Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by dew234 ("dew234", "we", "us", or "our"), the operator of the online betting and casino platform accessible at dew234.cam. It describes how we collect, use, disclose, store, and protect the personal data of individuals ("Members", "Users", or "you") who register for an account, access, or otherwise interact with the dew234 platform and its associated services.

dew234 is committed to handling all personal data with the highest standards of care, transparency, and security. Our data practices are designed to align with internationally recognised privacy frameworks, including the principles set out in the General Data Protection Regulation (GDPR) and applicable data protection legislation relevant to Indonesian residents.

By registering a dew234 account or continuing to use our platform, you confirm that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any aspect of this Policy, you must discontinue use of the platform and contact our support team to close your account.

2 Definitions

For the purposes of this Policy, the following terms carry the meanings defined below:

• "Personal Data" means any information that identifies or could reasonably identify a living individual, whether directly (e.g., full name, national identity number) or indirectly (e.g., device identifier, IP address, account username).
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means dew234 in its capacity as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third-party service provider that processes Personal Data on behalf of dew234 under a written data processing agreement.
• "KYC" means Know Your Customer — the identity verification and due diligence process we conduct to confirm your identity, age, and the legitimacy of your payment methods.
• "Sensitive Data" means a special category of Personal Data that requires heightened protection, including data relating to health, biometrics, religious beliefs, or racial and ethnic origin.
• "Platform" means the dew234 website, mobile-optimised web application, and all associated services operated at dew234.cam.

3 Data We Collect

We collect the following categories of Personal Data from or about our Members:

Data Category	Examples	Source
Identity Data	Full legal name, date of birth, nationality, government-issued ID number (KTP / Passport)	Registration form, KYC submission
Contact Data	Email address, Indonesian residential address, phone number	Registration form, account settings
Financial Data	Bank account name and number (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata), e-wallet identifier (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history	Deposit/withdrawal requests, KYC
Technical Data	IP address, browser type, device model, operating system, time-zone (WIB / WITA / WIT), session tokens	Automatic collection via platform
Usage Data	Pages visited, bet history, game session duration, login timestamps, feature interactions	Automatic collection via platform
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Direct interaction with support
Verification Documents	Scanned copies of National Identity Card (KTP), Passport, Driving Licence, selfie/liveness images, proof of payment method	KYC verification process

dew234 does not intentionally collect Sensitive Data. If Sensitive Data is incidentally disclosed to us (for example, in a support communication), we will handle it with appropriate safeguards and will not use it for profiling or marketing purposes.

4 How We Collect Data

We collect Personal Data through the following mechanisms:

• Direct submissions: Information you actively provide when registering an account, completing the KYC process, submitting deposit or withdrawal requests, or contacting our support team.
• Automated technical collection: Data gathered passively when you access the platform, including through cookies, server logs, pixel tags, and session-recording technologies that capture how you interact with the platform interface.
• Third-party service providers: Identity verification partners, payment processors, and fraud-detection services may share data with us as part of the service they provide on our behalf (e.g., confirming that your BCA or BRI bank account matches your registered name).
• Publicly available sources: In limited cases, we may cross-reference publicly available records to verify information you have provided, particularly in connection with anti-money-laundering (AML) compliance obligations.

5 Purpose of Processing

We process your Personal Data only for specific, explicit, and legitimate purposes. The primary purposes for which dew234 processes Personal Data are:

• Account creation and management: Registering your account, verifying your identity and age (21+ requirement), and maintaining your account profile.
• Service delivery: Processing deposits and withdrawals via your chosen Indonesian payment channels, settling bets and casino game outcomes, and delivering promotional offers you have opted into.
• KYC and AML compliance: Verifying your identity, confirming your payment method ownership, and monitoring transactions for patterns consistent with fraud or money laundering in accordance with our international compliance obligations.
• Platform security: Detecting, investigating, and preventing fraudulent activity, multiple-account abuse, bot usage, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible gaming: Monitoring gaming behaviour patterns to identify potential problem gambling indicators and to administer responsible gaming tools such as deposit limits, session time limits, and self-exclusion requests.
• Customer support: Responding to enquiries, resolving disputes, and improving our support processes based on interaction history.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the platform's design, performance, and feature set.
• Legal and regulatory compliance: Fulfilling any reporting or record-keeping obligations imposed by applicable law or by the terms of our international operating licence.

6 Legal Basis for Processing

dew234 relies on the following legal bases for processing your Personal Data:

• Contractual necessity: Processing required to perform our obligations under the Member Agreement — including account registration, transaction processing, and service delivery.
• Legal obligation: Processing required to comply with applicable AML, counter-terrorism financing, and KYC regulations imposed by our licensing authority and applicable international frameworks.
• Legitimate interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where our legitimate interests are not overridden by your fundamental privacy rights.
• Consent: Processing of non-essential data (such as personalised marketing communications) where you have provided clear, affirmative consent. You may withdraw consent at any time by contacting us at the address in Clause 15.

7 Data Sharing & Disclosure

dew234 does not sell, rent, or trade your Personal Data. We share your data only with the categories of third parties listed below, and only to the extent strictly necessary for the stated purpose:

• Payment processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction data necessary to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC/AML service providers receive your identity documents and biometric data solely for the purpose of verifying your identity and age.
• Technology partners: Cloud hosting providers, content delivery networks, cybersecurity firms, and platform analytics vendors who process data on our behalf under strict data processing agreements and are contractually prohibited from using your data for their own purposes.
• Game content providers: Certain game studios (such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft) may receive a pseudonymous session identifier to facilitate game delivery. These providers do not receive your full identity or financial data.
• Law enforcement and regulatory authorities: We will disclose Personal Data if required to do so by a valid court order, subpoena, regulatory directive, or applicable law. We will notify you of such disclosure where legally permitted to do so.

8 Data Retention

dew234 retains your Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following indicative retention periods apply:

• Account and identity records: Retained for the 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 the transaction, in line with international financial record-keeping standards.
• KYC documents: Retained for five (5) years following account closure or the completion of the KYC process, whichever is later.
• Support communications: Retained for three (3) years from the date of the last interaction, to support dispute resolution and service improvement.
• Technical and usage data: Retained in identifiable form for up to twenty-four (24) months, after which it is anonymised or deleted.
• Marketing consent records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised in accordance with our internal data destruction procedures.

9 Data Security

dew234 implements a comprehensive suite of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• SSL/TLS encryption: All data transmitted between your device and the dew234 platform is encrypted using industry-standard 256-bit SSL/TLS encryption, preventing interception by unauthorised third parties.
• Data-at-rest encryption: Personal Data stored on our servers is encrypted at rest using AES-256 encryption, ensuring that data remains protected even in the event of physical server compromise.
• Access controls: Access to Personal Data within dew234 is restricted on a strict need-to-know basis. All internal access is logged, audited, and subject to role-based access control policies.
• Multi-factor authentication: Administrative systems that process Personal Data require multi-factor authentication for all access attempts.
• Penetration testing: The platform undergoes regular independent security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident response: dew234 maintains a documented data breach response procedure. In the event of a security incident that is likely to result in a risk to your rights and freedoms, we will notify you promptly and take all reasonable steps to contain and remediate the breach.

While dew234 takes all reasonable precautions to protect your Personal Data, no internet-based platform can guarantee absolute security. You are responsible for keeping your account credentials — username, password, and any two-factor authentication codes — strictly confidential and for logging out of your account after each session, particularly when using shared or public devices.

10 Cookies & Tracking Technologies

dew234 uses cookies and similar tracking technologies to operate and improve the platform, personalise your experience, and gather analytical insights. A cookie is a small text file placed on your device by the platform server when you visit the platform.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the platform to function correctly. These include session authentication tokens, security cookies, and load-balancing identifiers. These cookies cannot be disabled without impairing your ability to use the platform.
• Functional cookies: Remember your preferences such as language selection, preferred deposit method, and responsible gaming settings, so that you do not need to reconfigure them on each visit.
• Analytics cookies: Collect anonymised or pseudonymised data about how Members navigate the platform, which features are used most frequently, and where technical errors occur. This data is used solely for internal platform improvement.
• Security cookies: Assist in detecting and preventing fraudulent login attempts, bot activity, and multiple-account abuse by tracking device fingerprint consistency across sessions.

You may manage cookie preferences through your browser settings. Please note that disabling functional or analytics cookies may affect the quality of your experience on the platform but will not prevent you from accessing core betting and gaming services.

11 Your Data Rights

Subject to applicable law and certain legitimate restrictions (such as our AML record-keeping obligations), you hold the following rights with respect to your Personal Data held by dew234:

• Right of access: You may request a copy of all Personal Data we hold about you, together with information about how it is being processed.
• Right to rectification: You may request that inaccurate or incomplete Personal Data be corrected or updated. Minor updates (such as contact email or residential address) can be made directly through your account settings panel.
• Right to erasure: You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations. Please note that AML and KYC regulations require us to retain certain identity and transaction records for a minimum of five (5) years regardless of an erasure request.
• Right to restriction: You may request that we restrict processing of your Personal Data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to data portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you may request a copy of your Personal Data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing carried out on the basis of legitimate interests, including profiling for responsible gaming purposes, at any time. We will cease processing unless we can demonstrate compelling legitimate grounds that override your objection.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal.

To exercise any of the above rights, please submit a written request to our Data Protection contact at [email protected] with the subject line "Data Rights Request — [Your Account Username]". We will respond within thirty (30) calendar days of receipt. Identity verification may be required before we action a request to protect against fraudulent access to another Member's data.

12 Minors

The dew234 platform is strictly intended for adults aged 21 years and above. We do not knowingly collect Personal Data from individuals under 21 years of age. Our registration process and KYC verification procedures are specifically designed to detect and prevent access by minors.

If dew234 discovers or is notified that Personal Data belonging to a person under 21 years of age has been collected — whether through misrepresentation during registration or any other means — we will immediately suspend the associated account, delete all Personal Data relating to that individual to the extent permitted by law, and return any deposited funds to the payment method used.

If you believe that a minor has registered an account on our platform, please notify us immediately at [email protected] so that we can take prompt corrective action.

13 International Data Transfers

As an internationally operated platform, dew234 may transfer your Personal Data to servers, service providers, or processing facilities located outside of Indonesia. Such transfers occur where our cloud infrastructure, KYC partners, or game content providers operate from jurisdictions other than Indonesia.

Whenever Personal Data is transferred internationally, dew234 ensures that appropriate safeguards are in place to protect the data at a level equivalent to the protections described in this Policy. These safeguards may include:

• Standard contractual clauses approved by recognised international data protection authorities, incorporated into our agreements with all Data Processors operating outside Indonesia.
• Transfers only to jurisdictions that maintain an adequate level of data protection as assessed against internationally recognised standards.
• Binding corporate rules or equivalent intra-group data transfer mechanisms where applicable.

14 Policy Amendments

dew234 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 features. When material changes are made, we will notify registered Members via the email address on record at least seven (7) calendar days before the revised Policy takes effect.

The "Last Updated" date displayed at the top of this document reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how we protect your data. Your continued use of the dew234 platform following the effective date of any revised Policy constitutes your acknowledgement and acceptance of the changes.

If a proposed amendment materially reduces your privacy rights and you do not accept the revised Policy, you must cease using the platform and contact us to close your account before the effective date of the change.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way dew234 handles your Personal Data, please contact our support team using the details below:

• Email: [email protected]
• Subject line for data rights requests: "Data Rights Request — [Your Account Username]"
• Subject line for privacy enquiries: "Privacy Enquiry — [Your Account Username]"
• Support Hours: Daily, 08:00 – 23:00 WIB (Western Indonesia Time, UTC+7)
• Response Time: Within 30 calendar days for formal data rights requests; within 24 hours for general privacy enquiries.