diwi11 Privacy Policy

Throughout this Privacy Policy, the following terms carry the meanings defined below. Familiarity with these definitions will help you understand how diwi11 handles your personal information.

diwi11 collects the following categories of Personal Data from Members and prospective Members. We collect only what is necessary for the purposes described in this policy.

diwi11 collects Personal Data through the following channels and mechanisms:

• Direct submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting our support team, or responding to a survey or promotion.
• Automated technologies: Technical Data and Usage Data collected automatically when you access the Platform, via cookies, web beacons, server logs, and similar technologies (see Section 7 for cookie details).
• Payment processors: Transaction confirmation data shared with us by your bank (BCA, BRI, BNI, Mandiri, and others) or e-wallet provider (OVO, DANA, GoPay, ShopeePay, LinkAja) to confirm the status of deposits and withdrawals.
• KYC verification partners: Identity verification results returned by our third-party KYC service providers, including document authenticity checks and sanction-list screening outcomes.
• Fraud prevention services: Risk signals and device fingerprint data provided by our fraud-detection infrastructure to identify potentially suspicious account activity.

diwi11 processes your Personal Data for the following specific purposes. We do not use your data for any purpose that is incompatible with those listed here without first seeking your consent.

• Account management: Creating, maintaining, and securing your diwi11 account, including processing login requests, resetting passwords, and managing session security.
• Transaction processing: Executing deposits and withdrawals via Indonesian local banks and digital wallets, reconciling your Wallet balance, and maintaining an accurate transaction history.
• Identity and age verification: Confirming that you are at least 21 years of age and that the identity information provided at registration is accurate, in compliance with our KYC obligations.
• Fraud prevention and security: Detecting and investigating suspicious activity, enforcing our one-account-per-person policy, preventing money laundering, and protecting the integrity of the Platform.
• Responsible gaming: Monitoring usage patterns to identify signs of problem gambling, enforcing self-exclusion requests, and applying deposit or session limits set by the Member.
• Customer support: Handling your enquiries, resolving disputes, and maintaining records of support interactions for quality assurance and training purposes.
• Marketing communications: Sending promotional emails, bonus notifications, and personalised offers to Members who have opted in to marketing communications. You may withdraw consent at any time.
• Platform improvement: Analysing aggregated Usage Data to understand how Members interact with the Platform and to inform product development decisions.
• Legal and regulatory compliance: Meeting our obligations under applicable anti-money laundering (AML) regulations, record-keeping requirements, and obligations arising from court orders or official government requests.

diwi11 processes your Personal Data on one or more of the following legal grounds, depending on the specific purpose:

• Contractual necessity: Processing required to fulfil our obligations under the diwi11 Terms & Conditions, including operating your account and processing transactions.
• Legal obligation: Processing required to comply with applicable AML regulations, KYC requirements, and any legally binding official requests.
• Legitimate interests: Processing necessary for fraud prevention, Platform security, responsible gaming monitoring, and internal analytics, where those interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and optional personalisation features, where you have given clear, freely withdrawable consent. Where consent is the basis, you may withdraw it at any time without affecting the lawfulness of prior processing.

diwi11 does not sell your Personal Data. We share it only in the limited circumstances described below, and only with parties who are contractually bound to protect it to a standard equivalent to this policy:

• KYC and identity verification providers: Third-party services that process identity documents and screen against sanction lists on our behalf. These providers act as Data Processors under written agreements.
• Payment processors and banking partners: Indonesian banks and digital wallet operators (including those processing transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja) who require sufficient transaction data to execute deposits and withdrawals.
• Fraud prevention and security services: Specialist providers who analyse Technical Data and transaction patterns to detect and prevent fraudulent activity on the Platform.
• Game content providers: Licensed studios (including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, and Spribe) may receive a Member's session token and stake data to facilitate gameplay. These providers do not receive full identity data.
• Legal and regulatory authorities: Where diwi11 is required by law, court order, or binding regulatory direction to disclose Personal Data, we will comply. We will notify the affected Member of such disclosure wherever legally permissible.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of diwi11's business, Personal Data held by diwi11 may be transferred to the acquiring entity. Members will be notified of any such transfer and their rights will be maintained.

The diwi11 Platform uses cookies and similar tracking technologies to deliver core functionality, maintain your session, and improve your experience. The cookies we use fall into the following categories:

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your diwi11 account. diwi11 does not use third-party advertising cookies or tracking pixels for retargeting campaigns on external platforms.

diwi11 retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Active account data: Retained for the full duration of your account's active status plus a minimum of five (5) years following account closure, to satisfy AML record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with financial record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant KYC review, whichever is later.
• Support communications: Retained for three (3) years from the date of the last interaction, for dispute resolution and quality-assurance purposes.
• Marketing data: Retained only while your marketing consent remains active. Upon withdrawal of consent, your details are removed from marketing lists within 48 hours.
• Technical and usage logs: Retained for a maximum of ninety (90) days in raw form. Aggregated, anonymised analytics data may be retained indefinitely.

Once the applicable retention period expires and there is no longer a legal or operational basis for retaining your data, diwi11 will securely delete or anonymise it.

diwi11 implements a comprehensive set of technical and organisational measures to protect your Personal Data against unauthorised access, loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• AES-256 encryption for Personal Data stored at rest in our databases.
• Role-based access control ensuring that only authorised personnel can access Personal Data, on a strict need-to-know basis.
• Multi-factor authentication required for all diwi11 administrative and operational system access.
• Regular penetration testing and vulnerability assessments conducted by qualified independent security firms.
• Automated intrusion-detection systems that monitor for anomalous access patterns in real time.
• Formal incident response procedures with defined escalation paths and notification timelines in the event of a confirmed data breach.

Despite these measures, no system connected to the internet can be guaranteed to be completely secure. If you believe your diwi11 account has been compromised, contact our support team immediately via Live Chat or WhatsApp so we can act promptly to protect your account.

As a diwi11 Member, you hold the following rights in relation to your Personal Data. To exercise any of these rights, contact our support team via email at [email protected] or through the Live Chat function. We will respond within ten (10) business days of receiving a valid request.

• Right of access: You may request a copy of the Personal Data diwi11 holds about you, along with information about how it is being used.
• Right to rectification: You may request that inaccurate or incomplete Personal Data be corrected. Minor details (such as contact number) can be updated directly through account settings.
• Right to erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our overriding legal obligations (e.g., AML record-keeping requirements that mandate a minimum five-year retention period).
• Right to restrict processing: You may request that we pause processing of your Personal Data in certain circumstances — for example, while the accuracy of data you have contested is being verified.
• Right to data portability: You may request a copy of Personal Data you have provided to us in a structured, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: You may object to processing carried out on the basis of legitimate interests. diwi11 will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.

The diwi11 Platform is strictly intended for adults aged 21 and over. diwi11 does not knowingly collect Personal Data from individuals under the age of 21. If we become aware that an account has been registered by a person under 21, we will immediately close the account and delete all associated Personal Data. If you have reason to believe that a minor has registered a diwi11 account, please contact our support team immediately so that we can investigate and take appropriate action.

The diwi11 Platform may contain links to third-party game providers or content partners. Once you leave the diwi11 Platform and access a third-party site or service, this Privacy Policy no longer applies. diwi11 is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policy of any third-party service you access through or in connection with the Platform before providing any Personal Data to that service.

diwi11 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or operational requirements. Where amendments are material, we will notify Members by email to their registered address or by posting a prominent notice on the Platform at least seven (7) days before the changes take effect. The "Effective Date" at the top of this policy will be updated on each revision. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgement of the revised policy. We recommend reviewing this page periodically to stay informed of how diwi11 protects your data.

If you have any questions about this Privacy Policy, wish to exercise a data right, or want to raise a concern about how diwi11 has handled your Personal Data, please contact us through any of the following channels:

• Email: [email protected] — include "Privacy Request" in the subject line for fastest routing. Responses within 24 hours during WIB business hours.
• Live Chat: Available 24/7 via the chat widget on the diwi11 Platform (00:00–24:00 WIB, every day of the year).
• WhatsApp: +62 811 1234 5678 (08:00–24:00 WIB).

diwi11 is committed to resolving all privacy-related complaints promptly and fairly. We will acknowledge your complaint within 24 hours and aim to provide a full response within ten (10) business days. If you are not satisfied with our response, you may refer your complaint to the relevant data protection authority in your jurisdiction.