Privacy Policy

1. Introduction

diwi11 ("we", "us", "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, share, and protect information about you when you use our online gaming platform at diwi11.cam and related services. This policy applies to all Indonesian residents who register accounts, place bets, or interact with our platform in any capacity.

By creating an account on diwi11 or using our services, you acknowledge that you have read, understood, and agreed to the data collection and usage practices described in this Privacy Policy. If you do not agree with any part of this policy, you should not use our services.

We are committed to compliance with Indonesian data protection regulations, including Law No. 27 of 2022 on Personal Data Protection (UU PDP), and international best practices for data security and privacy. This policy should be read in conjunction with our Terms and Conditions, which govern your overall use of diwi11 services.

2. Data Controller

For the purposes of data protection law, diwi11 is the data controller responsible for your personal information. We determine the purposes and means of processing your personal data. If you have questions about how we handle your data or wish to exercise your data protection rights, please contact our Data Protection Officer at [email protected].

3. Information We Collect

We collect several categories of personal information from and about users of our platform. The specific data we collect depends on how you interact with our services.

3.1 Information You Provide Directly

When you register an account or use diwi11 services, you voluntarily provide us with the following personal information:

• Account Registration Data: Full legal name, date of birth, gender, residential address (street, city, province, postal code), email address, mobile phone number, username, and password.
• Identity Verification Documents (KYC): Government-issued identification (KTP/National ID card, passport, driver's license), proof of address documents (utility bills, bank statements dated within 3 months), selfie photographs holding identification documents, and bank account or e-wallet verification screenshots.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account information (OVO, DANA, GoPay, ShopeePay account numbers), deposit and withdrawal transaction history, and currency preferences (Indonesian Rupiah).
• Communication Data: Content of messages you send us via live chat, email, WhatsApp, or other support channels, including customer service inquiries, complaint details, and feedback.
• Marketing Preferences: Your consent choices regarding promotional emails, SMS messages, push notifications, and other marketing communications.

3.2 Information Collected Automatically

When you access or use the diwi11 platform, we automatically collect certain technical and behavioral data:

• Device Information: Device type (smartphone, tablet, desktop computer), operating system and version (Android, iOS, Windows, macOS), browser type and version, screen resolution, device identifiers (IMEI, advertising ID), and mobile network information.
• Usage Data: Pages viewed, features accessed, games played, bet types placed, session duration, click patterns, navigation paths through the site, search queries, and time stamps for all activities.
• Location Data: IP address, country, city, and approximate geographic coordinates derived from IP geolocation (we do not collect precise GPS coordinates).
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing behavior. See Section 8 for detailed information about our cookie usage.
• Betting and Gaming Data: Complete history of bets placed, games played, winnings and losses, bonus claims and wagering progress, VIP tier progression, and account balance changes.

3.3 Information from Third Parties

We may receive information about you from third-party sources:

• Payment Providers: When you deposit or withdraw funds, our payment partners (banks, e-wallet providers, payment gateways) share transaction confirmation data with us to process your payments.
• Identity Verification Services: We use third-party KYC verification services to validate your identity documents and check against fraud databases and sanctions lists.
• Marketing Partners: If you arrive at diwi11 through an affiliate link or marketing campaign, we may receive referral information from the partner who directed you to us.

4. How We Use Your Information

diwi11 processes your personal data for the following specific purposes, all of which are necessary for providing our gaming services or comply with our legal obligations:

4.1 Account Management and Service Provision

• Creating and maintaining your player account
• Processing your deposits, withdrawals, and internal fund transfers
• Enabling you to place bets, play games, and access all platform features
• Calculating and crediting winnings to your account balance
• Managing your VIP tier status and loyalty rewards
• Processing bonus claims and tracking wagering requirements
• Providing customer support and responding to your inquiries

4.2 Legal and Regulatory Compliance

• Verifying your identity and age to ensure you are 21+ years old
• Conducting Know Your Customer (KYC) checks as required by anti-money laundering (AML) regulations
• Monitoring transactions for suspicious activity and reporting to Financial Intelligence Units if required by law
• Maintaining records for audit and regulatory purposes
• Complying with court orders, legal processes, or government requests for information
• Enforcing our Terms and Conditions and protecting our legal rights

4.3 Fraud Prevention and Security

• Detecting and preventing fraud, money laundering, bonus abuse, and other illegal activities
• Identifying and blocking multiple accounts created by the same individual
• Monitoring gameplay patterns to detect collusion, bot usage, or other unfair practices
• Protecting against hacking attempts, DDoS attacks, and other security threats
• Investigating complaints and resolving disputes

4.4 Platform Improvement and Analytics

• Analyzing user behavior to improve platform design, navigation, and performance
• Understanding which games, bet types, and features are most popular
• Testing new features, promotions, and user interface designs
• Optimizing mobile performance and fixing technical bugs
• Generating aggregate statistical reports (anonymized data that cannot identify individuals)

4.5 Marketing and Communications

• Sending you promotional offers, bonus notifications, and tournament announcements (only if you have consented to marketing communications)
• Personalizing promotional content based on your gaming preferences and history
• Sending transactional messages about your account, deposits, withdrawals, and important policy changes (you cannot opt out of these essential communications)
• Conducting customer satisfaction surveys to improve our services

4.6 Responsible Gaming

• Monitoring your gaming activity for signs of problem gambling behavior
• Enforcing deposit limits, loss limits, and session time limits you have set
• Processing self-exclusion requests and ensuring you cannot access your account during exclusion periods
• Providing access to responsible gaming tools and support resources

5. Legal Basis for Processing

Under Indonesian data protection law, we must have a valid legal basis for processing your personal data. We rely on the following legal grounds:

• Contract Performance: Processing is necessary to provide the gaming services you have requested when you create an account and agree to our Terms and Conditions (Article 20(1)(a) UU PDP).
• Legal Obligation: Processing is required to comply with Indonesian law, including KYC/AML regulations, age verification requirements, and tax reporting obligations (Article 20(1)(b) UU PDP).
• Legitimate Interests: Processing is necessary for our legitimate business interests in preventing fraud, improving our platform, and ensuring security, provided these interests do not override your fundamental rights (Article 20(1)(d) UU PDP).
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you can withdraw at any time (Article 20(1)(c) UU PDP).

6. How We Share Your Information

diwi11 does not sell your personal data to third parties. However, we share your information with the following categories of recipients when necessary to provide our services or comply with legal obligations:

6.1 Service Providers and Business Partners

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, etc.) and e-wallet providers (OVO, DANA, GoPay, ShopeePay) process your deposits and withdrawals. We share necessary transaction data with them to complete payments.
• Identity Verification Providers: Third-party KYC services verify your identity documents and perform background checks. We share your name, date of birth, address, and ID documents with these providers.
• Cloud Hosting Providers: Our platform and databases are hosted on secure cloud infrastructure. These providers have access to your data solely for the purpose of providing hosting services under strict confidentiality agreements.
• Customer Support Tools: We use third-party live chat and helpdesk software to manage customer inquiries. Support agents employed by diwi11 or our authorized partners can view your account information when assisting you.
• Analytics and Monitoring Services: We use analytics platforms to understand user behavior and improve our services. These providers receive anonymized or pseudonymized usage data.
• Game Content Providers: Some casino games and sports betting content are provided by third-party developers. These providers may process gameplay data to ensure game integrity and calculate outcomes.

6.2 Legal and Regulatory Authorities

We may disclose your personal data to government agencies, law enforcement, courts, or regulatory bodies when required by Indonesian law or international legal obligations. This includes:

• Responding to valid court orders, subpoenas, or search warrants
• Reporting suspicious transactions to the Indonesian Financial Transaction Reports and Analysis Centre (PPATK) under AML regulations
• Cooperating with law enforcement investigations into criminal activity
• Complying with tax reporting obligations to Direktorat Jenderal Pajak (Indonesian Tax Authority)

6.3 Corporate Transactions

If diwi11 is involved in a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity. In such cases, we will notify you via email and prominent notice on our website before your data is transferred and becomes subject to a different privacy policy.

6.4 Data Protection Standards for Third Parties

All third parties with whom we share your data are contractually required to:

• Process your data only for the specific purposes we have authorized
• Implement appropriate technical and organizational security measures
• Not use your data for their own marketing purposes without your separate consent
• Delete or return your data when the service contract ends
• Comply with Indonesian data protection law and international standards

7. Data Security Measures

diwi11 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data transmitted between your device and our servers is protected by industry-standard SSL/TLS encryption. Sensitive data stored in our databases (passwords, financial information) is encrypted at rest using AES-256 encryption.
• Access Controls: Employee access to personal data is restricted based on job role and necessity. All access is logged and monitored. Multi-factor authentication is required for administrative access to systems containing personal data.
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, and DDoS mitigation services. We conduct regular vulnerability scans and penetration testing.
• Data Segregation: Player funds are held in segregated bank accounts separate from operational capital, ensuring your money is always available for withdrawal.
• Secure Development Practices: Our software development follows secure coding standards, and all code undergoes security review before deployment.
• Incident Response: We maintain a data breach response plan and will notify you within 72 hours if a breach occurs that poses a risk to your rights and freedoms, in accordance with Indonesian law.
• Staff Training: All employees receive regular training on data protection principles, security best practices, and their legal obligations under UU PDP.
• Third-Party Audits: We engage independent security firms to audit our systems and practices annually.

8. Cookies and Tracking Technologies

diwi11 uses cookies, web beacons, and similar tracking technologies to enhance your experience on our platform. A cookie is a small text file stored on your device that allows us to recognize you on return visits.

8.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for the platform to function. These enable account login, maintain your session, process transactions, and remember your language preference.	Session or up to 30 days
Performance Cookies	Collect anonymous information about how you use our site, which pages are most popular, and where errors occur. This helps us improve platform performance.	Up to 2 years
Functional Cookies	Remember your preferences (display settings, favorite games) to provide enhanced features and personalization.	Up to 1 year
Marketing Cookies	Track your activity across websites to deliver relevant promotional content. These require your consent and can be disabled.	Up to 1 year

8.2 Managing Cookies

You can control cookie settings through your browser preferences. Most browsers allow you to:

• View what cookies are stored and delete them individually or entirely
• Block third-party cookies while allowing first-party cookies
• Block all cookies from specific websites
• Delete all cookies when you close your browser

Please note that blocking essential cookies will prevent you from using diwi11 services, as they are necessary for account login and security. Blocking performance or functional cookies may reduce platform functionality and personalization.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, and resolve disputes.

• Active Account Data: While your account remains active, we retain all account information, transaction history, and gameplay records to provide ongoing service.
• Closed Account Data: After you close your account, we retain your data for 7 years to comply with Indonesian financial record-keeping requirements and anti-money laundering regulations. After 7 years, we permanently delete your personal data.
• Marketing Data: If you opt out of marketing communications, we retain your email address on a suppression list indefinitely to ensure we do not contact you again.
• KYC Documents: Identity verification documents are retained for 7 years from the date of account closure to comply with AML record-keeping obligations.
• Self-Exclusion Records: If you self-exclude, we retain your details permanently to prevent you from re-registering and to fulfill our responsible gaming commitments.

10. Your Data Protection Rights

Under Indonesian Law No. 27 of 2022 on Personal Data Protection (UU PDP), you have the following rights regarding your personal data:

10.1 Right to Access

You have the right to request a copy of the personal data we hold about you. You can access most of this information through your account dashboard. For additional information, contact our Data Protection Officer at [email protected]. We will respond within 30 days and provide data in a commonly used electronic format.

10.2 Right to Rectification

If any of your personal data is inaccurate or incomplete, you have the right to request correction. You can update most information (address, phone number, email) through your account settings. For changes to your legal name or date of birth, contact customer support with supporting documentation.

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

You have the right to request deletion of your personal data in certain circumstances:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw consent (where consent was the legal basis for processing)
• You object to processing based on legitimate interests and we have no overriding grounds
• The data was processed unlawfully

This right is not absolute. We may refuse deletion if we are required to retain the data by Indonesian law (e.g., 7-year financial record retention) or to establish, exercise, or defend legal claims.

10.4 Right to Restrict Processing

You can request that we restrict how we use your data in certain situations, such as when you contest the accuracy of the data or object to processing. During restriction, we will store your data but not actively process it (except with your consent or for legal claims).

10.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller. This right applies only to data you provided to us based on consent or contract performance.

10.6 Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes. If you object to marketing, we will immediately stop sending promotional communications. For objections based on legitimate interests, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

10.7 Right to Withdraw Consent

Where we process your data based on consent (e.g., marketing communications, non-essential cookies), you can withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

10.8 Right to Lodge a Complaint

If you believe we have violated your data protection rights, you have the right to lodge a complaint with the Indonesian Data Protection Authority (Lembaga Pelindung Data Pribadi). You can also contact us first at [email protected], and we will work to resolve your concern.

10.9 Exercising Your Rights

To exercise any of these rights, email [email protected] with your request. We may need to verify your identity before fulfilling requests to protect against fraudulent requests. We will respond within 30 days and will not charge a fee unless your request is manifestly unfounded or excessive.

11. International Data Transfers

diwi11 primarily operates within Indonesia and stores your data on servers located in Indonesia and/or the Asia-Pacific region. However, some of our service providers (cloud hosting, analytics, customer support tools) may be located outside Indonesia, which means your data may be transferred to and processed in other countries.

When we transfer data internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by data protection authorities
• Transfers to countries deemed to have adequate data protection standards
• Binding corporate rules for intra-group transfers
• Your explicit consent for specific transfers

If you have questions about international data transfers, contact [email protected].

12. Children's Privacy

diwi11 services are strictly for individuals who are at least 21 years of age. We do not knowingly collect personal data from anyone under 21. If we become aware that we have inadvertently collected data from a person under 21, we will immediately delete that data and permanently close the account.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at [email protected].

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will notify you by:

• Sending an email to the address registered on your account
• Displaying a prominent notice on our website
• Requiring you to accept the updated policy when you next log in (for significant changes)

The "Last Updated" date at the top of this policy indicates when the most recent changes were made. We encourage you to review this policy periodically. Your continued use of diwi11 services after notice of changes constitutes acceptance of the updated policy.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact:

• Data Protection Officer: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 on our website
• Customer Service Hours (Peak): 09:00 - 01:00 WIB daily

We aim to respond to all privacy-related inquiries within 72 hours during business days.