Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how win199 ("we", "us", or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you", "your", or "User") who access or use the win199 platform at https://win199.cam (the "Platform").

This Policy applies to all Users of the win199 Platform, including registered account holders, visitors who browse the Platform without registering, and individuals who contact our customer support team. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to the data practices described in this Policy.

If you do not agree with this Policy, you must not use the win199 Platform. This Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy.

2. Data Controller

win199 is the data controller responsible for the personal information collected through this Platform. For all data-related inquiries, requests, or complaints, you may contact us using the details provided in Section 13 (Contact Information) of this Policy.

3. Information We Collect

win199 collects personal information through several channels. The categories of data we collect are described below:

3.1 Information You Provide Directly

When you register for an Account, complete identity verification (KYC), make deposits or withdrawals, or contact our support team, you may provide the following:

• Identity Information: Full legal name, date of birth, gender, and nationality as it appears on your government-issued identification (e.g., Indonesian KTP, passport, or driver's license).
• Contact Information: Email address, mobile phone number, and residential address (city, province, postal code — standard Indonesian address format).
• Financial Information: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), deposit and withdrawal history.
• Identity Verification Documents: Copies of government-issued photo ID, proof of address documents, and selfie verification images submitted during KYC review.
• Support Communications: Records of live chat conversations, email exchanges, WhatsApp messages, and any other communications with our customer support team.

3.2 Information Collected Automatically

When you access the win199 Platform, we automatically collect certain technical and behavioral data:

• Device Information: Device type, operating system, browser type and version, screen resolution, and unique device identifiers.
• Network Information: IP address, approximate geographic location (city and province level, derived from IP), Internet service provider, and connection type.
• Usage Data: Pages visited, game titles accessed, session duration, click-through patterns, betting and wagering history, and navigation paths through the Platform.
• Cookies and Similar Technologies: Data stored via cookies, web beacons, local storage, and session tokens as described in Section 8 of this Policy.

3.3 Information From Third Parties

In certain circumstances, win199 may receive personal information about you from third-party sources, including:

• Identity verification and KYC service providers who validate your submitted documents against public records.
• Payment processors and financial institutions that confirm transaction status and fraud screening results.
• Anti-fraud and anti-money-laundering (AML) screening services that check your details against international watchlists and sanctions databases.

4. How We Use Your Information

win199 uses the personal information we collect for the following purposes, each grounded in a legitimate legal basis:

Purpose	Data Used	Legal Basis
Account registration and management	Identity, contact information	Contract performance
Identity verification (KYC/AML compliance)	Identity documents, financial data	Legal obligation
Processing deposits and withdrawals	Financial information, transaction records	Contract performance
Customer support and dispute resolution	Contact info, support communications	Contract performance
Fraud prevention and platform security	Device info, IP address, usage data	Legitimate interest
Responsible gaming monitoring	Wagering history, session data	Legal obligation / legitimate interest
Platform improvement and analytics	Usage data, device information	Legitimate interest
Promotional communications (where opted in)	Contact information, preferences	Consent
Compliance with legal and regulatory obligations	All categories as required	Legal obligation

win199 does not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects without human review, except where required by AML screening obligations, in which case you retain the right to request human intervention.

5. How We Share Your Information

win199 does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. We share your information only in the following limited circumstances:

5.1 Service Providers

We engage carefully vetted third-party service providers to assist in delivering our Services. These include payment processors (such as Indonesian banking networks and e-wallet providers including OVO, DANA, GoPay, ShopeePay, and LinkAja), KYC and identity verification platforms, cloud hosting and infrastructure providers, customer support software vendors, and fraud and AML screening services. All service providers are bound by data processing agreements that restrict their use of your data to the specific purposes for which it was shared.

5.2 Legal and Regulatory Authorities

win199 may disclose your personal information to law enforcement agencies, regulatory bodies, courts, or other governmental authorities when required to do so by law, court order, or binding regulatory directive. We will notify you of such disclosures where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets involving win199, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you by prominent notice on the Platform before your data becomes subject to a different privacy policy as a result of any such transfer.

6. Data Retention

win199 retains your personal information for as long as is necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. The general retention schedules we apply are as follows:

• Account and identity data: Retained for the duration of your Account's active status plus a minimum of five (5) years following Account closure, in compliance with international AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• KYC verification documents: Retained for a minimum of five (5) years following your most recent transaction or Account closure, whichever is later.
• Customer support communications: Retained for three (3) years from the date of the communication, unless the matter relates to an ongoing dispute.
• Usage and analytics data: Retained in aggregated, anonymized form indefinitely for platform improvement purposes. Individual session logs are retained for up to twelve (12) months.
• Marketing preferences: Retained until you withdraw consent or close your Account.

When retention periods expire, we securely delete or anonymize the relevant data using industry-standard data destruction methods.

7. Your Rights and Choices

As a User of win199, you hold the following rights with respect to your personal data. To exercise any of these rights, please contact our customer support team using the details in Section 13:

• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is being used.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct or update it.
• Right to Erasure: Subject to legal retention obligations, you may request deletion of your personal data. Note that we may be required to retain certain data (such as transaction records and KYC documents) even after Account closure.
• Right to Restriction of Processing: You may request that we restrict our use of your personal data in certain circumstances, for example while a correction request is being reviewed.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format for transfer to another service provider where technically feasible.
• Right to Object: You may object to the processing of your personal data where we rely on legitimate interest as the legal basis, including objection to direct marketing communications at any time.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

We aim to respond to all data rights requests within 30 calendar days. In complex cases, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

8. Cookies and Tracking Technologies

win199 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit a website. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These enable core features such as Account login sessions, security tokens, and the shopping cart for deposit flows. You cannot opt out of strictly necessary cookies while using the Platform.
• Functional Cookies: Remember your preferences (such as language, time-zone display, and preferred deposit method) to personalize your experience. These are set only with your consent.
• Analytics Cookies: Help us understand how Users interact with the Platform — which games are most popular, where Users encounter difficulties, and how page performance can be improved. Data is aggregated and anonymized where possible.
• Security and Fraud-Prevention Cookies: Used to detect and prevent fraudulent activity, unauthorized Account access, and abuse of our promotional systems.

You may manage cookie preferences through your browser settings. Please note that disabling functional or analytics cookies may impair certain features of the Platform. For most major browsers (Chrome, Firefox, Safari, Edge), cookie management instructions are available in the browser's Help documentation.

9. Data Security

win199 implements a comprehensive suite of technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

• Encryption in Transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or TLS 1.3 (256-bit SSL).
• Encryption at Rest: Sensitive data fields (including financial identifiers and identity document images) are encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is strictly limited to authorized personnel who require it to perform their job functions. Role-based access controls and multi-factor authentication are enforced for all internal systems.
• Regular Security Audits: Our platform and infrastructure undergo regular penetration testing and security audits by independent third-party specialists.
• Incident Response: win199 maintains a documented data breach response plan. In the event of a breach that poses a risk to your rights, we will notify affected Users and relevant authorities within 72 hours of becoming aware of the incident.

While we take every reasonable precaution to secure your data, no platform can guarantee absolute security. You play an important role in keeping your Account secure by using a strong, unique password and not sharing your login credentials with anyone.

10. International Data Transfers

win199 primarily serves Indonesian players (Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, and across the archipelago), and our primary data processing operations are conducted within our licensed jurisdiction. However, some of our third-party service providers may process data in jurisdictions outside Indonesia. In all such cases, win199 ensures that adequate safeguards are in place — including contractual data protection clauses — to provide a level of protection equivalent to that applied within our primary operating jurisdiction.

11. Children's Privacy

The win199 Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected data from a minor, we will delete that information from our systems immediately and close the associated Account. If you believe that we may have collected data from a person under 21, please contact us immediately at the details provided in Section 13.

12. Changes to This Privacy Policy

win199 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered Users via email or prominent on-platform notice.

Your continued use of the win199 Platform after any change to this Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you should stop using the Platform and may request Account closure by contacting our support team.

13. Contact Information

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our Data Privacy team through one of the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 directly on the win199 Platform — the fastest route for most inquiries.
• WhatsApp: Contact number displayed in your Account dashboard once logged in.

Our Indonesian-speaking support agents are available during WIB (Western Indonesia Time, UTC+7) business hours. For data rights requests requiring formal processing, we recommend contacting us via email so that we can maintain a clear written record of your request and our response.