Privacy Policy

1. Introduction

This Privacy Policy applies to all personal data collected and processed by kiw69 (accessible at https://kiw69.cam) in connection with the provision of online gaming services, including sports betting, live casino games, togel lottery, and slot games to users in Indonesia and other permitted jurisdictions.

kiw69 respects your privacy and is committed to processing your personal data in accordance with applicable data protection laws and industry best practices. We collect only the data necessary to provide our services, comply with legal obligations, and protect the integrity of the platform.

This policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy, which together govern your use of the kiw69 platform.

2. Data Controller

For the purposes of applicable data protection legislation, kiw69 is the data controller responsible for the collection, use, and protection of your personal data. Questions, concerns, or requests regarding your personal data should be directed to our Data Protection Officer at the contact details provided in Section 15 of this policy.

3. Data We Collect

kiw69 collects the following categories of personal data from users of the platform:

3.1 Registration Data

• Account Information: Username, email address, password (stored in encrypted form), date of birth, country of residence, preferred language
• Contact Details: Phone number (optional for account recovery), residential address (required for KYC verification)

3.2 Identity Verification (KYC) Data

• Government-Issued ID: Indonesian National Identity Card (KTP), passport, or driver's license number and scanned copy
• Proof of Address: Utility bill, bank statement, or government correspondence dated within 90 days
• Facial Verification: Selfie photograph or live video verification (where required by risk assessment)
• Source of Funds Declaration: Information regarding employment, income sources, or financial capacity (where required by anti-money laundering regulations)

3.3 Financial Data

• Payment Information: Bank account number, bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon), account holder name
• Transaction History: Deposit amounts, withdrawal amounts, timestamps, payment method used, transaction reference numbers
• Balance Records: Current account balance, bonus balance, historical balance changes

3.4 Gameplay and Betting Data

• Betting Activity: Sports bets placed (teams, odds, stake amounts), casino game sessions (game name, bet size, win/loss outcome), togel lottery selections and results
• Account Activity Logs: Login timestamps, IP addresses, device identifiers, session duration, pages viewed
• Bonus and Promotion Activity: Bonuses claimed, wagering progress, bonus terms acceptance timestamps

3.5 Communications Data

• Customer Support Interactions: Live chat transcripts, email correspondence, support ticket history
• Marketing Preferences: Consent status for promotional emails, SMS notifications, and push notifications

3.6 Technical Data

• Device Information: Operating system, browser type and version, screen resolution, device model
• Network Data: IP address, internet service provider, geolocation (country and city level only, based on IP)
• Cookies and Tracking Technologies: Session cookies, preference cookies, analytics cookies (see Section 10 for details)

4. How We Use Your Data

kiw69 processes your personal data for the following purposes:

5. Legal Basis for Processing

kiw69 processes your personal data under the following legal bases, as applicable under data protection laws:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide gaming services, process transactions, and maintain your account).
• Legal Obligation: Processing is required to comply with applicable laws, including anti-money laundering regulations, age verification requirements, tax reporting obligations, and regulatory oversight.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, internal analytics, and debt collection, provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where required by law, we obtain your explicit consent before processing data for direct marketing purposes or using non-essential cookies.

6. Data Sharing and Disclosure

kiw69 does not sell your personal data to third parties for marketing purposes. We may share your data with the following categories of recipients under strict data processing agreements:

• Payment Processors: Banks and financial institutions in Indonesia (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) receive the minimum data necessary to process deposits and withdrawals on your behalf.
• Identity Verification Providers: Third-party KYC service providers receive your identity documents and personal details solely for the purpose of verifying your identity and age.
• Game Providers: Slot game developers, live casino platform providers, and sports betting data suppliers receive anonymized or pseudonymized gameplay data required to deliver game content and settle bets.
• Customer Support Tools: Live chat software providers and email service platforms process communications data to enable customer service delivery.
• Analytics Services: We use third-party analytics platforms (configured to anonymize IP addresses and respect user privacy settings) to understand platform usage and improve user experience.
• Legal and Regulatory Authorities: We may disclose personal data to government agencies, law enforcement, tax authorities, or regulatory bodies where required by law, court order, or regulatory investigation.
• Professional Advisors: Lawyers, accountants, auditors, and consultants may access data on a need-to-know basis under confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

All third-party service providers are contractually bound to process your data only for specified purposes, maintain appropriate security measures, and comply with applicable data protection laws. kiw69 conducts due diligence on all data processors before engagement.

7. Data Retention

kiw69 retains your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy and to comply with legal obligations. Specific retention periods are as follows:

• Account Data: Retained for the duration of your active account plus 7 years following account closure (to comply with financial audit and tax reporting obligations).
• Transaction Records: Retained for 7 years from the date of transaction (as required by anti-money laundering and financial regulations).
• KYC Documents: Retained for 7 years following account closure or last transaction (whichever is later), in accordance with regulatory requirements.
• Communications Records: Customer support transcripts retained for 3 years; marketing communications preferences retained until you withdraw consent.
• Cookies and Technical Data: Session cookies deleted when you close your browser; analytics cookies retained for up to 2 years (or as specified in cookie settings).

At the end of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be associated with you as an individual. Anonymized data may be retained indefinitely for statistical and research purposes.

8. Security Measures

kiw69 employs industry-standard technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS/SSL protocols. Passwords are hashed using strong cryptographic algorithms and are never stored in plain text.
• Access Controls: Personal data is accessible only to authorized kiw69 employees and contractors who require access to perform their job functions. All personnel are bound by confidentiality obligations.
• Firewalls and Intrusion Detection: Our servers are protected by enterprise-grade firewalls and intrusion detection systems that monitor for suspicious activity 24/7.
• Regular Security Audits: kiw69 conducts periodic security assessments and penetration testing by independent third-party security firms to identify and remediate vulnerabilities.
• Data Segregation: Financial records and sensitive KYC documents are stored in segregated, access-restricted databases with enhanced security controls.
• Incident Response Plan: In the event of a data breach, kiw69 has established procedures to contain the breach, assess its impact, notify affected users (where required by law), and report the incident to relevant authorities.

While we implement robust security measures, no system is completely invulnerable. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately at [email protected] if you suspect unauthorized access to your account.

9. Your Data Protection Rights

Subject to applicable data protection laws, you have the following rights regarding your personal data:

• Right of Access: You may request a copy of the personal data kiw69 holds about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. You can update certain information directly through your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where: the data is no longer necessary for the purposes for which it was collected; you withdraw consent (where consent is the legal basis); or the data has been unlawfully processed. This right is subject to legal obligations that require data retention (e.g., financial records, KYC documents).
• Right to Restriction of Processing: You may request that we limit the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to processing.
• Right to Data Portability: You may request that we provide your personal data in a structured, machine-readable format, or transmit it directly to another controller (where technically feasible).
• Right to Object: You may object to processing of your personal data where it is based on legitimate interests or for direct marketing purposes. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing conducted prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory data protection authority in your jurisdiction if you believe your rights have been violated.

To exercise any of these rights, please submit a request in writing to [email protected] with the subject line "Data Protection Request." We will respond within 30 calendar days and may request additional information to verify your identity before processing your request.

10. Cookies and Tracking Technologies

kiw69 uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and deliver personalized content.

10.1 Types of Cookies We Use

• Essential Cookies: Required for core functionality such as login authentication, session management, and secure transaction processing. These cookies cannot be disabled.
• Preference Cookies: Store your language selection, currency preference, and display settings to personalize your experience.
• Analytics Cookies: Collect anonymized data about how users interact with the platform (pages visited, time spent, click paths) to help us improve usability.
• Marketing Cookies: Track your browsing activity to deliver relevant promotional offers. These cookies are only set with your explicit consent.

10.2 Managing Cookies

You can control cookie settings through your browser preferences. Most browsers allow you to block all cookies, accept only first-party cookies, or delete cookies upon closing the browser. Please note that disabling essential cookies may impair functionality and prevent you from using certain features of kiw69.

To opt out of analytics tracking, many analytics providers offer browser plugins (e.g., Google Analytics Opt-out Browser Add-on). kiw69 respects Do Not Track signals where technically feasible.

11. Third-Party Services and Links

The kiw69 platform may contain links to third-party websites, including game provider sites, payment processor pages, or social media platforms. This Privacy Policy applies solely to data collected by kiw69. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before providing any personal data.

Third-party game providers (such as live casino operators and slot developers) may collect limited data directly through their embedded game interfaces. Such data collection is governed by the game provider's own privacy policy, not by this policy. kiw69 selects game providers that maintain industry-standard privacy and security practices.

12. International Data Transfers

kiw69 primarily serves users in Indonesia, and your personal data is stored on servers located within secure data centers. In certain circumstances, your data may be transferred to, or processed by, service providers located outside Indonesia (such as cloud hosting providers or identity verification services).

Where data is transferred internationally, kiw69 ensures that appropriate safeguards are in place, including: reliance on adequacy decisions by relevant data protection authorities; use of standard contractual clauses approved by regulatory bodies; or certification under recognized data protection frameworks. You have the right to obtain information about the safeguards applied to international transfers by contacting us at [email protected].

13. Children's Privacy

kiw69 is an adult-only platform. We do not knowingly collect, process, or solicit personal data from individuals under the age of 21. All users must confirm they are at least 21 years of age during registration, and we verify age through KYC processes before permitting withdrawals.

If we become aware that we have inadvertently collected personal data from a person under 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has accessed the platform, please notify us immediately at [email protected].

14. Changes to This Privacy Policy

kiw69 reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform functionality. Any revisions will be effective immediately upon posting to the platform, with the "Last Updated" date revised accordingly.

For material changes that significantly affect how we process your personal data or your rights, we will provide advance notice via the email address registered to your account. Continued use of the platform after the effective date of an updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with the revised policy, you may close your account in accordance with our Terms & Conditions.

15. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the kiw69 Data Protection Team using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Privacy Inquiries: "Privacy Policy Question" or "Data Protection Request"
• Response Time: We aim to acknowledge all privacy-related inquiries within 24 hours and provide a substantive response within 30 calendar days.

For urgent privacy concerns (such as suspected unauthorized access to your account or a potential data breach), please mark your email as "URGENT — PRIVACY" to ensure priority handling by our security team.