Privacy Policy

1. Introduction

At tokwin ("we", "us", "our", or "the Platform"), we are committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, store, share, and protect the personal data you provide to us when you access or use our online betting and casino services at tokwin.cam, including all associated mobile applications and features (collectively, "the Service").

This Privacy Policy should be read in conjunction with our Terms and Conditions and Responsible Gaming Policy. By creating an account with tokwin or using our Service, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree with this Privacy Policy, you must not use our Service.

We take data protection seriously and comply with applicable international data protection laws and regulations. This includes implementing appropriate technical and organizational measures to ensure the security and confidentiality of your personal information. We are committed to transparency in our data handling practices, and this Privacy Policy sets forth in detail what information we collect, why we collect it, how we use it, and what rights you have regarding your personal data.

2. Information We Collect

To provide you with our betting and casino services, tokwin collects various types of personal information from and about you. The information we collect falls into several categories:

2.1 Information You Provide Directly

When you register an account with tokwin, you voluntarily provide us with the following information:

• Personal Identification Information: Your full legal name, date of birth, gender, and nationality as they appear on your government-issued identification documents.
• Contact Information: Your email address, mobile phone number (including country code), and residential address in Indonesia including city, province, and postal code.
• Account Credentials: Your chosen username, password, and security questions/answers used to access your tokwin account.
• Financial Information: Your bank account details (bank name, account number, account holder name), e-wallet information (OVO, DANA, GoPay account numbers), and transaction history including deposits, withdrawals, and bet placements.
• Identity Verification Documents: Copies of your Indonesian National Identity Card (KTP Nasional), proof of address documents (utility bills, bank statements), and selfie photographs holding your identification as part of our KYC (Know Your Customer) verification process.
• Communication Data: Any information you provide when you contact our customer support team via live chat, email, WhatsApp, or in-app messaging, including the content of your messages, attachments, and support ticket history.

2.2 Information We Collect Automatically

When you access or use tokwin's Service, we automatically collect certain information about your device and usage patterns:

• Device Information: Your device type (smartphone, tablet, desktop computer), operating system (Android, iOS, Windows, macOS), browser type and version, screen resolution, and device identifiers (IMEI, advertising ID where permitted).
• Connection Information: Your IP address, internet service provider, connection type (3G, 4G, 5G, WiFi), approximate geographic location derived from your IP address, and time zone settings.
• Usage Data: Information about how you interact with our Service, including pages visited, features used, time spent on each page, clickstream data, search queries within the platform, games played, bet types and amounts, win/loss records, session duration, frequency of visits, and referring/exit pages.
• Cookies and Tracking Technologies: We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your browsing behavior and preferences. See Section 8 for detailed information about our cookie practices.

2.3 Information from Third Parties

In certain circumstances, we may receive information about you from third-party sources:

• Payment Processors: When you make deposits or withdrawals, our payment processing partners (banks, e-wallet providers) may share transaction confirmation data, payment method verification, and fraud screening results with us.
• Identity Verification Services: We may use third-party identity verification services to validate the authenticity of the documents you provide during KYC verification and to screen for fraud, money laundering, or terrorist financing risks.
• Marketing Partners: If you arrive at tokwin through an affiliate link or marketing campaign, we may receive referral information and campaign tracking data from our marketing partners (but not your personal identification details unless you choose to provide them by registering).

3. How We Use Your Information

tokwin uses the personal information we collect for the following purposes:

3.1 To Provide and Maintain Our Service

• Create and manage your tokwin account
• Process your deposits, withdrawals, and betting transactions
• Verify your identity and age to comply with legal requirements and prevent underage gambling
• Authenticate your account access and protect against unauthorized use
• Enable you to participate in sports betting, casino games, lottery draws, and other gaming activities
• Calculate and credit winnings to your account balance
• Process and fulfill bonus claims, cashback, and promotional offers
• Provide customer support and respond to your inquiries, complaints, and feedback

3.2 To Comply with Legal Obligations

• Verify your eligibility to use our Service under Indonesian law and our license requirements (21+ age restriction, resident status)
• Conduct anti-money laundering (AML) and counter-terrorism financing (CTF) checks as required by international gambling regulations
• Maintain records of transactions and account activity for regulatory audits and compliance reporting
• Detect, prevent, and investigate fraud, cheating, collusion, bonus abuse, and other prohibited activities
• Respond to lawful requests from law enforcement, regulatory authorities, courts, or government agencies
• Enforce our Terms and Conditions and protect the rights, property, and safety of tokwin, our users, and the public

3.3 To Improve and Personalize Our Service

• Analyze usage patterns and player behavior to understand how our Service is used and identify areas for improvement
• Develop new features, games, and betting markets based on user preferences and demand
• Personalize your experience by recommending games, sports events, or promotions that may interest you based on your betting history
• Optimize our website and mobile applications for performance, speed, and usability across different devices and connection types
• Conduct research and statistical analysis to improve our odds, game selection, payment methods, and customer support quality

3.4 To Communicate with You

• Send transactional notifications about your account activity (deposit confirmations, withdrawal updates, bet settlements, bonus credits)
• Provide customer support responses via your chosen communication channel (live chat, email, WhatsApp)
• Send important account alerts regarding security, terms updates, or service changes
• Notify you about new promotions, bonuses, tournaments, and special offers that may be of interest (you can opt out of marketing communications at any time)
• Request feedback about your experience with tokwin through surveys or review requests

3.5 For Security and Fraud Prevention

• Monitor account activity for suspicious behavior, unauthorized access attempts, or security breaches
• Detect and prevent multiple account registrations, identity fraud, payment fraud, and bonus abuse
• Identify coordinated betting patterns, collusion, or cheating in casino games and sports betting
• Implement responsible gaming measures by monitoring betting patterns that may indicate problem gambling behavior
• Protect our systems and infrastructure from cyberattacks, malware, and unauthorized intrusion

4. How We Share Your Information

tokwin does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with selected third parties in the following circumstances:

4.1 Service Providers and Business Partners

We share your information with trusted third-party service providers who assist us in operating our platform and delivering our services:

• Payment Processors: Banks, e-wallet providers, and payment gateways that process your deposits and withdrawals. These providers receive your payment information solely for the purpose of completing transactions.
• Identity Verification Services: Third-party KYC verification providers that validate your identification documents and screen for fraud, money laundering, and terrorist financing risks.
• Game Providers: Casino game and live dealer studios (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, etc.) receive anonymized gameplay data to operate their games and ensure fairness, but they do not receive your personal identification details.
• Cloud Hosting and Data Storage: We use secure cloud infrastructure providers to host our platform and store your account data with bank-grade encryption.
• Customer Support Tools: We use third-party customer relationship management (CRM) and live chat software to manage support inquiries and maintain ticket history.
• Analytics and Monitoring: We use analytics services to understand usage patterns, identify technical issues, and improve our platform performance. These services receive anonymized or pseudonymized data.

All third-party service providers are contractually obligated to protect your information, use it only for the purposes we specify, and comply with applicable data protection laws. We conduct due diligence to ensure our partners maintain appropriate security standards.

4.2 Legal and Regulatory Authorities

We may disclose your information to law enforcement agencies, regulatory authorities, courts, or government bodies when:

• Required by law, regulation, legal process, or governmental request
• Necessary to comply with our gambling license obligations or regulatory reporting requirements
• Responding to valid subpoenas, court orders, or legal investigations
• Detecting, preventing, or addressing fraud, security breaches, or illegal activities
• Protecting the rights, property, or safety of tokwin, our users, or the public as required by law

4.3 Business Transfers

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

5. Data Security

tokwin employs industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL (Secure Socket Layer) technology, the same encryption standard used by banks and financial institutions worldwide.
• Secure Storage: Your personal data and identification documents are stored on encrypted servers in secure data centers with restricted physical access, fire suppression systems, and 24/7 monitoring.
• Access Controls: Access to your personal information is restricted to authorized tokwin employees and contractors who require access to perform their job functions. All personnel are bound by confidentiality obligations.
• Password Protection: Your account is protected by your password, which is stored in hashed and salted form and cannot be retrieved by tokwin staff. We encourage you to choose a strong, unique password and enable two-factor authentication.
• Regular Security Audits: We conduct regular security assessments, vulnerability testing, and penetration testing to identify and address potential weaknesses in our systems.
• Fraud Detection: We employ advanced fraud detection algorithms and monitoring systems to identify suspicious activity and protect against unauthorized transactions.

While we implement robust security measures, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorized access to your account.

6. Data Retention

tokwin retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with our legal and regulatory obligations:

• Active Accounts: While your account remains active, we retain all associated personal information, transaction history, and gameplay data to provide ongoing service and support.
• Closed Accounts: After you close your account, we retain certain information for up to seven years to comply with anti-money laundering regulations, tax reporting requirements, and our gambling license obligations. This includes your identification documents, transaction records, and account activity logs.
• Marketing Data: If you opt out of marketing communications, we retain your email address or phone number on a suppression list indefinitely to ensure we do not inadvertently contact you again.
• Legal Holds: If your account or transactions are subject to a legal investigation, dispute, or regulatory inquiry, we will retain all relevant information until the matter is resolved, even if this extends beyond our standard retention periods.

Once the retention period expires and there are no legal or regulatory reasons to retain your data, we will securely delete or anonymize your personal information so that it can no longer be associated with you.

7. Your Rights and Choices

You have certain rights regarding your personal information. tokwin is committed to facilitating the exercise of these rights:

7.1 Access and Portability

You have the right to access the personal information we hold about you. You can view much of this information directly in your tokwin account dashboard, including your profile details, transaction history, and bet history. If you require a comprehensive copy of all personal data we hold about you, you may submit a data access request to our Data Protection Officer at [email protected]. We will provide the requested information in a structured, commonly used, and machine-readable format within 30 days.

7.2 Correction and Update

You have the right to correct inaccurate or incomplete personal information. You can update your email address, phone number, and residential address directly in your account settings. If you need to update your name, date of birth, or other information verified during KYC, please contact customer support with supporting documentation. We will review and process your request within 5 business days.

7.3 Deletion and Account Closure

You have the right to request deletion of your personal information and closure of your tokwin account at any time by contacting customer support. Please note that we may need to retain certain information for up to seven years after account closure to comply with legal and regulatory obligations, as described in Section 6. Any remaining account balance will be returned to you via your verified payment method before account closure.

7.4 Marketing Opt-Out

You have the right to opt out of receiving marketing communications from tokwin at any time. You can unsubscribe from promotional emails by clicking the "unsubscribe" link at the bottom of any marketing email, or by adjusting your communication preferences in your account settings. Please note that even if you opt out of marketing communications, we will still send you essential transactional and account-related notifications.

7.5 Data Portability

You have the right to receive your personal data in a portable format and to transmit it to another service provider where technically feasible. We will provide your data in CSV, JSON, or PDF format upon request.

7.6 Complaints

If you believe that tokwin has mishandled your personal information or violated your data protection rights, you have the right to lodge a complaint with our Data Protection Officer at [email protected]. We will investigate your complaint and respond within 30 days. If you are not satisfied with our response, you may also have the right to lodge a complaint with the data protection authority in the jurisdiction where you reside.

8. Cookies and Tracking Technologies

tokwin uses cookies and similar tracking technologies to enhance your experience, analyze usage patterns, and personalize content. Cookies are small text files stored on your device when you visit our website. You can control cookie preferences through your browser settings, though disabling certain cookies may limit your ability to use some features of our Service. For detailed information about the specific cookies we use and how to manage them, please refer to our Cookie Policy.

9. Children's Privacy

tokwin's services are strictly prohibited for individuals under 21 years of age. We do not knowingly collect personal information from anyone under 21. If we discover that we have inadvertently collected information from someone under 21, we will immediately delete that information and close the associated account. If you are a parent or guardian and believe your child has provided personal information to tokwin, please contact us immediately at [email protected].

10. Changes to This Privacy Policy

tokwin reserves the right to update or modify 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 email to your registered email address and display a prominent notice on our platform. The "Last Updated" date at the top of this Privacy Policy will be revised to reflect the date of the most recent changes. Your continued use of tokwin's Service after such notification constitutes your acceptance of the updated Privacy Policy.

11. International Data Transfers

tokwin operates internationally and may transfer your personal information to countries outside of Indonesia for processing and storage. These countries may have data protection laws that differ from Indonesian laws. When we transfer your data internationally, we implement appropriate safeguards to ensure your information receives adequate protection, including using standard contractual clauses approved by data protection authorities and ensuring our service providers maintain appropriate security standards.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please contact us:

• Email: [email protected] (Data Protection Officer)
• Subject Line: "Privacy Policy Inquiry" or "Data Protection Request"
• Live Chat: Available 24/7 via your account dashboard

We aim to respond to all privacy-related inquiries within 30 days. For urgent security concerns, please use live chat for immediate assistance.