Privacy Policy — win178

win178 ("we", "us", "our") is committed to protecting and respecting the privacy of every person who visits, registers with, or transacts on the win178 platform at https://win178.cam (the "Platform"). This Privacy Policy sets out the basis on which any personal data we collect from you — or that you provide to us — will be processed.

This policy applies to all members of win178, including residents of Jakarta, Surabaya, Medan, Bandung, Bali, Yogyakarta, Semarang, Palembang, and Makassar, as well as all other users across Indonesia who access our Platform using English-language interfaces. It covers all product lines available on the Platform, including sports betting, live casino, slot gacor (high-RTP online slots), togel (Indonesia's traditional numbers lottery), and sabung ayam (live cockfighting) streams.

By accessing the Platform, creating an account, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and agree to the data practices described herein. This policy is incorporated by reference into our Terms & Conditions and forms part of your overall agreement with win178.

For the purposes of applicable data protection law, the data controller responsible for your personal data is the operating entity behind the win178 brand, which holds an international gaming licence and operates the Platform at https://win178.cam.

Enquiries regarding this Privacy Policy or the exercise of your data rights should be directed to our dedicated Data Protection contact using the details set out in Clause 14 of this policy. All such enquiries are handled by our compliance team and are subject to a 30-day response commitment.

The categories of personal data win178 collects and processes are described in the table below. We collect only what is necessary for the stated purposes.

win178 does not intentionally collect any special categories of personal data (such as racial or ethnic origin, health data, religious beliefs, or biometric data) except where strictly required by our KYC programme (for example, a photograph on a government identity document). Such data is processed solely for the purpose of identity verification and is not used for any other purpose.

win178 collects personal data thro ugh the following channels:

• Direct interactions: Data you provide when you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or update your account settings.
• Automated technologies: Technical data collected automatically when you visit the Platform, including IP address, browser fingerprint, device identifiers, session timestamps, and clickstream data, gathered via server logs, cookies, and similar tracking technologies.
• Payment processors: Transaction confirmation data returned by our payment partners when you deposit or withdraw funds via BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, DANA, GoPay, ShopeePay, or LinkAja.
• KYC verification partners: Identity verification data returned by our contracted KYC and anti-fraud service providers after you submit identity documents for review.
• Third-party game studios: Aggregated game outcome and session data provided by licensed game studios such as Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft, and Microgaming for the purpose of audit, dispute resolution, and responsible gaming monitoring.
• Fraud prevention and risk systems: Signals from our internal risk management engine and, where applicable, external fraud intelligence databases, used to detect irregular account behaviour or potential money laundering activity.

win178 processes your personal data only where there is a valid legal basis for doing so. The table below maps each processing purpose to its corresponding legal basis.

Where win178 relies on legitimate interests as the legal basis for processing, we have assessed that our interests do not override your fundamental rights and freedoms, taking into account the reasonable expectations of members using an online betting and gaming platform.

win178 does not sell, rent, or trade your personal data. We share data with third parties only in the following defined circumstances, and always subject to contractual data protection obligations:

• Payment processors and banking partners: Your name, account number, and transaction details are shared with the relevant Indonesian bank (BCA, BRI, BNI, Mandiri, CIMB Niaga, or BSI) or e-wallet provider (OVO, DANA, GoPay, ShopeePay, or LinkAja) solely to execute your deposit or withdrawal instruction.
• KYC and identity verification providers: Identity documents and personal details are shared with our contracted KYC partner solely for the purpose of verifying your identity and address in compliance with our international licensing requirements.
• Game studio operators: Minimal session and account identifiers are shared with licensed game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) to facilitate game session authentication and audit trails.
• Anti-fraud and risk intelligence services: Technical identifiers (IP address, device fingerprint) may be checked against fraud intelligence databases to protect the integrity of the platform and all members.
• Regulatory and law enforcement authorities: win178 will disclose personal data to licensing authorities, financial intelligence units, or law enforcement agencies where required to do so by applicable law or a binding legal order.
• Professional advisors: Legal counsel, auditors, and compliance consultants engaged by win178 may access relevant member data under strict confidentiality obligations when providing advice or conducting audits.

As an internationally operated platform, win178 may process and store your personal data on servers located outside of Indonesia. Some of our technology partners, game studio operators, and cloud infrastructure providers maintain data centres in jurisdictions that may not have data protection laws equivalent to those of the European Union or specific national standards.

Where such international transfers occur, win178 ensures that appropriate safeguards are in place, which may include:

• Standard contractual clauses approved by recognised data protection authorities, incorporated into agreements with all third-party data processors outside Indonesia.
• Binding corporate rules where the third party is part of a corporate group with an approved intra-group data transfer mechanism.
• Adequacy decisions or equivalent international frameworks recognised by our licensing jurisdiction.

You may request further information about the specific safeguards applied to any international transfer of your personal data by contacting our support team using the details in Clause 14.

win178 implements a layered technical and organisational security programme designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Key elements of this programme include:

• Transport Layer Security (TLS 1.3): All data in transit between your device and win178 servers is encrypted using TLS 1.3 with 256-bit AES cipher suites.
• Encryption at rest: Sensitive data fields — including identity document scans, bank account details, and password hashes — are encrypted at rest using AES-256 with hardware security module (HSM) key management.
• Access control: Access to member personal data within win178's internal systems is restricted on a strict need-to-know basis, enforced through role-based access controls (RBAC) and multi-factor authentication (MFA) for all administrative users.
• Penetration testing: win178 commissions independent security audits and penetration tests on a regular basis to identify and remediate potential vulnerabilities before they can be exploited.
• Incident response: win178 maintains a documented data breach incident response plan. In the event of a breach, our security team is trained to contain, assess, and remediate the incident, and to notify affected members and relevant authorities within the required timeframes.
• Staff training: All win178 staff with access to member data receive mandatory data protection and information security training upon onboarding and on a recurring annual basis.

win178 retains your personal data for as long as is necessary to fulfil the purpose for which it was collected, taking into account our licensing obligations, legal requirements, and legitimate business interests. The following retention schedules apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

As a member of win178, you hold the following rights in relation to the personal data we process about you. These rights may be subject to certain conditions and limitations under applicable law and our licensing obligations.

• Right of Access: You have the right to request a copy of the personal data win178 holds about you, together with information about how it is being processed. We will respond to access requests within 30 days.
• Right to Rectification: If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it. Minor corrections (such as updates to your contact number) can be made directly via your member account settings.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances — for example, where data is no longer necessary for the purpose it was collected — you may request that we delete your personal data. Please note that this right is subject to our legal obligation to retain certain records under our licensing and AML requirements, as set out in Clause 9.
• Right to Restrict Processing: You may request that we restrict the processing of your personal data in certain circumstances, such as while a dispute regarding accuracy is being resolved.
• Right to Object: Where we rely on legitimate interests as our legal basis, you have the right to object to that processing. You also have an unconditional right to object to processing for direct marketing purposes at any time.
• Right to Data Portability: Where processing is based on your consent or a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to Withdraw Consent: Where we rely on your consent as the legal basis for processing (for example, for promotional emails), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. To opt out of marketing communications, update your preferences in your member account settings or contact our support team.

win178 uses cookies and similar tracking technologies to operate the Platform effectively, maintain your session, remember your preferences, and analyse platform performance. The categories of cookies we use are described below.

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable core features such as member authentication, session management, and security. You cannot opt out of these cookies while using the Platform.
• Performance & Analytics Cookies: These cookies collect aggregated, anonymised data about how members use the Platform — such as which pages are visited most frequently and whether error messages are encountered. This data is used to improve platform performance and user experience.
• Functionality Cookies: These cookies remember your preferences and settings — such as your preferred language, time-zone display (WIB/WITA/WIT), and bet slip configuration — so you do not have to reconfigure them on each visit.
• Fraud Prevention Cookies: These cookies support our risk management systems by helping to identify unusual account activity, bot traffic, and other potential security threats. They are considered strictly necessary for the safe operation of a financial services platform.

win178 does not use third-party advertising cookies or behavioural tracking cookies that profile your activity across other websites for the purpose of targeted advertising. Most web browsers allow you to control cookies through their settings. However, disabling strictly necessary cookies may prevent you from accessing certain features of the Platform.

The win178 platform is strictly intended for adults aged 21 and over. We do not knowingly collect or process personal data from persons under the age of 21. If win178 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered an account or submitted personal data to win178, please notify us immediately at [email protected]. We treat all such reports as high-priority safeguarding matters and will investigate and respond without delay.

Parents and guardians are encouraged to use parental control software to prevent underage individuals from accessing online betting and gaming platforms. For guidance on available responsible gaming tools for our members, please visit our Responsible Gaming page.

win178 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or licensing requirements. The date of the most recent revision is displayed prominently at the top of this page.

Where changes are material — for example, where we introduce a new purpose for processing your data or share data with a new category of third party — we will notify you via your registered email address at least seven (7) days before the changes take effect. For non-material changes, such as clarifications or corrections, the updated policy will take effect upon publication.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. Continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated policy. If you do not accept the revised policy, you may close your account by contacting our support team prior to the effective date.

If you have any questions, concerns, or complaints about this Privacy Policy, the way in which win178 handles your personal data, or if you wish to exercise any of your data rights, please contact our support team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via your member dashboard. Our support agents are available in both English and Bahasa Indonesia. Average first response time: under 2 minutes.
• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Data Rights Request" as appropriate. Responses are provided within 30 days for data rights requests and within 24 hours (WIB, UTC+7) for general privacy enquiries.

win178 is committed to resolving all privacy-related concerns promptly and transparently. If you submit a formal privacy complaint and are not satisfied with our response, you may escalate the matter to the data protection authority or gaming regulator of our licensing jurisdiction. Details of the relevant authority will be provided upon request.