Privacy Policy

This Privacy Policy ("Policy") is issued by win100, the operator of the online betting and gaming platform accessible at https://win100.cam ("Platform"). It applies to all personal data collected from Members, visitors, and prospective registrants who interact with the Platform, whether via desktop browser, mobile browser, or any associated mobile interface.

win100 is committed to handling your personal data with care, transparency, and respect. This Policy explains:

• What categories of personal data we collect and process
• The purposes for which we process that data
• The legal bases we rely upon for processing
• With whom we may share your data, and under what conditions
• How long we retain data and how we keep it secure
• The rights you hold with respect to your personal data and how to exercise them

By registering an account on the Platform or continuing to use our Services, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, you should cease using the Platform and contact us to discuss the closure of your account.

This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform. In the event of any inconsistency between the two documents on a data-related matter, this Policy prevails.

win100 collects personal data across several categories depending on the nature of your interaction with the Platform. The following table summarizes the key data categories and specific data points collected:

We do not knowingly collect sensitive personal data beyond what is required for identity verification (e.g., identity document images). We do not collect biometric data, health data, or political/religious affiliation data.

win100 collects personal data through the following channels:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated technologies: When you access the Platform, our servers automatically record Technical Data including your IP address, device identifiers, browser fingerprint, and session activity. This is collected via server logs, cookies, and similar tracking technologies (see Section 7).
• Payment processors: When you initiate a deposit or withdrawal, our integrated payment partners (local Indonesian banks and e-wallet providers) transmit transaction confirmation data to us, which we associate with your account.
• Third-party identity verification services: win100 may use licensed third-party KYC providers to cross-verify identity documents and confirm that the personal details you have provided are accurate.
• Responsible gaming tools: Data generated when you interact with self-exclusion, deposit limit, or session limit features within the Platform dashboard.

win100 processes your personal data for the following purposes:

• Account management: Creating and maintaining your account, verifying your identity and age (21+), authenticating your logins, and managing your account settings and preferences.
• Service delivery: Processing deposits and withdrawals via your chosen local bank or e-wallet, settling bets, awarding bonuses, and providing access to all Platform products.
• KYC and compliance: Meeting our obligations under applicable anti-money laundering (AML), counter-terrorist financing (CTF), and know-your-customer (KYC) regulatory requirements.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, bonus abuse, collusion, and other prohibited conduct as defined in our Terms & Conditions.
• Customer support: Responding to your enquiries, resolving disputes, and providing assistance via live chat and email.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviors, administering self-exclusion and limit settings, and fulfilling our duty-of-care obligations.
• Platform improvement: Analyzing aggregated usage data to improve platform performance, user experience, and product offerings. This analysis is conducted on anonymized or pseudonymized datasets wherever possible.
• Marketing communications: Sending you promotional offers, seasonal bonus notifications (e.g., Idul Fitri, Ramadhan, Indonesian Independence Day promotions), and platform updates — but only where you have consented to receive such communications. You may withdraw marketing consent at any time via account settings or by emailing [email protected].
• Legal compliance: Retaining records as required by applicable law and responding to lawful requests from competent authorities.

win100 processes personal data on the following legal bases, depending on the purpose of processing:

Where win100 relies on legitimate interests as a legal basis, we have conducted a balancing assessment to confirm that our interests do not override your fundamental rights and freedoms. You may request a summary of any such assessment by contacting [email protected].

win100 does not sell, rent, or trade your personal data to third-party marketers. We may share your data with the following categories of recipient, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: Local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI) and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum transaction data necessary to process your deposits and withdrawals.
• Identity verification providers: Licensed third-party KYC service providers receive your identity document data solely for the purpose of verifying your age and identity. These providers are contractually prohibited from using your data for any other purpose.
• IT and infrastructure providers: Cloud hosting providers, content delivery networks, and cybersecurity vendors who process data on our behalf under strict data processing agreements.
• Customer support platforms: Third-party live chat and helpdesk software providers who process support communication data on our behalf.
• Fraud prevention and analytics services: Specialist fraud detection providers who analyze transaction and behavioral patterns to protect Members and the Platform from abuse.
• Regulatory and law enforcement authorities: We will disclose personal data to competent governmental or regulatory authorities when legally required to do so, including in response to court orders, regulatory inquiries, or law enforcement requests. We will notify you of any such disclosure where legally permitted.
• Business transfers: In the event of a merger, acquisition, or sale of all or a substantial portion of win100's business assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

win100 uses cookies and similar tracking technologies to operate the Platform effectively, personalize your experience, and analyze usage patterns. The following categories of cookies are in use:

Strictly necessary cookies are placed automatically, as the Platform cannot function without them. For all other cookie categories, win100 will request your consent via an in-platform notice on your first visit. You may manage or withdraw cookie consent at any time through your browser settings or by contacting [email protected]. Please note that disabling functional or analytics cookies may affect your experience on the Platform.

win100 implements a comprehensive, multi-layered security framework to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• AES-256 encryption at rest for sensitive data stored in our databases, including financial records and identity documents.
• Multi-factor authentication (MFA) available for Member accounts and mandatory for all win100 internal staff accessing Member data systems.
• Role-based access controls (RBAC): Internal staff access to Member data is granted strictly on a need-to-know basis. All access events are logged and audited regularly.
• Intrusion detection and prevention systems (IDS/IPS) that continuously monitor network traffic for suspicious activity.
• Regular penetration testing and vulnerability assessments conducted by qualified third-party security specialists.
• Incident response plan: In the event of a confirmed data breach that poses a risk to Members' rights and freedoms, win100 will notify affected Members without undue delay and take all reasonable steps to mitigate harm.

While win100 applies industry-leading security practices, no method of electronic storage or transmission is 100% secure. Members are encouraged to use a strong, unique password for their win100 account and to enable any available two-factor authentication features. You are responsible for keeping your login credentials confidential.

win100 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Data that has been anonymized in a manner that prevents re-identification is no longer considered personal data and may be retained indefinitely for statistical purposes.

Depending on your jurisdiction and the legal bases applicable to the processing of your data, you may hold some or all of the following rights with respect to your personal data held by win100:

• Right of access: You may request a copy of the personal data win100 holds about you, along with information about how it is used and with whom it has been shared.
• 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. You can update basic account information directly from your account dashboard.
• Right to erasure ("right to be forgotten"): In certain circumstances, you may request the deletion of your personal data. This right is subject to exceptions, including our legal obligation to retain financial and identity records for a defined period after account closure.
• Right to restriction of processing: You may request that we restrict the processing of your personal data in certain situations — for example, while a rectification request is being assessed.
• Right to data portability: Where processing is based on your consent or the performance of a contract, and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing carried out on the basis of legitimate interests, including profiling for direct marketing purposes. Upon receipt of an objection to direct marketing, we will cease that processing immediately.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the rights listed above, please submit a written request to [email protected]. Please include your registered email address and, where applicable, a copy of your identity document so we can verify your identity before processing your request. We will respond within 30 days of receipt. If you are dissatisfied with our response, you have the right to escalate your complaint to the applicable data protection authority in your jurisdiction.

win100 employs mandatory age verification as part of its registration and KYC process. Any account found to belong to a person under 21 years of age will be immediately closed, all balances will be refunded to the originating payment method, and all associated data will be deleted in accordance with our data retention policy.

If you believe that a person under the age of 21 has registered an account on the Platform or has provided us with personal data, please contact us immediately at [email protected]. We will investigate and take appropriate action without delay.

win100's primary operations and data infrastructure are based in the jurisdiction of its licensing authority. As an operator serving Indonesian residents, some personal data may be transferred to, stored in, or processed in countries outside of Indonesia, including the location of our hosting infrastructure and those of certain third-party service providers.

Where such international transfers occur, win100 ensures that adequate safeguards are in place to protect your personal data to a standard at least equivalent to the protections applicable in Indonesia. These safeguards may include:

• Standard contractual clauses that impose data protection obligations on the recipient party
• Transfers to countries that have been assessed as providing an adequate level of data protection
• Binding corporate rules where applicable within a corporate group structure

You may request further information about the specific safeguards applicable to any international transfer of your personal data by contacting [email protected].

The win100 Platform does not contain outbound links to third-party websites. However, in the event that any linked content or integration directs you to an external site, please be aware that those sites operate under their own privacy policies, which are entirely independent of this Policy. win100 accepts no responsibility for the privacy practices or content of any third-party website, and we encourage you to review the privacy policy of any external site you visit.

win100 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the Services we offer. When material changes are made, we will notify you by posting a prominent notice on the Platform and, where appropriate, by sending a notification to your registered email address.

The updated Policy will specify the effective date of the revision. Your continued use of the Platform after that effective date constitutes your acknowledgment of the revised Policy. We recommend that you review this page periodically to stay informed of how we protect your personal data.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way win100 handles your personal data, please contact our dedicated data protection team through the following channel:

• Email: [email protected] — please include "Privacy Request" in the subject line.
• Live Chat: Available 24/7 directly within the Platform. Our Indonesian-speaking support agents can assist in both Bahasa Indonesia and English.
• Response time: We aim to acknowledge all privacy-related enquiries within 48 hours and provide a substantive response within 30 calendar days.

If you are not satisfied with our response to your complaint, or if you believe that win100 is processing your personal data in a manner inconsistent with this Policy or applicable data protection law, you have the right to lodge a complaint with the competent data protection supervisory authority in your jurisdiction.

This Privacy Policy was last reviewed and updated on 1 January 2026. It supersedes all previous versions of the win100 Privacy Policy.