Privacy Policy — ayowin Platform

This Privacy Policy ("Policy") is issued by ayowin ("we", "us", "our", "the Company") and applies to all personal data collected, processed, and stored in connection with the operation of the ayowin online betting platform, accessible at https://ayowin.cam, and all related services, mobile interfaces, and subdomains (collectively, "the Platform").

This Policy applies to all individuals who interact with the Platform, including registered Members, prospective registrants, and visitors who browse without registering. By accessing the Platform or submitting personal information to us, you acknowledge that you have read this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read in conjunction with the ayowin Terms & Conditions, available at /terms-conditions, which govern the broader contractual relationship between Members and ayowin. Where this Policy and the Terms & Conditions address the same matter, both documents apply and are to be read consistently with one another.

ayowin's Platform is directed at adults aged 21 and over who are residents of Indonesia or individuals otherwise legally permitted to access online gaming services in their jurisdiction. We do not knowingly collect personal data from individuals under the age of 21.

The following definitions apply throughout this Privacy Policy:

ayowin collects the following categories of Personal Data in the course of operating the Platform and delivering our Services:

Identity & Contact Data

• Full legal name as it appears on a government-issued identity document.
• Date of birth and age verification information.
• Indonesian National Identity Card number (NIK) or passport number.
• Residential address (street address, city, province, and postal code).
• Email address and mobile phone number.

Financial & Payment Data

• Bank account details for Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI (Bank Syariah Indonesia), and Bank Permata.
• E-wallet account identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Transaction history, deposit records, withdrawal records, and account balance history.

Technical & Usage Data

• IP address, device type, operating system, browser type and version.
• Session timestamps, login history, and pages visited within the Platform.
• Betting history, game activity, wagering patterns, and session duration.
• Customer support interaction records, including chat transcripts and email correspondence.

KYC & Verification Documents

• Scanned or photographed copies of identity documents (KTP, passport).
• Proof of address documentation (utility bills, bank statements issued within three months).
• Selfie or live-capture images used for facial recognition verification where required.

ayowin collects Personal Data through the following channels:

• Direct submission: Data provided by you at the point of account registration, during KYC verification, when making a deposit or withdrawal, when contacting customer support, or when participating in promotions.
• Automated collection: Technical data collected automatically as you use the Platform, including cookies, session tokens, IP address logging, and device fingerprinting.
• Third-party verification: Identity and age verification data received from our KYC service providers in response to verification requests we initiate based on your submissions.
• Payment processors: Transaction confirmation data received from Indonesian bank partners (BCA, BRI, BNI, Mandiri, and others) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) when you make deposits or request withdrawals.
• Fraud prevention systems: Risk signals and device reputation data received from third-party fraud detection providers engaged by ayowin to protect the integrity of the Platform.

ayowin processes your Personal Data for the following specific purposes:

ayowin processes your Personal Data on one or more of the following legal grounds:

• Contractual necessity: Processing is required to perform the contract between you and ayowin — specifically, to operate your account, process your transactions, and deliver the Services you have requested.
• Legal obligation: Processing is necessary for ayowin to comply with applicable legal requirements, including identity verification obligations, anti-money-laundering regulations, and responses to lawful authority requests.
• Legitimate interests: Processing is necessary for ayowin's legitimate business interests, including fraud detection, platform security, and the prevention of prohibited conduct, provided those interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

ayowin does not sell, rent, or trade your Personal Data to any third party. We may share your data only in the following strictly limited circumstances:

• KYC and identity verification providers: Third-party services engaged to verify the authenticity of identity documents and confirm age eligibility. These providers process data solely on our behalf and are bound by confidentiality agreements.
• Payment processors and banking partners: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, and others) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum data necessary to facilitate your deposit or withdrawal transactions.
• Fraud prevention and risk management providers: Specialist third-party systems that analyze transaction and behavioral data to identify suspicious activity. These providers operate as Data Processors under contractual data protection obligations.
• IT infrastructure and hosting providers: Cloud hosting and server management partners who maintain the technical infrastructure on which the Platform operates. All such providers are subject to binding data processing agreements.
• Regulatory and law enforcement authorities: Where required by law or court order, or where ayowin has reasonable grounds to believe that disclosure is necessary to prevent or investigate criminal activity including fraud or money laundering, we may disclose relevant data to Indonesian or international authorities without prior notice to the Member.
• Business restructuring: In the event of a merger, acquisition, or sale of all or part of ayowin's business, Member data may be transferred to the acquiring entity, subject to the same level of data protection described in this Policy.

Given the international nature of ayowin's operations and the third-party service providers we engage, your Personal Data may be transferred to and processed in countries outside of Indonesia. This may include countries whose data protection laws differ from those applicable in Indonesia.

Where such international transfers occur, ayowin takes appropriate safeguards to ensure that your data receives a level of protection consistent with the standards described in this Policy. These safeguards include:

• Entering into data processing agreements with recipient entities that incorporate standard contractual clauses requiring equivalent data protection standards.
• Transferring data only to jurisdictions that maintain internationally recognized data protection frameworks.
• Applying technical security measures — including end-to-end encryption — to all data transmitted across borders.

If you would like further information about the specific safeguards in place for any particular international data transfer, please contact our Data Protection team at [email protected].

ayowin retains your Personal Data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized so that it can no longer be associated with any individual. Where data must be retained beyond the standard period due to an ongoing legal proceeding or regulatory inquiry, it will be placed under restricted access until the matter is resolved.

ayowin employs a comprehensive range of technical and organizational security measures to protect your Personal Data against unauthorized access, disclosure, alteration, and destruction. Our security framework includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ayowin Platform, ensuring that session data, login credentials, and financial information are protected in transit.
• Encryption at rest for all Sensitive Data stored on our servers, including KYC documents, financial records, and identity information.
• Role-based access controls ensuring that Personal Data is accessible only to authorized personnel who require it for their specific operational function.
• Regular security audits and penetration testing conducted by independent cybersecurity specialists to identify and remediate vulnerabilities before they can be exploited.
• Multi-factor authentication (MFA) available for Member accounts to provide an additional layer of login security beyond passwords alone.
• Incident response protocols enabling rapid detection and containment of any potential data security incidents, with prompt notification to affected Members where required.

ayowin uses cookies and similar tracking technologies to operate essential Platform functions, analyze usage patterns, and deliver a personalized experience. The categories of cookies we use are as follows:

• Strictly necessary cookies: Required for the Platform to function correctly, including session management, authentication, and security tokens. These cannot be disabled without impairing core Platform functionality.
• Performance and analytics cookies: Collect aggregated, anonymized data about how Members navigate the Platform, which pages they visit most frequently, and how they interact with key features. This data is used solely to improve Platform performance and usability.
• Functional cookies: Remember your preferences — such as language settings, display options, and regional configurations — to provide a more consistent experience across sessions.
• Marketing cookies: Used only where you have provided explicit consent, to track engagement with promotional content and to avoid showing you irrelevant offers. You may withdraw consent for marketing cookies at any time.

Most web browsers allow you to manage cookie preferences through their settings. Disabling strictly necessary cookies may impair your ability to log in or use key Platform features. For guidance on managing cookies in your specific browser, please refer to that browser's official support documentation.

As a Member of the ayowin Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please submit a written request to [email protected]. We will respond within 30 calendar days of receipt.

• Right of Access: You may request a copy of the Personal Data we hold about you, together with information about how it is being processed.
• Right to Rectification: You may request the correction of any inaccurate or incomplete Personal Data we hold about you.
• Right to Erasure: You may request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to any legal retention obligations that require us to retain it for a longer period.
• Right to Restriction: You may request that we restrict the processing of your Personal Data in certain circumstances — for example, while an inaccuracy dispute is being resolved.
• Right to Data Portability: You may request that your Personal Data be provided to you in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
• Right to Object: You may object to processing carried out on the basis of our legitimate interests. We will cease that processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

The ayowin Platform is intended exclusively for adults aged 21 years and over. We do not knowingly collect, process, or retain Personal Data from individuals under the age of 21. If we become aware that a Member's account has been created by or on behalf of an individual under 21, we will immediately close that account, delete all associated Personal Data, and return any deposited funds to the originating payment method.

If you are a parent or guardian and believe that your child under 21 has registered on the ayowin Platform, please contact us immediately at [email protected] so that we can take prompt action. We take our obligation to protect minors from exposure to gambling services extremely seriously.

The ayowin Platform may, from time to time, contain references or links to third-party websites, services, or resources that are not operated or controlled by ayowin — for example, links to game provider websites or payment partner information pages. This Privacy Policy applies solely to data collected and processed by ayowin and does not extend to any third-party sites or services.

We encourage you to review the privacy policies of any third-party platforms you visit through or in connection with your use of the ayowin Platform. ayowin accepts no responsibility for the privacy practices, data handling, or content of third-party sites.

ayowin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform operations. When a material change is made, we will update the "Last Updated" date at the top of this Policy and, where appropriate, notify registered Members by email or via an in-platform notification.

Your continued use of the ayowin Platform following the posting of any revised Privacy Policy constitutes your acceptance of the updated terms. We recommend reviewing this Policy periodically to stay informed about how we protect your data. Archived versions of previous Privacy Policy revisions are available upon request by contacting our support team.

If you have any questions, concerns, or complaints relating to this Privacy Policy or the way ayowin handles your Personal Data, please contact our Data Protection team using the details below. Our team — including native Indonesian-speaking staff — is available 24 hours a day, 7 days a week (WIB, UTC+7).

If you are not satisfied with our response to your privacy complaint, you may escalate the matter to the relevant data protection authority in your jurisdiction. ayowin is committed to resolving all privacy concerns fairly and transparently, and we will cooperate fully with any regulatory inquiry.