won91 Privacy Policy

won91 ("we", "us", "our") is committed to protecting and respecting the privacy of every person who uses our online gaming 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. It applies to all services offered through https://won91.app, including casino games, live dealer tables, sportsbook betting, slot gacor (high-payout slot) titles, and all associated account management and payment services.

This policy is written in plain English and is designed to be transparent and easy to understand. Where technical or legal terms are unavoidable, we provide explanations. If you have any questions about anything in this policy, please contact us using the details in Clause 16 before using the platform.

won91 primarily serves players based in Indonesia, including major cities such as Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, Semarang, and Makassar. All account balances are held in Indonesian Rupiah (IDR) and payment processing is supported for leading Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja). These local integrations mean we process certain Indonesia-specific personal and financial data as described in this policy.

For the purposes of applicable data protection legislation, won91 is the data controller in respect of personal data processed through the platform. The data controller is responsible for determining the purposes and means of processing your personal data and for ensuring that such processing is carried out lawfully, fairly, and transparently.

As the data controller, won91 is accountable for the personal data it holds and processes. If you wish to exercise any of your data rights described in Clause 10, or if you have a complaint about how your data has been handled, the appropriate contact channels are set out in Clause 16.

won91 collects and processes the following categories of personal data. We collect only what is necessary for the specific purpose identified and do not retain data beyond its useful life.

won91 does not intentionally collect special categories of sensitive personal data (such as health information, racial or ethnic origin, or religious beliefs) unless it is strictly necessary for responsible gaming assessments and you have provided explicit consent for that specific purpose.

won91 collects personal data through the following methods:

• Direct provision by you: Data you supply when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or responding to a survey or promotion.
• Automated technologies: Data collected automatically as you use the platform, including cookies, server logs, pixel tags, and session-replay tools that help us understand how players interact with the site and identify technical issues.
• Third-party service providers: Data received from identity verification bureaus, payment processors (including Indonesian bank gateways and e-wallet providers), fraud detection services, and game content suppliers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. These providers may share data with us as part of their contracted services.
• Publicly available sources: In limited circumstances for fraud prevention or AML compliance, won91 may cross-reference data against publicly available records or licensed third-party databases.

won91 processes your personal data only where we have a legitimate legal basis for doing so. The table below maps each processing purpose to its legal basis:

Where we rely on legitimate interest as the legal basis, we have conducted a balancing test and determined that our interest does not override your fundamental rights and freedoms as a data subject.

won91 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and only to the extent necessary for the stated purpose:

• Payment processors and banking partners: Indonesian bank gateways (BCA, BRI, BNI, Mandiri, and others), e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), and QRIS infrastructure operators — solely to process your deposit and withdrawal instructions.
• Identity verification providers: Licensed KYC and AML service providers who assist us in verifying your identity and age in compliance with our licensing obligations.
• Game content suppliers: Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive limited technical data (session tokens, game identifiers) necessary to deliver their games to your device. These providers operate under strict data processing agreements.
• Technology and infrastructure providers: Cloud hosting, content delivery, customer support software, and cybersecurity service providers who process data on our behalf under contractual data protection obligations.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory directive, won91 will disclose personal data to competent authorities. We will notify you of such disclosures where legally permitted to do so.
• Fraud prevention networks: We may share limited data with industry fraud-prevention consortia to protect our platform and other operators from known bad actors.

All third parties with whom we share personal data are required by contract to maintain appropriate technical and organisational security measures and to process data only for the specific purpose for which it was shared.

won91 uses cookies and similar technologies (pixel tags, local storage) to operate the platform effectively, remember your preferences, analyse usage patterns, and deliver relevant promotions. The cookies we use fall into the following categories:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication tokens and security cookies. They cannot be disabled without impairing platform functionality.
• Functional cookies: Remember your preferences such as language choice, preferred payment method, and responsible gaming settings so you do not need to re-enter them on each visit.
• Analytics cookies: Help us understand aggregate player behaviour — which games are most popular, where players experience friction in the deposit flow, and how long sessions typically last. This data is anonymised where possible.
• Marketing cookies: Used only where you have consented to receive personalised promotional offers. These cookies may track your activity across sessions to ensure you see promotions relevant to your gaming preferences.

You may manage your cookie preferences through your browser settings. Disabling analytics or marketing cookies will not affect your ability to play games or access your account. Please note that disabling strictly necessary cookies will prevent the platform from operating correctly.

won91 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, taking into account any legal, regulatory, or contractual retention obligations. Our standard retention periods are as follows:

Where data is no longer required for any legitimate purpose, it will be securely deleted or anonymised so that it can no longer be associated with you as an individual.

As an internationally operated platform, won91 may transfer your personal data to countries outside Indonesia for storage and processing — for example, to cloud infrastructure providers or game content suppliers whose servers are located in other jurisdictions. Where such transfers occur, won91 takes the following steps to ensure your data remains adequately protected:

• Transfers to service providers are governed by binding contractual clauses that require the recipient to apply data protection standards equivalent to those applied by won91.
• We conduct due diligence on all third-party processors to verify that their security practices meet the standards required under our data protection obligations.
• Where a recipient country has been recognised as providing adequate data protection under applicable international frameworks, we rely on that adequacy determination as the transfer mechanism.

As a data subject, you have the following rights in relation to the personal data won91 holds about you. You may exercise any of these rights by contacting our support team at [email protected]. We will respond to all valid requests within 30 calendar days.

• Right of access: You may request a copy of the personal data won91 holds about you, along with information about how it is being processed.
• Right to rectification: If any personal data we hold is inaccurate or incomplete, you have the right to request that it be corrected. For account-level changes (name, address, contact details), please contact our support team directly.
• Right to erasure ("right to be forgotten"): You may request that won91 delete your personal data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent. This right is subject to legal retention obligations — for example, AML regulations require us to retain certain records for five years regardless of your erasure request.
• Right to restrict processing: You may request that won91 restrict the processing of your data in certain circumstances — for example, while a dispute about data accuracy is being resolved.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, machine-readable format and to have it transferred to another data controller where technically feasible.
• Right to object: You may object to processing carried out on the basis of legitimate interest, including profiling for fraud detection purposes. won91 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent (such as for marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

won91 implements a multi-layered security framework to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Our security measures include, but are not limited to:

• Transport Layer Security (TLS): All data in transit between your device and our servers is encrypted using 256-bit TLS encryption.
• Data-at-rest encryption: Sensitive data stored on our servers — including KYC documents and financial records — is encrypted using AES-256 or equivalent standards.
• Access controls: Personal data is accessible only to authorised won91 personnel and contracted service providers who require it for their specific role. Access is managed through role-based permissions and reviewed regularly.
• Two-factor authentication (2FA): Available and strongly recommended for all player accounts. Internal staff systems require 2FA as a mandatory control.
• Vulnerability management: Regular security assessments, penetration tests, and patch management processes are in place to identify and remediate technical vulnerabilities promptly.
• Incident response: won91 maintains a documented data breach response plan. In the event of a breach that poses a risk to your rights, we will notify affected players as required under applicable data protection law.

Despite these measures, no internet-based platform can guarantee absolute security. You are encouraged to use a strong, unique password for your won91 account, enable 2FA, and contact our support team immediately if you suspect any unauthorised activity.

If won91 becomes aware that personal data has been collected from a person under the age of 21 — whether through KYC review, a report from a third party, or any other means — that account will be immediately closed, all associated funds will be frozen pending investigation, and the data will be deleted to the extent not required for legal compliance purposes.

If you believe that a person under 21 has registered an account on won91, please contact us immediately at [email protected]. Parents and guardians are encouraged to use parental control software to restrict access to gambling websites where minors share devices. For more information on protecting younger family members, visit our Responsible Gaming page.

The won91 platform may contain references or navigational links to third-party websites or services — for example, links to responsible gaming organisations or banking partner sites. This Privacy Policy applies solely to data processed by won91. It does not extend to any third-party website you visit after leaving the won91 platform.

won91 has no control over, and accepts no responsibility for, the privacy practices, content, or data handling of any third-party website. We recommend that you review the privacy policy of any third-party site you visit before providing any personal information.

Where you have explicitly consented to receive marketing communications from won91, we may send you promotional emails, SMS messages, and in-platform notifications covering bonus offers, new game releases, sportsbook specials (including BRI Liga 1 match promotions, EPL accumulators, and Timnas Indonesia fixtures), and seasonal campaigns tied to Indonesian cultural events such as Idul Fitri, Ramadhan, and Indonesian Independence Day (17 August).

You may withdraw your consent to marketing communications at any time by:

• Clicking the "Unsubscribe" link included at the bottom of every marketing email we send.
• Updating your communication preferences within your Account settings panel.
• Contacting our support team at [email protected] with the subject line "Marketing Opt-Out".

Withdrawal of marketing consent will not affect your ability to use the platform or receive transactional communications (such as deposit confirmations, withdrawal notifications, and support responses). Opt-out requests are processed within 5 business days.

won91 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or platform features. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page.
• Send a notification to your registered email address at least 14 days before the changes take effect, summarising what has changed and why.
• Display a prominent in-platform notice for a period of at least 30 days after the change takes effect.

Your continued use of the won91 platform after any amendment takes effect constitutes your acknowledgment of the revised Privacy Policy. If you do not agree with the changes, you have the right to close your account and request deletion of your personal data (subject to legal retention obligations) by contacting support.

If you have any questions, concerns, or complaints about this Privacy Policy or the way in which won91 handles your personal data, please contact us through the following channels:

• Email: [email protected] — please use the subject line "Privacy Request" or "Privacy Complaint" as appropriate.
• Live Chat: Available 24 hours a day, 7 days a week, within your won91 Account dashboard. Indonesian-speaking agents are always on shift.
• Response time: We aim to acknowledge all privacy-related contacts within 24 hours and to provide a substantive response within 30 calendar days.