Privacy Policy — boswin

1 Definitions

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly — including name, email address, national identity number, IP address, device identifiers, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" means boswin, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of boswin under a contractual data-processing agreement.
• "KYC" means Know Your Customer — identity verification carried out to confirm a Member's identity and comply with anti-money laundering obligations.
• "Cookies" means small text files stored on your device by the boswin website to support functionality, session management, and analytics.
• "WIB" means Western Indonesia Time (UTC+7), the primary reference time zone for all processing timestamps.

2 Scope & Application

This Policy applies to all Personal Data processed by boswin in connection with the operation of its online betting platform, including data collected from:

• Members who register and maintain an active account on boswin.
• Prospective members who begin but do not complete the registration process.
• Visitors who access the boswin website without registering.
• Members located anywhere across the Indonesian archipelago — including Jakarta, Surabaya, Medan, Bandung, Yogyakarta, Semarang, Bali, Makassar, Palembang, and all other provinces.

This Policy does not apply to the privacy practices of third-party game providers, payment processors, or other external services accessed through links or integrations on the Platform. Each such third party governs its own data practices independently.

3 Data We Collect

3.1 Registration Data

When you create a boswin account, we collect the following information:

• Full legal name (as it appears on your government-issued identity document).
• Date of birth (to verify that you are 21 years of age or older).
• Residential address (including province and postal code within Indonesia).
• Email address and mobile telephone number.
• Chosen username and encrypted password (passwords are never stored in plain text).

3.2 KYC Verification Data

To comply with anti-money laundering (AML) obligations and to process withdrawals, we collect:

• A copy of your Indonesian National Identity Card (KTP — Kartu Tanda Penduduk).
• A selfie photograph taken while holding your KTP alongside your boswin username and the current date.
• Bank account details (account name, account number, and bank name — e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga) or e-wallet details (OVO, DANA, GoPay, ShopeePay, LinkAja) for payment verification purposes.

3.3 Transaction Data

All financial transactions processed through your boswin account are recorded, including deposit amounts, withdrawal requests, wager values, game outcomes, bonus credits and deductions, and account balance history. All amounts are denominated in Indonesian Rupiah (IDR / Rp).

3.4 Technical and Device Data

When you access the Platform, we automatically collect certain technical data, including your IP address, browser type and version, operating system, device type and identifier, referring URL, session start and end timestamps (in WIB), and pages visited within the Platform.

3.5 Communications Data

Records of all communications between you and boswin — including live chat transcripts, email correspondence, and support ticket history — are retained for quality assurance, compliance, and dispute resolution purposes.

3.6 Behavioral and Gameplay Data

We record your wagering patterns, game preferences, session frequency, and responsible gaming tool usage (e.g., deposit limit settings, cooling-off activations). This data is used to personalize your experience, monitor for problem gambling indicators, and detect fraudulent behavior.

4 How Data Is Collected

boswin collects Personal Data through the following channels:

5 Purposes of Processing

boswin processes your Personal Data for the following clearly defined purposes:

• Account Management: Creating, maintaining, and administering your Member account, including password resets and account security.
• Transaction Processing: Facilitating deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Identity Verification (KYC): Confirming your identity, age (21+), and payment method ownership to comply with AML and responsible gaming obligations.
• Platform Personalization: Adapting game recommendations, promotional offers, and interface language to your demonstrated preferences and account activity.
• Responsible Gaming Monitoring: Identifying early indicators of problem gambling behavior, enforcing deposit limits and self-exclusion requests, and proactively offering support resources.
• Fraud Prevention and Security: Detecting and preventing fraudulent activity, account takeover attempts, money laundering, and Terms violations.
• Customer Support: Responding to enquiries, resolving disputes, and maintaining records of communications for quality assurance.
• Legal Compliance: Meeting obligations under applicable international gaming regulations, financial reporting requirements, and responding to lawful requests from competent authorities.
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve site performance, game selection, and user experience features.
• Marketing Communications: Sending promotional offers, bonus notifications, and seasonal campaign messages — only where you have opted in to receive such communications and subject to your right to unsubscribe at any time.

boswin will not process your Personal Data for any purpose that is incompatible with those listed above without first obtaining your explicit consent or establishing a separate, valid legal basis for doing so.

6 Legal Basis for Processing

boswin relies on the following legal bases when processing your Personal Data:

7 Data Sharing & Disclosure

7.1 Authorized Third-Party Processors

boswin shares Personal Data with carefully vetted third-party service providers who act as Data Processors under written data-processing agreements. These include:

• Payment processors and banking partners (BCA, BRI, BNI, Mandiri, and e-wallet operators OVO, DANA, GoPay, ShopeePay, LinkAja) — to facilitate deposits and withdrawals.
• Game content providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Ezugi, Pocket Games Soft) — who receive anonymized session identifiers necessary to deliver game content and settle game outcomes.
• Identity verification services — third-party KYC platforms used to authenticate document authenticity.
• IT infrastructure and hosting providers — cloud server operators who store encrypted data under strict security agreements.
• Customer support technology providers — live chat platform operators who process communication transcripts on our behalf.

All Data Processors are contractually prohibited from using your Personal Data for any purpose beyond the specific service they provide to boswin.

7.2 Legal and Regulatory Disclosure

boswin may disclose Personal Data to law enforcement agencies, regulatory authorities, financial intelligence units, or courts of competent jurisdiction where we are legally required to do so, or where disclosure is necessary to protect the rights, property, or safety of boswin, its members, or the general public. Such disclosures are made only to the extent required and are logged internally.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of boswin's business, Personal Data held by boswin may be transferred to the acquiring entity as part of that transaction. Members will be notified of any such transfer via Platform announcement or email with a minimum of thirty (30) calendar days' notice before the transfer takes effect.

7.4 No Sale of Personal Data

boswin does not sell, rent, barter, or otherwise commercially transfer your Personal Data to any third party for their own marketing or commercial purposes. This is an absolute commitment, not subject to exceptions.

8 International Data Transfers

boswin operates servers in multiple international locations. As a result, your Personal Data may be transferred to and stored in countries outside Indonesia. Where such transfers occur, boswin ensures that adequate safeguards are in place, including:

• Contractual data-processing agreements incorporating internationally recognized standard contractual clauses.
• Transfer only to jurisdictions that maintain data protection standards equivalent to or exceeding those applicable to boswin's primary licensing jurisdiction.
• Encryption of data in transit and at rest, regardless of the destination country.

By using the boswin Platform, you acknowledge that your data may be processed in jurisdictions outside Indonesia and consent to such transfers under the safeguards described above.

9 Data Retention

boswin retains Personal Data for the following periods:

Upon expiry of the applicable retention period, Personal Data is securely and irreversibly deleted or anonymized so that it can no longer be attributed to any identifiable individual. Anonymized, aggregated data may be retained indefinitely for statistical analysis.

10 Security Measures

boswin implements a layered security architecture to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. Our technical and organizational measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and boswin servers.
• AES-256 encryption at rest for all sensitive data fields, including identity document copies and financial records.
• Bcrypt password hashing — your account password is never stored in plain text under any circumstances.
• Role-based access controls limiting employee access to Personal Data strictly to those whose job function requires it.
• Regular penetration testing conducted by independent security auditors on a minimum quarterly schedule.
• 24/7 intrusion detection and monitoring by our infrastructure security team across all WIB, WITA, and WIT time zones.
• Multi-factor authentication requirements for all internal systems that process member Personal Data.

Despite these measures, no internet-based service can guarantee absolute security. If you have reason to believe your boswin account has been compromised, please contact our support team immediately via live chat.

11 Cookies & Tracking Technologies

11.1 What We Use

The boswin Platform uses cookies and similar tracking technologies (including local storage and session storage) to support core platform functionality and improve your experience. We use three categories of cookies:

• Essential Cookies: Required for the Platform to function. These include session authentication tokens, security cookies, and load-balancing identifiers. These cannot be disabled without breaking core functionality.
• Functional Cookies: Remember your preferences — such as display settings and notification preferences — to personalize your session.
• Analytics Cookies: Collect anonymized, aggregated data about how members navigate the Platform, which pages are visited most, and where errors occur. This data is used solely for internal improvement and is never linked to individual member identities.

11.2 What We Do Not Use

boswin does not use third-party advertising cookies, cross-site behavioral tracking pixels, or social media tracking scripts. We do not share cookie data with advertising networks or data brokers.

11.3 Managing Cookies

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling essential cookies will prevent you from logging in or using core Platform features. Instructions for managing cookies in popular browsers are available through each browser's official help documentation.

12 Your Rights

As a member of the boswin Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request — [Your Username]":

• Right of Access: Request a copy of the Personal Data boswin holds about you, including the categories of data, the purposes for which it is processed, and the third parties with whom it has been shared.
• Right to Rectification: Request correction of any inaccurate or incomplete Personal Data held in your account. Minor corrections (e.g., email address updates) can be made directly in your account settings.
• Right to Erasure ("Right to Be Forgotten"): Request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to boswin's legal retention obligations. Note that financial and KYC records must be retained for regulatory periods even after account closure.
• Right to Restrict Processing: Request that boswin restrict active processing of your data while a dispute or rectification request is pending.
• Right to Data Portability: Request a machine-readable copy of the Personal Data you have provided to boswin in a commonly used format (CSV or JSON).
• Right to Object: Object to processing based on legitimate interests, including direct marketing communications. Marketing objections take effect within 5 business days.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing emails), withdraw that consent at any time without affecting the lawfulness of prior processing.

boswin will respond to all data rights requests within thirty (30) calendar days. Complex requests may be extended by a further thirty (30) days with written notification to you. There is no charge for exercising your rights unless requests are manifestly unfounded or excessive.

13 Minors

The boswin Platform is strictly intended for adults aged 21 years and older. boswin does not knowingly collect, store, or process Personal Data belonging to individuals under the age of 21. If boswin becomes aware that an account has been registered by a person under 21, that account will be immediately suspended, all associated data will be deleted within 30 days, and any deposited funds will be returned to the originating payment method where technically feasible.

If you are a parent or guardian and believe a minor has registered on the boswin Platform, please contact us immediately at [email protected] so that we can take prompt remedial action.

14 Third-Party Services

The boswin Platform integrates with third-party game providers (including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Ezugi) and payment infrastructure providers. When you interact with a game or initiate a payment, certain data is transmitted to these providers to fulfil the service. Each provider operates under its own privacy policy and data-processing practices, which boswin cannot control beyond the contractual requirements imposed through our Data Processing Agreements.

boswin is not responsible for the privacy practices of any third-party service accessible through or integrated into the Platform. We recommend reviewing the privacy documentation of any provider whose services you use directly.

15 Policy Amendments

boswin reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or operational requirements. When material changes are made, we will:

• Post a prominent notice on the Platform homepage for a minimum of fourteen (14) calendar days.
• Send an email notification to all registered members at their account email address.
• Update the "Effective Date" displayed at the top of this Policy.

Your continued use of the boswin Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any amendment, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

16 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data, please contact the boswin data team through any of the following channels:

• Live Chat: Available 24/7 directly from the Platform — recommended for urgent data security concerns.
• Email: [email protected] (plain text — not a clickable link). Use the subject line "Privacy Enquiry" or "Data Rights Request" for faster routing. Response time: under 30 minutes during WIB hours.

Formal data rights requests (access, erasure, portability) must be submitted in writing to the email address above and will be actioned within thirty (30) calendar days of receipt.