Privacy Policy

1. Introduction

nw108 ("we", "us", "our", "the Company") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, store, and protect the personal data of users ("you", "your", "User") who access or use our gaming platform located at https://nw108.cam (the "Platform" or "Services"). This policy applies to all Indonesian residents and international users who register accounts, place bets, play games, or otherwise interact with nw108 Services.

By creating an account or using any part of our Services, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with any part of this policy, you must immediately cease using our Services and contact us to request account closure and data deletion. This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming policy, which together form the complete agreement governing your use of nw108 Services.

2. Data Controller and Contact Information

nw108 is the data controller responsible for the personal information we collect and process through our Platform. For any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, you may contact our Data Protection Officer:

• Email: [email protected] (Subject line: "Privacy Inquiry" or "Data Protection Request")
• Live Chat: Available 24/7 on the website (select "Privacy/Data Protection" as the inquiry category)
• Response Time: We aim to respond to all privacy-related inquiries within 72 hours, and to formal data subject requests within 30 days as required by applicable data protection regulations.

3. Information We Collect

3.1 Personal Information You Provide

When you register an account with nw108, we collect the following personal information directly from you:

• Account Registration Data: Full legal name, date of birth, gender, email address, phone number, residential address, and chosen username and password.
• Identity Verification Documents: For KYC (Know Your Customer) compliance, we collect copies of your Indonesian National ID (KTP / Kartu Tanda Penduduk), selfie photographs holding your ID, and optionally proof of address documents such as utility bills or bank statements.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account identifiers (phone numbers associated with OVO, DANA, GoPay, etc.), payment card information (if applicable), and transaction history including deposits, withdrawals, and bet settlements.
• Communication Data: Any information you provide when contacting our customer support team via live chat, email, or other communication channels, including the content of messages, attachments, and support ticket history.
• Survey and Feedback Data: Responses to voluntary surveys, feedback forms, or promotional questionnaires you choose to complete.

3.2 Information We Collect Automatically

When you access or use nw108 Services, we automatically collect certain technical and behavioral information:

• Device Information: IP address, device type and model, operating system and version, browser type and version, screen resolution, device identifiers (IMEI, MAC address, advertising ID), and mobile network information.
• Usage Data: Pages visited, features used, time spent on pages, clickstream data, search queries, bet history (sports, casino, slots, lottery), game play patterns, deposit and withdrawal activity, login timestamps, and session duration.
• Location Data: Approximate geographic location derived from IP address to verify Indonesian residency and comply with geo-restriction requirements. We do not collect precise GPS coordinates unless you explicitly grant location permissions on mobile devices.
• Cookies and Tracking Technologies: We use cookies, web beacons, pixel tags, and similar technologies to track user activity, remember preferences, analyze site performance, and deliver personalized content. See Section 10 for detailed information about our cookie practices.

3.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction confirmation data, payment method verification, and fraud screening results from bank partners and e-wallet providers operating in Indonesia.
• Identity Verification Services: Age verification, identity authentication, and sanction screening results from third-party KYC service providers.
• Game Providers: Gameplay data, bet outcomes, and bonus usage from third-party game suppliers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, and others whose games are offered on our Platform.
• Fraud Prevention Services: Device fingerprinting, risk scores, and fraud alerts from security partners that help us protect against account takeovers, payment fraud, and bonus abuse.

4. How We Use Your Information

nw108 uses your personal information for the following purposes, all of which are necessary to provide our Services or comply with legal obligations:

4.1 Service Provision and Account Management

• Create, maintain, and authenticate your user account
• Process your deposits and withdrawals securely
• Enable you to place bets and play games on our Platform
• Calculate and credit your winnings, bonuses, and cashback
• Maintain accurate account balances and transaction records
• Provide customer support and respond to your inquiries
• Send important service notifications, account updates, and transaction confirmations

4.2 Legal Compliance and Security

• Verify your identity and age (21+ requirement) to prevent underage gambling
• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Detect, prevent, and investigate fraud, cheating, collusion, and other prohibited activities
• Enforce our Terms & Conditions and investigate Terms violations
• Respond to legal requests, court orders, and regulatory inquiries
• Protect the security and integrity of our Platform and other users
• Maintain audit trails and comply with record-keeping requirements

4.3 Platform Improvement and Analytics

• Analyze usage patterns to improve Platform performance, features, and user experience
• Conduct A/B testing and product experiments to optimize functionality
• Monitor website traffic, conversion rates, and technical performance metrics
• Identify and fix bugs, errors, and technical issues
• Develop new games, features, and services based on user behavior insights

4.4 Marketing and Communications (With Your Consent)

• Send promotional emails about bonuses, tournaments, and new game launches
• Display personalized offers and recommendations based on your gaming preferences
• Deliver targeted advertisements on our Platform and partner websites (subject to your cookie preferences)
• Conduct player satisfaction surveys and request feedback
• Invite you to participate in VIP events, exclusive promotions, or loyalty programs

Note: You can opt out of marketing communications at any time by clicking the "unsubscribe" link in emails, adjusting your account preferences, or contacting customer support. Opting out of marketing does not affect essential service communications.

5. Legal Basis for Processing (GDPR and Indonesian Law)

Under applicable data protection laws including Indonesia's Personal Data Protection Law and the EU General Data Protection Regulation (GDPR) where applicable, we process your personal information based on the following legal grounds:

• Contractual Necessity: Processing necessary to perform our contract with you (our Terms & Conditions), including account creation, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with Indonesian and international laws, including KYC/AML regulations, age verification requirements, tax reporting, and regulatory audits.
• Legitimate Interest: Processing necessary for our legitimate business interests in fraud prevention, security, Platform improvement, analytics, and protecting the rights of nw108 and other users, provided such interests are not overridden by your fundamental rights.
• Consent: Processing based on your explicit consent, such as marketing communications, optional cookies, and data uses beyond what is strictly necessary for service provision. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. How We Share Your Information

nw108 does not sell, rent, or trade your personal information to third parties for their marketing purposes. We only share your information in the following limited circumstances:

6.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who assist us in operating the Platform and delivering Services, including:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP) and e-wallet providers (OVO, DANA, GoPay, ShopeePay) to process deposits and withdrawals.
• Game Providers: Third-party game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft, etc.) who power casino games, slots, and live dealer tables on our Platform.
• Identity Verification Services: KYC/AML service providers that verify your identity, age, and address using government databases and document authentication technology.
• Cloud Infrastructure Providers: Hosting companies that store and process data in secure data centers with ISO 27001 certification and other industry-standard security measures.
• Customer Support Tools: Live chat software providers, helpdesk platforms, and CRM systems used to deliver customer service.
• Analytics and Performance Monitoring: Website analytics platforms, error tracking tools, and performance monitoring services that help us optimize the Platform.
• Security and Fraud Prevention: Anti-fraud services, DDoS protection providers, and cybersecurity firms that protect against malicious activity.

All service providers are contractually required to protect your personal information, use it only for the specified purposes, and comply with applicable data protection laws. They are prohibited from selling or using your data for their own purposes.

6.2 Legal and Regulatory Obligations

We may disclose your personal information to government authorities, law enforcement agencies, regulators, courts, or other third parties when required or permitted by law, including:

• In response to valid legal process such as subpoenas, court orders, or regulatory requests
• To comply with Indonesian tax reporting requirements or anti-money laundering regulations
• To cooperate with law enforcement investigations of fraud, illegal gambling, or other criminal activity
• To protect the rights, property, or safety of nw108, our users, or the public
• To enforce our Terms & Conditions or investigate potential violations

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor company. We will notify you via email and/or prominent notice on the Platform before your information is transferred and becomes subject to a different privacy policy.

7. Data Security and Protection Measures

nw108 takes data security seriously and implements comprehensive technical, administrative, and physical safeguards to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

While we implement robust security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we continuously monitor and improve our security practices to protect your information to the best of our ability.

8. Data Retention

nw108 retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Our retention practices are as follows:

Upon account closure or at the end of the applicable retention period, we will securely delete or anonymize your personal information in accordance with our data retention and deletion procedures, except where we are legally required to retain records for longer periods (e.g., for tax, accounting, or regulatory purposes).

9. Your Privacy Rights

Under Indonesian data protection law and international privacy regulations, you have the following rights regarding your personal information:

9.1 Right to Access

You have the right to request a copy of the personal information we hold about you. We will provide this information in a commonly used electronic format within 30 days of your request.

9.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most account information directly through your account settings, or contact customer support for assistance.

9.3 Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal information in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or you withdraw consent. Please note that we may be legally required to retain certain information for compliance purposes even after you request deletion.

9.4 Right to Restrict Processing

You have the right to request that we limit how we use your personal information in certain situations, such as when you contest the accuracy of the data or object to processing.

9.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, machine-readable format and transmit it to another service provider.

9.6 Right to Object

You have the right to object to processing of your personal information based on legitimate interests or for direct marketing purposes. We will cease processing unless we have compelling legitimate grounds that override your interests.

9.7 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

9.8 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with "Data Subject Request" in the subject line, or use the live chat feature and select "Privacy/Data Rights" as your inquiry type. We will respond to your request within 30 days and may ask you to verify your identity before processing the request.

10. Cookies and Tracking Technologies

nw108 uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze Platform usage, and deliver personalized content. Cookies are small text files stored on your device when you visit our Platform. We use the following types of cookies:

• Strictly Necessary Cookies: Essential for Platform operation, security, and core functionality. These cannot be disabled without affecting how the Platform works (e.g., session authentication, security tokens, load balancing).
• Performance and Analytics Cookies: Help us understand how visitors use the Platform by collecting anonymous statistical data (e.g., pages visited, time on site, bounce rate). We use this information to improve performance and user experience.
• Functionality Cookies: Remember your preferences and settings (e.g., language preference, display settings, favorite games) to provide a personalized experience.
• Marketing and Advertising Cookies: Track your activity across websites to deliver targeted advertisements and measure campaign effectiveness. These cookies are only placed with your explicit consent.

You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies, though disabling certain cookies may affect Platform functionality. To opt out of marketing cookies, adjust your preferences in your account settings or use the cookie consent banner displayed on your first visit.

11. Children's Privacy

nw108 Services are strictly intended for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have collected personal information from a minor, we will take immediate steps to delete such information and close the associated account. If you believe a minor has registered an account with nw108, please contact us immediately at [email protected] so we can investigate and take appropriate action.

12. International Data Transfers

Your personal information may be transferred to, stored, and processed in countries outside of Indonesia where our servers, service providers, or business partners are located. These countries may have data protection laws that differ from Indonesian laws. When we transfer your data internationally, we ensure appropriate safeguards are in place to protect your information, including:

• Standard contractual clauses approved by regulatory authorities
• Data processing agreements requiring service providers to maintain equivalent security standards
• Adherence to international privacy frameworks and certifications (e.g., ISO 27001)

By using nw108 Services, you consent to the transfer of your personal information to countries outside Indonesia for the purposes described in this Privacy Policy.

13. Changes to This Privacy Policy

nw108 reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting the updated Privacy Policy on this page with a new "Last Updated" date
• Sending an email notification to your registered email address
• Displaying a prominent notice on the Platform homepage or via pop-up banner

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of nw108 Services after changes are posted constitutes acceptance of the updated Privacy Policy.

14. Contact Us About Privacy

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact us:

• Email: [email protected] (Subject: "Privacy Inquiry")
• Live Chat: 24/7 on the website (select "Privacy & Data Protection" category)
• Data Protection Officer: Available for formal privacy concerns and data subject requests

We are committed to resolving privacy concerns promptly and transparently. If you are not satisfied with our response, you have the right to lodge a complaint with the Indonesian data protection authority or your local supervisory authority where applicable.