subpoena, or legal process
• Necessary to comply with our gaming license obligations
• Requested by anti-money laundering authorities or financial intelligence units
• Necessary to protect the rights, property, or safety of win37, our Users, or the public

5.3 Business Transfers

In the event that win37 is involved in a merger, acquisition, asset sale, or bankruptcy, your personal information may be transferred to the acquiring entity. We will notify you of any such transfer and the choices you may have regarding your personal information.

5.4 Affiliates and Group Companies

We may share your personal information with companies within the win37 corporate group for internal administrative purposes, fraud prevention, and service improvement.

5.5 With Your Consent

We may share your personal information with other third parties when you have given us explicit consent to do so.

6. Cookies and Tracking Technologies

6.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. Cookies are widely used to make websites work more efficiently and to provide information to website owners.

6.2 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for the Service to function (login sessions, security, account access)	Session / Persistent
Functional Cookies	Remember your preferences (language, currency, bet slip settings)	Persistent
Analytics Cookies	Track usage patterns, page views, and user behavior to improve the Service	Persistent
Marketing Cookies	Deliver targeted advertising and track marketing campaign effectiveness	Persistent

6.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can set your browser to refuse all cookies or to alert you when a cookie is being sent. However, disabling essential cookies may prevent you from using certain features of the win37 Service, including the ability to log in and place bets.

6.4 Third-Party Cookies

Some cookies on the win37 website are placed by third-party service providers (e.g., Google Analytics, advertising networks). These third parties may collect information about your online activities over time and across different websites. We do not control third-party cookies and encourage you to review their privacy policies.

7. Data Security

7.1 Security Measures

win37 takes data security seriously and implements industry-standard technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL encryption: All data transmitted between your device and our servers is encrypted using Secure Socket Layer (SSL) technology
• Encrypted data storage: Sensitive data, including passwords and KYC documents, are stored in encrypted form
• Access controls: Personal data is accessible only to authorized employees and service providers on a need-to-know basis
• Two-factor authentication (2FA): Available for User accounts to add an extra layer of security
• Regular security audits: Third-party security assessments and penetration testing to identify vulnerabilities
• Intrusion detection and monitoring: Real-time monitoring for suspicious activity and unauthorized access attempts

7.2 Limitations of Security

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you use the Service at your own risk. You are responsible for maintaining the confidentiality of your Account credentials and for any activity that occurs under your Account.

7.3 Data Breach Notification

In the event of a data breach that compromises your personal information, we will notify affected Users and relevant regulatory authorities in accordance with applicable data protection laws. Notification will be provided via email and/or a prominent notice on the win37 website.

8. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. Indonesian residents have the following rights under international data protection standards:

8.1 Right to Access

You have the right to request access to the personal information we hold about you. You can request a copy of your data by contacting customer support.

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through your Account settings.

8.3 Right to Erasure (Right to Be Forgotten)

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal retention requirements, ongoing disputes). Note that certain data must be retained for regulatory compliance even after Account closure.

8.4 Right to Restrict Processing

You have the right to request that we limit how we use your personal information in certain circumstances (e.g., while we verify the accuracy of disputed data).

8.5 Right to Data Portability

You have the right to request a copy of your personal information in a structured, commonly used, machine-readable format for transfer to another service provider.

8.6 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes. You can unsubscribe from marketing emails at any time by clicking the unsubscribe link or contacting customer support.

8.7 Right to Withdraw Consent

Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

8.8 How to Exercise Your Rights

To exercise any of the above rights, please contact win37 customer support via email at support at win37.cam or through live chat. We will respond to your request within 30 days.

9. International Data Transfers

win37 is an internationally licensed platform. Your personal information may be transferred to, stored in, and processed in countries outside of Indonesia, including countries that may not have the same data protection laws as Indonesia. When we transfer data internationally, we implement appropriate safeguards, including:

• Contractual clauses requiring recipients to protect data in accordance with international standards
• Transfer to countries recognized as providing adequate data protection
• Use of certified service providers who comply with international data protection frameworks

By using the win37 Service, you acknowledge and consent to the international transfer of your personal information as described in this Policy.

10. Children's Privacy

The win37 Service is strictly intended for individuals aged 21 years or 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 person under 21, we will immediately delete that information and suspend the Account. Parents or guardians who believe their child has provided personal information to win37 should contact us immediately at support at win37.cam.

11. Changes to This Privacy Policy

win37 reserves the right to update or modify this Privacy Policy at any time. Any changes will be effective immediately upon posting the revised Policy to the win37 website. The "Last Updated" date at the top of this document will reflect the date of the most recent changes. We encourage you to review this Policy periodically. Continued use of the Service after changes have been posted constitutes your acceptance of the revised Policy. If we make material changes that significantly affect your privacy rights, we will provide additional notice via email or a prominent notice on the website.

12. Contact Information

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

• Email: support at win37.cam (plain text, not a clickable link)
• Live Chat: Available 24/7 on the win37 website
• WhatsApp: +62 811-XXXXXXX (plain text, hours: 08:00–24:00 WIB)

We aim to respond to all privacy-related inquiries within 30 days. If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority.