dewu11 Privacy Policy

1 Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings defined below:

Term	Meaning
"Personal Data"	Any information relating to an identified or identifiable natural person ("data subject"), including names, contact details, identification numbers, financial data, and online identifiers such as IP addresses.
"Processing"	Any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
"Platform"	The dewu11 website accessible at dewu11.app and all associated pages, services, and features.
"Player" / "you"	Any individual who registers an Account on the Platform or who accesses any part of the Platform in any capacity.
"Account"	The personal dewu11 member account through which a Player accesses betting and gaming services and conducts financial transactions.
"Third-Party Processor"	Any external company or service provider that processes Personal Data on behalf of dewu11, under contract and subject to data protection obligations, in order to deliver services required for Platform operation.
"KYC"	Know Your Customer — the identity and age-verification process conducted to confirm that Players are at least 21 years of age and to meet anti-money-laundering (AML) compliance requirements.

2 Data Controller

2.1  dewu11 ("the Company", "we", "us", "our") is the data controller responsible for the Personal Data collected through the Platform. As data controller, dewu11 determines the purposes for which Personal Data is processed and the manner in which that processing is carried out.

2.2  For all data-related enquiries, correction requests, deletion requests, or complaints, you may contact the dewu11 data protection contact point by email at [email protected]. All data-related requests are handled in accordance with the timeframes set out in Section 11 of this Policy.

3 Data We Collect

3.1  dewu11 collects the following categories of Personal Data from Players:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identity document.
• Date of birth ( used to verify that you are at least 21 years of age).
• Residential address in Indonesia, including city (e.g., Jakarta, Surabaya, Bandung, Bali, Medan, Yogyakarta) and postal code.
• Valid email address.
• Mobile phone number registered in Indonesia.

3.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents such as your Indonesian National Identity Card (KTP), passport, or driver's licence.
• Proof of residential address documents (utility bills, bank statements) dated within the last three months.
• Photographs or screenshots of payment method accounts used for deposits, confirming ownership.
• Source-of-funds documentation where required for high-value transactions.

3.3 Financial and Transaction Data

• Bank account numbers and bank names (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) associated with your deposits and withdrawals.
• E-wallet account identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method used.
• Betting and gaming activity records, including bet amounts, game types, and outcomes.

3.4 Technical and Usage Data

• IP address and approximate geographic location derived from it.
• Device type, operating system, and browser version.
• Session duration, pages visited, and features used within the Platform.
• Login timestamps and session identifiers.
• Cookie identifiers and similar tracking technologies (see Section 10).

3.5 Communications Data

• Records of your communications with dewu11 customer support, including live chat transcripts, emails, and WhatsApp message logs.
• Feedback, complaints, and survey responses submitted through the Platform.

4 How We Collect Your Data

4.1  dewu11 collects Personal Data through the following means:

• Directly from you: when you register an Account, complete KYC verification, make a deposit or withdrawal, place a bet, contact customer support, or participate in a promotion.
• Automatically: through cookies, session tracking technology, and server logs when you browse or use the Platform. See Section 10 for full details on cookies.
• From Third-Party Processors: payment providers (such as local banks and e-wallet operators), identity verification service providers, and fraud-detection partners may share data with dewu11 as part of the service they deliver on our behalf.
• From publicly available sources: in limited circumstances, dewu11 may supplement Account information with publicly available data for the purposes of fraud prevention or AML compliance.

5 Purposes & Legal Basis for Processing

5.1  The table below sets out each purpose for which dewu11 processes Personal Data, the categories of data used, and the legal basis on which that processing is carried out:

Purpose	Data Categories Used	Legal Basis
Account registration and management	Identity, contact, KYC	Performance of contract
Age and identity verification (KYC)	KYC, identity	Legal obligation; legitimate interests
Processing deposits and withdrawals	Financial, identity	Performance of contract
Bet settlement and gaming services	Financial, usage	Performance of contract
Fraud prevention and security monitoring	Technical, financial, identity	Legitimate interests; legal obligation
Anti-money laundering (AML) compliance	Identity, financial, KYC	Legal obligation
Responsible gaming monitoring	Usage, financial	Legitimate interests; legal obligation
Customer support and dispute resolution	Communications, identity	Performance of contract; legitimate interests
Platform performance and analytics	Technical, usage	Legitimate interests
Sending promotional communications	Identity, contact	Consent (where required); legitimate interests

5.2  Where dewu11 relies on legitimate interests as the legal basis for processing, we have assessed those interests against your rights and freedoms and are satisfied that they do not override your fundamental privacy rights. You may request further details of this assessment by contacting [email protected].

5.3  Where processing is based on consent — for example, receiving promotional communications — you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent, contact dewu11 support or use the unsubscribe mechanism in any marketing communication.

6 Data Sharing

6.1  dewu11 does not sell, rent, or trade your Personal Data to any third party for commercial marketing purposes. We share data only in the following limited circumstances:

6.1 Third-Party Processors

dewu11 engages the following categories of Third-Party Processors, each operating under contractual data protection obligations:

• Payment providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) — to process deposits and withdrawals.
• Identity verification providers: third-party KYC and document verification services — to confirm your identity and age.
• Fraud and AML screening services: to detect and prevent financial crime on the Platform.
• Game content suppliers: providers such as Pragmatic Play, Evolution Gaming, PG Soft, Microgaming, and NetEnt may receive pseudonymised session data necessary to operate their games within the Platform.
• IT infrastructure and hosting providers: cloud and data-centre operators responsible for hosting the Platform and storing data securely.
• Customer support platform providers: live chat and communication software vendors who process support conversation data on our behalf.

6.2 Legal and Regulatory Disclosure

dewu11 may disclose Personal Data to law enforcement agencies, regulatory bodies, courts, or other authorised public authorities where we are legally required to do so, or where disclosure is necessary to protect the rights, property, or safety of dewu11, its members, or the public.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of dewu11's business, Personal Data held by dewu11 may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material change to how your data is processed as a result.

7 International Data Transfers

7.1  The dewu11 platform serves Indonesian players and our primary data processing infrastructure is operated to serve this market. However, some Third-Party Processors engaged by dewu11 may operate servers or processing facilities outside Indonesia.

7.2  Where Personal Data is transferred internationally, dewu11 ensures that appropriate safeguards are in place to protect it, including contractual data protection clauses binding the receiving party to standards equivalent to those applied by dewu11.

7.3  By using the dewu11 platform, you acknowledge that your Personal Data may be processed in jurisdictions outside Indonesia as described in this section.

8 Data Retention

8.1  dewu11 retains Personal Data for no longer than is necessary for the purposes for which it was collected, subject to any longer retention period required by applicable law or regulatory obligation. The following retention schedules apply:

Data Category	Retention Period	Reason
Account and identity data	Duration of Account plus 5 years after closure	AML compliance and dispute resolution
KYC documents	Duration of Account plus 5 years after closure	Regulatory and AML obligations
Financial transaction records	7 years from date of transaction	Financial record-keeping and AML compliance
Betting and gaming activity logs	5 years from date of activity	Responsible gaming monitoring; dispute resolution
Customer support communications	3 years from date of communication	Dispute resolution and quality assurance
Technical and usage data	13 months from collection	Platform analytics and security monitoring
Marketing consent records	Until consent is withdrawn plus 1 year	Proof of consent

8.2  Upon expiry of the applicable retention period, Personal Data is either securely and permanently deleted or irreversibly anonymised so that it can no longer be attributed to any individual.

9 Security Measures

9.1  dewu11 implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and the Platform.
• Encryption at rest for sensitive data categories including KYC documents and financial account details stored on our servers.
• Access controls — access to Personal Data is restricted to dewu11 personnel and Third-Party Processors who have a legitimate operational need for it, subject to role-based access permissions.
• Two-factor authentication (2FA) available on all Player Accounts to add an additional layer of login security.
• Regular security audits and penetration testing conducted by independent third parties to identify and remediate vulnerabilities in the Platform.
• Incident response procedures — in the event of a data breach that is likely to result in a risk to your rights or freedoms, dewu11 will notify affected Players without undue delay.

9.2  While dewu11 takes all reasonable measures to protect your Personal Data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account login credentials and for notifying dewu11 immediately if you suspect any unauthorised access to your Account.

10 Cookies & Tracking Technologies

10.1  dewu11 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file stored on your device when you visit a website. dewu11 uses the following categories of cookies:

Cookie Type	Purpose	Can Be Disabled?
Strictly Necessary	Essential for Platform operation — enables login sessions, account authentication, and security features. Without these cookies the Platform cannot function.	No — required for site operation
Functional	Remembers your preferences (e.g., language settings, last visited games, preferred deposit method) to personalise your experience.	Yes — via browser settings
Analytics	Collects anonymised data about how Players navigate the Platform, which pages are most visited, and where technical errors occur — used to improve Platform performance.	Yes — via browser settings
Security / Fraud Prevention	Helps identify suspicious login behaviour, bot activity, and potential fraud attempts by analysing session patterns.	No — required for Platform security

10.2  You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling functional or analytics cookies may affect your experience on the Platform but will not prevent you from accessing core services.

10.3  dewu11 does not use third-party advertising cookies or permit external ad networks to place tracking cookies on the Platform.

11 Your Privacy Rights

11.1  As a dewu11 member, you hold the following rights in respect of your Personal Data. To exercise any of these rights, contact dewu11 at [email protected]. We will respond within 30 days of receiving a valid request.

• Right of Access: You may request a copy of all Personal Data that dewu11 holds 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 have the right to request that it be corrected or updated promptly.
• Right to Erasure ("Right to Be Forgotten"): You may request the deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where the processing is unlawful. This right is subject to dewu11's legal obligation to retain certain data categories for the periods defined in Section 8.
• Right to Restrict Processing: You may request that dewu11 limits the processing of your Personal Data in certain circumstances — for example, while a dispute about data accuracy is being resolved.
• Right to Data Portability: Where processing is based on your consent or on performance of a contract, you may request that your Personal Data be provided to you in a structured, commonly used, machine-readable format.
• Right to Object: You may object at any time to processing of your Personal Data where dewu11 relies on legitimate interests as the legal basis. You also have an absolute right to object to the use of your data for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

11.2  Please note that certain rights may be limited or overridden where dewu11 is subject to a legal obligation to retain or continue processing your data — for example, under AML or anti-fraud legislation. dewu11 will inform you if this is the case when responding to your request.

12 Minors

12.1  The dewu11 platform is strictly for adults aged 21 and over. dewu11 does not knowingly collect Personal Data from individuals under the age of 21. If we become aware that a minor has registered an Account or provided Personal Data through the Platform, we will immediately suspend the Account, delete the associated Personal Data, and take appropriate steps to prevent future access.

12.2  If you are a parent or guardian and believe that a minor in your care has registered an Account on dewu11, please contact us immediately at [email protected] so that we can take appropriate action without delay.

13 Third-Party Links

13.1  The dewu11 platform does not contain links to external third-party websites for commercial or advertising purposes. Where any reference is made to a third-party service provider (such as a payment provider), this is for informational clarity only. dewu11 is not responsible for the privacy practices of any third-party organisation, and we encourage you to review the privacy policies of any external service provider you use in connection with your dewu11 Account — such as your bank or e-wallet provider.

14 Policy Amendments

14.1  dewu11 reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, operational requirements, or applicable law. Where changes are material, we will notify registered Players by email at least 7 days before the amended Policy takes effect.

14.2  The current effective version of this Privacy Policy is always published on this page, with the "Last Updated" date displayed in the page header. Your continued use of the Platform after the effective date of an amendment constitutes your acceptance of the revised Policy.

14.3  If you do not accept a revised Privacy Policy, you must stop using the Platform and may close your Account by contacting dewu11 support.

15 Contact & Complaints

15.1  For any questions, concerns, or requests relating to this Privacy Policy or to your Personal Data, please contact the dewu11 support team through any of the following channels:

• Email: [email protected] — data-related requests are acknowledged within 24 hours and resolved within 30 days.
• Live Chat: Available 24 hours a day, 7 days a week through the Platform.
• WhatsApp: Available 08:00–24:00 WIB for general support queries.

15.2  All formal data subject requests must be submitted in writing (by email) and will receive a written response. dewu11 may request proof of identity before processing any access, rectification, or deletion request in order to protect against unauthorised requests.