Privacy Policy

1. Introduction

1.1 wso138 ("we," "us," "our") is committed to protecting the privacy and personal data of every player who accesses our Platform at https://wso138.cam. This Privacy Policy describes how we collect, use, store, share, and safeguard personal information in connection with the Services we provide.

1.2 This Privacy Policy applies to all visitors, registered players, and former account holders of wso138. It covers data collected through the Platform, our customer support channels, and any related communications you initiate with us.

1.3 By registering an Account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue your use of the Platform and contact us to close your Account.

1.4 This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy. In the event of any conflict between this policy and those documents on a privacy matter, this Privacy Policy shall prevail.

2. Definitions

Throughout this Privacy Policy, the following terms carry the meanings defined below:

• "Personal Data" means any information that identifies or could reasonably identify a living individual, either directly (e.g., full name, national ID number) or in combination with other data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, or deletion.
• "Data Controller" means wso138, the entity that determines the purposes and means of Processing your Personal Data.
• "Data Processor" means any third-party service provider that Processes Personal Data on wso138's behalf under a data processing agreement.
• "KYC Data" means identity and address documentation submitted to satisfy Know Your Customer verification requirements, including government-issued ID, proof of address, and proof of payment method.
• "Cookies" means small text files placed on your device by the Platform for purposes of session management, analytics, and personalization.
• "Platform" means the wso138 website at https://wso138.cam and all associated services, games, and features.

3. Data We Collect

3.1 wso138 collects the following categories of Personal Data in connection with operating the Platform:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (to verify you are 21 years of age or older);
• Email address (primary communication channel);
• Mobile phone number (for verification and account security alerts);
• Residential address (city, province — Indonesia-based players typically in Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, Semarang, or Makassar).

3.2 Identity Verification (KYC) Data

• Scanned copy or photograph of a government-issued photo ID (national identity card, passport, or driver's license);
• Proof of residential address document (utility bill, bank statement issued within 90 days);
• Photograph or screenshot confirming ownership of the payment method used (e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, or LinkAja account statement).

3.3 Financial & Transaction Data

• Bank account numbers and e-wallet identifiers associated with deposits and withdrawals;
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method used;
• Account balance in Indonesian Rupiah (IDR / Rp);
• Source of funds information for high-value account holders.

3.4 Gaming & Behavioral Data

• Bet history, game session logs, wagering amounts, and game outcomes;
• Bonus claims, wagering progress, and promotional participation records;
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, session timer activations).

3.5 Technical & Device Data

• IP address (used for geolocation, fraud detection, and access logging);
• Device type, operating system, and browser version;
• Session timestamps, page views, and navigation paths;
• Cookie identifiers and analytics data (see Section 10).

3.6 Communications Data

• Records of all communications with our customer support team (live chat transcripts, email correspondence);
• Feedback, complaints, and dispute records;
• Marketing communication preferences (opt-in / opt-out records).

3.2 wso138 does not knowingly collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where health-related information is voluntarily disclosed in the context of a responsible gaming request (e.g., a player indicating a gambling-related health concern when requesting self-exclusion).

4. How We Collect Data

wso138 collects Personal Data through the following channels:

• Direct submission: Information you provide when registering an Account, completing KYC, contacting support, or filling in any Platform form;
• Automated collection: Technical and device data collected automatically when you access the Platform (via cookies, log files, and analytics tools — see Section 10);
• Payment providers: Confirmation data from payment processors and Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, LinkAja) to verify transactions;
• Third-party verification services: Identity and address verification data returned by licensed KYC/AML service providers acting as Data Processors;
• Game providers: Game session data supplied by studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft via their game APIs.

5. Purpose of Processing

The table below summarizes the primary purposes for which wso138 Processes your Personal Data:

6. Legal Basis for Processing

6.1 wso138 processes your Personal Data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions (e.g., account management, transaction processing, game delivery);
• Legal obligation: Processing required to comply with applicable anti-money laundering (AML), counter-terrorism financing (CTF), and licensing obligations imposed by our international gaming license;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our interests do not override your fundamental rights;
• Consent: Processing for optional marketing communications, where you have provided explicit opt-in consent. You may withdraw this consent at any time by contacting support or adjusting your Account notification settings.

7. Data Sharing & Third Parties

7.1 wso138 may share your Personal Data with the following categories of recipients:

• Payment service providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) solely to process authorized transactions;
• KYC/AML verification providers: Licensed third-party identity verification services acting as Data Processors under binding data processing agreements;
• Game content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive the minimum player session data required to deliver their games and calculate outcomes;
• Regulatory and law enforcement authorities: Where we are legally compelled to do so by our licensing regulator, a court order, or a lawful request from a financial intelligence unit;
• Fraud prevention networks: Anonymized or pseudonymized risk signals may be shared with industry fraud prevention consortia to protect all Platform users;
• Professional advisers: Lawyers, auditors, and accountants under strict confidentiality obligations.

7.2 All third-party Data Processors are contractually bound to process your Personal Data only on wso138's instructions, to implement appropriate security measures, and not to use your data for their own purposes.

7.3 In the event of a merger, acquisition, or sale of substantially all wso138 assets, Personal Data may be transferred to the acquiring entity as part of the transaction. Players would be notified by email at least 30 days in advance of any such transfer.

8. Data Retention

8.1 wso138 retains Personal Data for as long as necessary to fulfill the purposes described in Section 5, or as required by applicable law. Specific retention periods:

• Active accounts: All Personal Data retained for the duration of account activity;
• Closed accounts — voluntary closure: Identity, contact, and gaming data retained for 5 years post-closure to support any future disputes and comply with responsible gaming obligations;
• Closed accounts — fraud or breach: All data retained for 7 years to support potential legal proceedings;
• Financial transaction records: 7 years from the date of transaction (standard financial record-keeping requirement);
• KYC documents: 5 years post-account closure;
• Marketing consent records: Retained until consent is withdrawn, or 2 years from last interaction if no active consent refresh;
• Analytics and aggregated data: Anonymized and retained indefinitely for platform improvement.

8.2 After the applicable retention period expires, Personal Data is securely deleted or anonymized such that you can no longer be identified from it.

9. Data Security

9.1 Technical security measures in place include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and wso138 servers;
• AES-256 encryption at rest for all stored Personal Data, including KYC documents and financial records;
• Multi-factor authentication (MFA) available for all player accounts;
• Network firewalls and intrusion detection systems monitoring all server traffic 24/7;
• Regular penetration testing conducted by independent security firms;
• Access controls limiting employee access to Personal Data on a strict need-to-know basis, with all access logged and audited.

9.2 Organizational measures include mandatory security training for all staff handling Personal Data, confidentiality agreements with all employees and contractors, and incident response procedures for any suspected data breach.

9.3 In the unlikely event of a data breach that poses a risk to your rights, wso138 will notify you by email within 72 hours of becoming aware of the breach, in accordance with applicable data protection obligations.

10. Cookies & Tracking Technologies

10.1 The wso138 Platform uses cookies and similar tracking technologies for the following purposes:

• Essential cookies: Required for core platform functionality including session management, login state persistence, and secure transaction processing. These cookies cannot be disabled without breaking core features.
• Analytics cookies: Used to understand how players interact with the Platform (pages visited, time spent, navigation paths) to improve user experience. We use Google Analytics with IP anonymization enabled.
• Functional cookies: Remember your language preference, timezone (WIB default), and display settings to personalize your experience.
• Marketing cookies: Track campaign effectiveness and measure conversion from promotional channels (only set if you have consented to marketing communications).

10.2 You can control or delete cookies through your browser settings. Note that disabling essential cookies will prevent you from using certain core Platform features.

10.3 Most web browsers accept cookies by default. Consult your browser's help documentation to learn how to modify cookie settings. Popular browsers include Chrome, Firefox, Safari, and Edge.

11. Your Rights

11.1 Under applicable data protection principles, you hold the following rights in relation to your Personal Data:

• Right of access: You may request a copy of all Personal Data wso138 holds about you. We will provide this within 30 days in a commonly used electronic format.
• Right to rectification: You may request correction of any inaccurate or incomplete Personal Data. Some data (email address, mobile number) can be updated directly in your Account settings.
• Right to erasure: You may request deletion of your Personal Data where there is no overriding legal or contractual reason for us to retain it. Note that certain data must be retained to comply with AML and licensing obligations (see Section 8).
• Right to restriction of processing: You may request that we limit the Processing of your Personal Data in specific circumstances (e.g., while disputing data accuracy).
• Right to data portability: You may request that we transfer your Personal Data to another service provider in a structured, commonly used format where technically feasible.
• Right to object: You may object to Processing based on legitimate interests. For marketing communications, you may opt out at any time via the unsubscribe link in any email or by contacting support.
• Right to withdraw consent: Where Processing is based on consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior Processing.

11.2 To exercise any of these rights, contact our support team at [email protected] (plain text) or via live chat. We will respond within 30 days. You will need to verify your identity before we can process rights requests.

11.3 If you believe wso138 has not handled your Personal Data in accordance with this Privacy Policy, you have the right to lodge a complaint with the relevant data protection supervisory authority in the jurisdiction where wso138 holds its license.

12. Protection of Minors

12.1 All players are required to declare their date of birth during registration and verify their age through KYC submission. Any account found to belong to a person under 21 years of age will be immediately suspended, all funds forfeited, and the matter reported to the account holder's parent or guardian and relevant authorities.

12.2 If you are a parent or guardian and believe your child has provided Personal Data to wso138, contact us immediately at [email protected] so we can take corrective action.

13. Changes to This Privacy Policy

13.1 wso138 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. The "Last Updated" date at the top of this page will always reflect the most recent revision.

13.2 Material changes to this Privacy Policy will be communicated to all active account holders by email at least 14 days before the new policy takes effect. Continued use of the Platform after the effective date constitutes acceptance of the revised policy.

13.3 We encourage you to review this Privacy Policy periodically. You can access the current version at any time at https://wso138.cam/privacy-policy.

14. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or the Processing of your Personal Data, please contact wso138 through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Subject line for privacy inquiries: "Privacy Policy Question" or "Data Rights Request"
• Live Chat: Available 24/7 via the Platform's live chat widget, staffed by English- and Indonesian-speaking agents (WIB, UTC+7)
• Response Time: Privacy-related inquiries are treated as high priority and typically responded to within 24 hours. Data rights requests are processed within 30 days as required by applicable data protection law.

When contacting us regarding a data rights request (access, rectification, erasure, etc.), please provide your full name, registered email address, and Account username to help us verify your identity and locate your records efficiently.