ngawin Privacy Policy

1. Introduction

ngawin ("we", "us", "our") operates the online betting platform accessible at https://ngawin.cam (the "Platform"). As a platform that collects and processes personal information from users across Indonesia, we take our privacy obligations seriously. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data in connection with your use of the ngawin Platform and all associated services.

This policy applies to all users of ngawin, including registered members, visitors who browse the Platform without registering, and individuals who interact with our customer support team. By accessing or using the Platform, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. If you do not agree with any part of this policy, you must not use the ngawin Platform.

This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which form part of the overall agreement governing your use of ngawin.

2. Definitions

• "Personal Data" means any information that identifies or could reasonably identify a natural person, directly or indirectly, including name, email address, phone number, IP address, device identifiers, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, deletion, or any combination thereof.
• "Data Controller" means ngawin, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on ngawin's behalf, under ngawin's written instructions.
• "User", "you", or "your" refers to any individual who accesses or uses the ngawin Platform.
• "Cookies" means small text files placed on your device by a website to store information about your browsing preferences and session data.
• "KYC" means Know Your Customer — the identity verification process ngawin uses to confirm the identity, age, and residential address of registered users.

3. Personal Data We Collect

ngawin collects Personal Data across several categories, depending on your interaction with the Platform. The table below summarises the types of data we collect and the context in which they are gathered:

Data Category	Examples	When Collected
Identity Data	Full name, date of birth, KTP or passport number, photograph	Registration, KYC verification
Contact Data	Email address, phone number, residential address	Registration, support interactions
Financial Data	Bank account number (BCA, BRI, BNI, Mandiri, etc.), e-wallet ID (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history, deposit/withdrawal amounts in IDR	Deposit/withdrawal processing, KYC
Technical Data	IP address, device type, browser type and version, operating system, session timestamps	Automatic collection on Platform access
Usage Data	Pages visited, games played, betting history, click paths, session duration	Automatic collection during Platform use
Communications Data	Live chat transcripts, email correspondence, WhatsApp messages with support	When you contact our support team
Marketing Preferences	Promotion opt-in/opt-out status, bonus claim history, preferred game categories	Account settings, Platform interactions
Responsible Gaming Data	Self-exclusion records, deposit limit settings, loss limit configurations, cooling-off periods	When you activate responsible gaming tools

We do not collect or store full payment card numbers. All financial transactions are processed through secure, certified payment intermediaries. ngawin does not store raw payment card data on its servers.

4. How We Collect Your Data

4.1 Data You Provide Directly

The majority of Personal Data ngawin holds is information you provide to us directly — for example, when you register an Account, complete KYC verification, make a deposit or withdrawal request, claim a bonus, contact our support team, or update your Account settings. You are under no obligation to provide this data, but failure to do so may prevent you from accessing certain features or Services.

4.2 Data Collected Automatically

When you access and use the ngawin Platform, we automatically collect certain Technical Data and Usage Data through cookies, web beacons, server logs, and similar tracking technologies. This data helps us understand how users interact with the Platform, diagnose technical issues, prevent fraud, and improve the overall user experience.

4.3 Data from Third Parties

ngawin may receive Personal Data about you from third-party sources, including:

• Identity verification providers: We use third-party KYC and AML service providers to verify your identity, age, and address. These providers may supply us with confirmation of your identity or flag potential fraud risks.
• Payment processors: Our banking and e-wallet partners (including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, and LinkAja) may share transaction data with us for the purpose of processing and reconciling your deposits and withdrawals.
• Fraud prevention agencies: We may receive information from fraud prevention and credit reference agencies to protect both you and ngawin from unauthorized activity.
• Analytics providers: Third-party analytics platforms may supply us with aggregated or pseudonymized data about Platform usage patterns.

5. Purposes of Processing

ngawin processes your Personal Data for the following purposes:

• Account management: To create, maintain, verify, and manage your ngawin Account, including KYC identity verification.
• Service delivery: To provide the betting, gaming, and ancillary services you request, including processing bets, calculating winnings, and applying bonuses.
• Payment processing: To process deposits and withdrawals via your nominated Indonesian bank account or e-wallet, and to reconcile financial transactions.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, account compromise, collusion, and other prohibited practices on the Platform.
• Regulatory compliance: To comply with applicable AML, KYC, and other legal obligations, including responding to requests from regulatory or law enforcement authorities.
• Responsible gaming: To implement and enforce responsible gaming tools that you have activated (deposit limits, self-exclusion, cooling-off periods), and to monitor for signs of problematic gambling behaviour.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance via live chat, email, and WhatsApp.
• Marketing and communications: To send you promotional offers, bonuses, and platform updates — but only where you have opted in to receive marketing communications. You may opt out at any time via your Account settings.
• Platform improvement: To analyse usage patterns, conduct A/B testing, and improve the functionality, speed, and content of the ngawin Platform.
• Legal claims: To establish, exercise, or defend legal claims arising in connection with your use of the Platform.

6. Legal Basis for Processing

ngawin processes your Personal Data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between ngawin and you (the Terms & Conditions) — including account management, service delivery, and payment processing.
• Legal obligation: Processing required to comply with applicable law, regulation, or court order — including AML/KYC obligations and regulatory reporting.
• Legitimate interests: Processing necessary for ngawin's legitimate business interests — including fraud prevention, platform security, and Platform improvement — where those interests are not overridden by your privacy rights.
• Consent: Processing based on your explicit, freely given consent — primarily for direct marketing communications and certain non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

ngawin does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja) — solely for the purpose of processing your deposits and withdrawals in Indonesian Rupiah (IDR).
• KYC and identity verification providers: Third-party services used to verify your identity, age, and address as required by our KYC policy.
• Game studios and content providers: Third-party game studios (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Pocket Games Soft, and others) may receive limited session data for the purpose of delivering their games on the ngawin Platform.
• Technology and infrastructure providers: Cloud hosting, server management, cybersecurity, and analytics vendors who process data on ngawin's behalf under contractual data processing agreements.
• Fraud prevention and AML agencies: Agencies that help us detect and prevent fraud, money laundering, and other financial crime.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory directive, ngawin may disclose your Personal Data to the relevant authority.
• Professional advisors: Legal counsel, auditors, and other professional advisors who require access to your data in connection with the services they provide to ngawin, subject to strict confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of ngawin's business, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party recipients of your Personal Data are contractually required to process that data only for the specified purpose, to maintain appropriate technical and organisational security measures, and to comply with applicable data protection law.

8. Cookies & Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They allow the website to recognise your device on subsequent visits, remember your preferences, and collect information about how you use the site. ngawin uses cookies and similar tracking technologies (including web beacons, pixels, and local storage) on the Platform.

8.2 Types of Cookies We Use

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that keep you logged in, security tokens, and cookies that remember your language and currency preferences. These cannot be disabled without affecting core Platform functionality.
• Performance and analytics cookies: Used to collect information about how visitors use the Platform — which pages are visited most often, where users navigate from, and whether error messages are encountered. This data is used in aggregated, anonymised form to improve Platform performance.
• Functionality cookies: Allow the Platform to remember choices you make (such as your preferred deposit method or game category) to provide a more personalised experience.
• Targeting and marketing cookies: Used to track your browsing activity and serve you relevant promotions and content. These cookies are only placed with your explicit consent and can be managed via your browser settings or Account preferences.

8.3 Managing Cookies

You can control and manage cookies through your browser settings. Most modern browsers allow you to block or delete cookies, though doing so may affect the functionality of the ngawin Platform. Disabling strictly necessary cookies will prevent you from logging in or using core Platform features. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.

9. Data Retention

ngawin retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, to comply with our legal obligations, and to resolve any disputes or enforce our agreements. Specific retention periods include:

• Account data and KYC records: Retained for a minimum of 5 years from the date of account closure, in compliance with AML and financial recordkeeping requirements.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction, in accordance with financial regulation standards.
• Betting history: Retained for 2 years from the date of each bet, or longer if required for dispute resolution or regulatory purposes.
• Customer support communications: Retained for 2 years from the date of the most recent interaction.
• Marketing data: Retained until you withdraw consent for marketing communications, after which it is deleted or anonymised within 30 days.
• Self-exclusion records: Retained for the full duration of the self-exclusion period plus 5 years thereafter, to prevent re-registration during the exclusion window.

When Personal Data is no longer required, ngawin will securely delete or anonymise it in a manner that prevents reconstruction or re-identification.

10. Data Security

ngawin implements a comprehensive range of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption: All data transmitted between your device and the ngawin Platform is encrypted using industry-standard 256-bit SSL/TLS protocols.
• Encrypted data storage: Sensitive Personal Data stored on our servers is encrypted at rest using AES-256 encryption.
• Access controls: Access to Personal Data is restricted to ngawin employees and contractors who require it to perform their job functions, on a strict need-to-know basis. All staff with data access undergo regular security awareness training.
• Two-factor authentication (2FA): Available for all ngawin accounts to add an additional layer of protection to your login process.
• Fraud detection systems: Real-time automated monitoring systems continuously scan Platform activity for signs of fraud, account compromise, and suspicious transactions.
• Regular security audits: ngawin conducts periodic internal and third-party security audits and penetration tests to identify and remediate vulnerabilities.
• Incident response: In the event of a data breach that poses a risk to your rights, ngawin will notify affected users and relevant authorities without undue delay, in accordance with applicable law.

While ngawin takes all reasonable precautions to protect your data, no system connected to the internet is completely immune from security threats. You also have a responsibility to keep your Account credentials secure and to notify ngawin immediately if you suspect unauthorised access to your Account.

11. Your Privacy Rights

As a user of the ngawin Platform, you have the following rights regarding your Personal Data. To exercise any of these rights, please contact our Data Privacy team at [email protected] (plain text — not a clickable link). ngawin will respond to all valid requests within 30 days:

• Right of access: You have the right to request a copy of the Personal Data ngawin holds about you, along with information about how and why we process it.
• Right to rectification: You have the right to request that inaccurate or incomplete Personal Data be corrected or updated. You may update many of your Account details directly within your Account dashboard.
• Right to erasure ("right to be forgotten"): You may request that we delete your Personal Data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where we have no other legitimate basis for retaining it. Note that certain data must be retained to comply with our legal obligations (e.g., AML recordkeeping), which may limit the scope of erasure.
• Right to restriction of processing: You may request that we restrict the processing of your Personal Data in certain circumstances — for example, while you contest the accuracy of the data or pending resolution of an objection.
• Right to data portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing based on ngawin's legitimate interests, and to opt out of direct marketing communications at any time, without providing a reason.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

ngawin will not discriminate against you for exercising any of your privacy rights. Exercising these rights will not affect your ability to use the Platform, except in cases where the data in question is strictly necessary for the provision of our Services.

12. Minors & Age Restriction

The ngawin Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect, use, or store Personal Data from individuals under the age of 21. During the registration process, all users are required to confirm that they meet the minimum age requirement, and KYC verification is used to validate age claims.

If ngawin discovers that Personal Data has been collected from an individual under the age of 21, we will immediately delete that data, close the associated Account, and void any transactions or winnings associated with it. If you believe that a minor has registered on the ngawin Platform, please contact our support team immediately at [email protected].

13. International Data Transfers

ngawin's operations span multiple jurisdictions, and your Personal Data may be transferred to, stored in, or processed in countries outside Indonesia. Where such international transfers occur, ngawin takes appropriate safeguards to ensure that your data receives a level of protection equivalent to that which it would receive in Indonesia. These safeguards may include:

• Contractual clauses (standard data protection agreements) with the receiving entity;
• Transfer to countries that provide an adequate level of data protection as recognised by applicable frameworks;
• Binding corporate rules, where applicable to affiliated entities within the ngawin group.

By using the ngawin Platform, you acknowledge and consent to the transfer of your Personal Data to jurisdictions outside Indonesia where necessary for the operation of the Platform and delivery of our Services.

14. Changes to This Privacy Policy

ngawin reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will provide a prominent notice on the Platform and update the "Last Updated" date at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how we handle your data.

If the changes materially affect the way we process your Personal Data and require your consent, we will obtain that consent before the changes take effect. For non-material changes, your continued use of the Platform after the updated policy is posted will constitute your acceptance of the revised terms.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way ngawin handles your Personal Data, please contact our Data Privacy team through any of the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the ngawin Platform
• WhatsApp: +62 812 0000 9999 (08:00–24:00 WIB)

For responsible gaming concerns, including self-exclusion and deposit limit requests, please visit our Responsible Gaming page. For general platform rules and eligibility requirements, please refer to our Terms & Conditions.

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Document Version: 1.0  |  Effective Date: January 1, 2026  |  Jurisdiction: Internationally licensed platform serving Indonesian users. This Privacy Policy is published in English and constitutes the binding version of this document. The latest version is always available at https://ngawin.cam/privacy-policy.