Privacy Policy — wd138

1 Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

2 Who We Are

wd138 operates an international online betting and casino platform accessible at https://wd138.cam. Our primary service audience consists of English-preference Indonesian players who access the Platform for sports betting (including football markets covering BRI Liga 1, EPL, Champions League, and Timnas Indonesia matches), live casino games, togel (Indonesia's traditional numbers lottery), and slot titles from certified international game studios.

wd138 is the data controller in respect of Personal Data collected through the Platform. If you have any questions or concerns about how wd138 handles your personal information, you may contact our Data Protection team using the details set out in Section 17 of this Policy.

3 Personal Data We Collect

wd138 collects the following categories of personal data in the course of operating the Platform and fulfilling its contractual and regulatory obligations:

4 How We Collect Your Data

wd138 collects Personal Data through the following methods:

• Direct submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically through cookies, server logs, and similar tracking technologies when you access or use the Platform. See Section 8 for details on cookies.
• Payment processors: Financial data may be supplemented by information received from our payment processing partners (banks and e-wallet providers) in the course of transaction verification.
• Identity verification providers: During KYC verification, wd138 may use third-party identity verification services to cross-reference the information you submit against official records. These providers operate under strict data-processing agreements with wd138.
• Fraud prevention databases: wd138 may check member data against industry-shared fraud prevention databases to protect the Platform and its members from fraudulent activity.

5 Purpose of Processing

wd138 processes your Personal Data for the following purposes:

1. Account registration and management: To create, verify, and administer your wd138 member account, including identity verification and KYC compliance.
2. Transaction processing: To process deposits and withdrawals via Indonesian bank channels (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja).
3. Service delivery: To provide access to betting markets, casino games, togel (lottery), and all other Platform features as contracted.
4. Customer support: To respond to your support requests, resolve disputes, and maintain records of communications for quality assurance.
5. Regulatory compliance: To comply with applicable anti-money laundering (AML) obligations, KYC requirements, age verification (21+ minimum for all members), and other legal or regulatory requirements applicable to wd138's operations.
6. Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account manipulation, and unauthorized access to the Platform.
7. Responsible gaming: To administer responsible gaming tools including deposit limits, loss limits, session time limits, self-exclusion, and reality-check features, and to monitor for indicators of problem gambling behavior.
8. Platform improvement: To analyze aggregate usage patterns (non-personally identifiable) to improve Platform performance, user experience, and feature development.
9. Marketing communications: To send promotional materials, bonus notifications, and seasonal offers (e.g., Idul Fitri promotions, Indonesian Independence Day campaigns) to members who have opted in to receive them. See Section 14 for opt-out rights.

6 Legal Basis for Processing

wd138 processes your Personal Data on the following legal grounds:

• Contractual necessity: Processing is necessary to perform the contract entered into when you register as a wd138 member — including account administration, transaction processing, and service delivery.
• Legal obligation: Processing is necessary to comply with applicable legal obligations, including AML, KYC, and age verification requirements.
• Legitimate interests: Processing is necessary for wd138's legitimate interests in operating a secure, fair platform — including fraud prevention, security monitoring, and aggregate analytics for service improvement — provided those interests are not overridden by your privacy rights.
• Consent: For marketing communications, wd138 processes your contact data only where you have given clear, informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7 Data Sharing and Disclosure

wd138 does not sell, rent, or trade your Personal Data to third parties for commercial purposes. Your data may be shared only in the following limited circumstances:

• Service providers: Verified third-party providers who assist wd138 in operating the Platform, including payment processors (Indonesian banks and e-wallet providers), identity verification services, fraud prevention providers, cloud infrastructure providers, and customer support tool vendors. All such providers are bound by contractual data-protection obligations and may not use your data for any purpose beyond the specific service they provide to wd138.
• Game studios: Where necessary for the delivery of specific games (e.g., Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft), limited session-level data (e.g., player identifier, stake amount, game result) may be shared with the relevant studio's systems to enable gameplay and resolve disputes.
• Legal authorities: wd138 may disclose Personal Data to law enforcement, regulatory bodies, or other competent authorities where required to do so by law, court order, or applicable regulation, or where necessary to protect the legal rights of wd138 or its members.
• Business transfers: In the event of a merger, acquisition, or sale of assets involving wd138, Personal Data held at that time may be transferred to the relevant successor entity, subject to equivalent privacy protections.
• With your consent: wd138 may share your data with additional parties where you have given explicit, informed consent for that specific sharing purpose.

8 Cookies and Tracking Technologies

wd138 uses cookies and similar technologies (including session tokens and local browser storage) to enable the Platform to function correctly, maintain the security of your account session, and understand how members use the Platform in aggregate.

The categories of cookies used by wd138 are as follows:

• Strictly necessary cookies: Required for the Platform to operate. These include session authentication cookies that keep you logged in as you navigate between pages. These cookies cannot be disabled without preventing use of the Platform.
• Functional cookies: Used to remember your preferences (e.g., preferred language display, time zone defaulting to WIB — Western Indonesia Time, UTC+7). Disabling these may reduce the quality of your experience but will not prevent basic Platform use.
• Analytics cookies: Used to collect aggregate, anonymized data about how members navigate and use the Platform. This data is used internally to identify areas for improvement. wd138 does not share analytics data with third-party advertising networks.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from using your account.

9 Data Retention

wd138 retains your Personal Data for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by applicable law or regulation. In general:

• Active account data: Retained for the duration of your membership and for a period of five (5) years following account closure, in order to comply with AML, tax, and record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years following the date of the relevant transaction, consistent with financial record-keeping requirements.
• KYC documentation: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Support communications: Retained for two (2) years following the resolution of the relevant support interaction, unless retained longer for dispute resolution or legal purposes.
• Marketing consent records: Retained for the duration of the consent and for one (1) year following withdrawal of consent, as evidence of the consent lifecycle.

Data that is no longer required for any legitimate retention purpose is securely deleted or irreversibly anonymized.

10 Data Security

wd138 implements a range of technical and organizational security measures to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and wd138's servers.
• Encrypted storage of sensitive data fields (including passwords, stored using strong one-way hashing algorithms, and financial identifiers) at rest.
• Access controls ensuring that wd138 staff access Personal Data only on a strict need-to-know basis, with role-based access permissions and audit logging.
• Two-factor authentication (2FA) available to all members to secure account login.
• Penetration testing and regular security audits of the Platform infrastructure.
• Incident response procedures for detecting and responding to potential data breaches, including notification obligations where applicable.

While wd138 takes all reasonable steps to protect your data, no system can guarantee absolute security. We encourage you to use a strong, unique password for your wd138 account and to enable 2FA where available.

11 Your Data Rights

Subject to applicable law, you have the following rights in respect of your Personal Data held by wd138:

• Right of access: You may request a copy of the Personal Data wd138 holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete Personal Data. Members can update most account information directly from their account settings page.
• Right to erasure: You may request deletion of your Personal Data, subject to wd138's legal retention obligations (see Section 9). Mandatory retention periods may prevent complete erasure of certain records.
• Right to restriction: You may request that wd138 restricts processing of your data in certain circumstances — for example, while a dispute regarding data accuracy is being resolved.
• Right to data portability: You may request a copy of Personal Data you have provided to wd138 in a commonly used, machine-readable format.
• Right to object: You may object to processing based on legitimate interests, including profiling for responsible gaming monitoring, where your particular circumstances justify an objection.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our Data Protection team as described in Section 17. wd138 will respond to valid requests within thirty (30) days and may request identity verification before processing a request.

12 International Data Transfers

wd138 operates an internationally distributed platform. Certain elements of the Platform's infrastructure, including cloud hosting, game delivery networks, and analytics systems, may involve the processing of Personal Data outside of Indonesia.

Where Personal Data is transferred internationally, wd138 ensures that appropriate safeguards are in place to protect your data to an equivalent standard — including contractual data-protection clauses with receiving entities and, where applicable, data-processing agreements incorporating internationally recognized data transfer standards.

13 Children's Privacy and Age Restriction

All registration attempts are subject to mandatory age verification as part of the KYC process. Any account found to belong to an individual under 21 years of age will be immediately suspended, funds will be returned to the relevant payment source where legally and technically possible, and the account will be permanently closed.

If you believe that wd138 has inadvertently collected data from a minor, please contact us immediately at the address in Section 17 so that we may take prompt remedial action.

14 Marketing Communications

With your explicit consent, wd138 may contact you by email or WhatsApp with information about promotions, bonuses, seasonal campaigns (such as Idul Fitri offers, Imlek bonuses, and Indonesian Independence Day promotions), and new Platform features.

You may opt out of marketing communications at any time by contacting our support team via live chat or email (see Section 17). Opting out of marketing will not affect your ability to access and use your wd138 account, and you will continue to receive transactional communications necessary for the operation of your account (e.g., deposit confirmations, withdrawal notifications, security alerts).

15 Third-Party Links and Services

The wd138 Platform integrates games and content from third-party providers (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft). While these providers operate under data-processing agreements with wd138, they maintain their own privacy policies governing any data processed directly within their game environments.

wd138 is not responsible for the privacy practices of third-party providers or any external websites that are not operated by wd138. We encourage you to review the privacy policies of any third-party services you interact with.

16 Updates to This Privacy Policy

wd138 reserves the right to update or amend this Privacy Policy at any time. When changes are made, the revised Policy will be published on this page with an updated "Last Updated" date at the top of the document.

Where changes are material — meaning they significantly affect your rights or the way wd138 processes your Personal Data — wd138 will notify active members via their registered email address or via a notification displayed upon next login, providing a reasonable period to review the changes before they take effect.

Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of those changes. If you do not agree with a material change, you may close your account by contacting our support team.

17 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or wd138's handling of your Personal Data, please contact our Data Protection team through any of the following channels:

wd138 is committed to resolving privacy-related concerns promptly and transparently. All requests made under Section 11 (Your Data Rights) will receive a substantive written response within thirty (30) days of receipt.