Privacy Policy

1. Introduction

hanwin ("we", "us", "our") operates an online betting and gaming platform accessible at hanwin.cam (the "Platform"). This Privacy Policy describes how we collect, use, disclose, and protect personal information obtained from users ("you", "your") who access or use our Platform and services. By creating an account or using the Platform in any capacity, you consent to the data practices described in this Privacy Policy.

We recognize that your privacy is important, and we are committed to maintaining the confidentiality, integrity, and security of all personal information we collect. This Privacy Policy complies with applicable data protection laws and industry best practices for online gaming operators. If you do not agree with the terms of this Privacy Policy, you must discontinue use of the Platform immediately.

2. Information We Collect

hanwin collects several categories of personal information to provide, maintain, and improve our services, comply with legal obligations, and ensure the security and integrity of the Platform.

2.1 Information You Provide Directly

When you register for an account, place a wager, or contact customer support, you voluntarily provide us with personal information, including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification number (Indonesian national identity card number or passport number).
• Contact Information: Email address, mobile phone number, residential address, city, province, postal code.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account identifiers (OVO, DANA, GoPay account numbers), cryptocurrency wallet addresses, payment transaction history.
• Verification Documents: Copies of government-issued ID (KTP, passport), utility bills, bank statements, selfies for facial verification, proof of payment method ownership.
• Communication Data: Content of emails, live chat transcripts, support tickets, feedback forms, survey responses.

2.2 Information Collected Automatically

When you access the Platform, we automatically collect certain technical and usage information through cookies, web beacons, log files, and similar technologies:

• Device Information: Device type (desktop, mobile, tablet), operating system (Windows, macOS, Android, iOS), browser type and version, screen resolution, installed fonts, device fingerprint identifiers.
• Usage Data: IP address, geolocation data (city, region, country), pages visited, time spent on pages, referral sources, clickstream data, wager history, game play patterns, deposit and withdrawal history, session duration, timestamps of activity.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, authentication tokens, analytics identifiers, advertising identifiers. For more information, see Section 8 (Cookies and Tracking Technologies).

2.3 Information from Third Parties

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

• Payment Processors: Transaction verification data, fraud screening results, payment method ownership confirmation from banks, e-wallet providers, and cryptocurrency exchanges.
• Identity Verification Providers: KYC and AML verification results, identity fraud risk scores, watchlist screening results from third-party compliance vendors.
• Marketing Partners: Aggregated demographic data, interest-based audience segments (no personally identifiable information is shared without your explicit consent).

3. How We Use Your Information

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

3.1 Account Management and Service Delivery

• Creating, maintaining, and authenticating your account.
• Processing deposits, withdrawals, and internal fund transfers.
• Enabling you to place wagers and participate in games.
• Calculating winnings, settling bets, and crediting your account balance.
• Providing customer support and responding to your inquiries.
• Sending transactional communications (account confirmations, password resets, transaction receipts, withdrawal approvals).

3.2 Compliance and Security

• Verifying your identity and age (21+ requirement) through KYC procedures.
• Conducting Anti-Money Laundering (AML) screening and sanctions list checks.
• Detecting, preventing, and investigating fraud, collusion, money laundering, and other illegal activities.
• Monitoring for problem gambling behaviors and enforcing responsible gaming policies.
• Complying with legal obligations, regulatory requirements, court orders, and law enforcement requests.
• Protecting the security and integrity of the Platform against cyberattacks, unauthorized access, and malicious activity.

3.3 Marketing and Personalization

• Sending promotional offers, bonuses, and marketing communications via email and SMS (you may opt out at any time).
• Personalizing your user experience based on your betting preferences, game history, and browsing behavior.
• Conducting market research, surveys, and user analytics to improve our services.
• Measuring the effectiveness of our advertising campaigns and referral programs.

3.4 Legal and Operational Requirements

• Establishing, exercising, or defending legal claims.
• Complying with tax reporting obligations and financial audits.
• Maintaining business records and internal reporting.
• Facilitating corporate transactions such as mergers, acquisitions, or asset sales (your data may be transferred to successor entities).

4. Legal Basis for Processing (International Users)

For users subject to data protection laws that require disclosure of a legal basis for processing (such as the European Union's General Data Protection Regulation, GDPR), hanwin processes your personal information under the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., providing betting and gaming services).
• Legal Obligation: Processing is required to comply with applicable laws, including AML, KYC, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, and improving our services, provided these interests are not overridden by your privacy rights.
• Consent: Where required by law, we obtain your explicit consent before processing certain categories of data (e.g., marketing communications, location tracking).

5. How We Share Your Information

hanwin does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for the purposes described in this Privacy Policy:

5.1 Service Providers and Business Partners

• Payment Processors: Banks, e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), and cryptocurrency payment gateways that facilitate deposits and withdrawals.
• Identity Verification Vendors: Third-party KYC/AML service providers that verify your identity and screen for sanctions, politically exposed persons (PEPs), and fraud risks.
• Game Providers: Licensed software studios (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe) that supply games and maintain game logs.
• Cloud Hosting Providers: Data centers and infrastructure providers that host the Platform and store encrypted backups.
• Customer Support Platforms: Third-party live chat, ticketing, and CRM systems used to manage customer inquiries.
• Marketing and Analytics Services: Email marketing platforms, SMS gateways, analytics tools (Google Analytics, Mixpanel, Hotjar) that help us understand user behavior and optimize the Platform (anonymized data only).

5.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies, regulators, law enforcement, courts, or other public authorities if required by law or in response to a valid legal request, including but not limited to:

• Compliance with subpoenas, court orders, or legal processes.
• Cooperation with AML investigations, tax audits, or financial crime inquiries.
• Protection of hanwin's rights, property, and safety, or the rights and safety of other users or the public.

5.3 Business Transfers

In the event that hanwin undergoes a merger, acquisition, reorganization, asset sale, or bankruptcy proceeding, your personal information may be transferred to the acquiring entity or successor organization. We will notify you via email and/or a prominent notice on the Platform before your information is transferred and becomes subject to a different Privacy Policy.

6. Data Retention

hanwin retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Active Account Data: Retained for the duration of your account's active status plus 6 years after account closure (to comply with financial record-keeping and AML obligations).
• Transaction Records: Retained for 7 years from the date of the transaction (tax and audit compliance).
• Marketing Communications: Retained until you opt out or withdraw consent, plus 1 year for record-keeping purposes.
• Support Tickets and Communications: Retained for 3 years from the date of the last interaction.
• Device and Usage Logs: Retained for 2 years for fraud prevention and security purposes, then anonymized or deleted.

After the applicable retention period expires, your personal information will be securely deleted or anonymized in accordance with our data destruction policies.

7. Data Security

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

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit TLS/SSL protocols. Sensitive data at rest (passwords, payment information) is encrypted using AES-256 encryption.
• Access Controls: Personal information is accessible only to authorized personnel on a need-to-know basis. All employees and contractors with access to personal data are bound by confidentiality agreements.
• Network Security: Firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) protect our infrastructure from cyberattacks.
• Regular Audits: We conduct quarterly security audits and annual penetration testing to identify and remediate vulnerabilities.
• Secure Development Practices: Code reviews, vulnerability scanning, and security testing are integrated into our software development lifecycle.

While we implement robust security measures, no method of electronic storage or transmission over the Internet is 100% secure. We cannot guarantee absolute security, and you acknowledge that you provide your personal information at your own risk. If we become aware of a data breach that compromises your personal information, we will notify you in accordance with applicable data breach notification laws.

8. Cookies and Tracking Technologies

hanwin uses cookies, web beacons, and similar tracking technologies to enhance your user experience, analyze Platform usage, and deliver targeted advertising. A cookie is a small text file stored on your device that allows us to recognize you on subsequent visits.

8.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly (session management, authentication, load balancing). These cookies cannot be disabled.
• Performance Cookies: Collect anonymous usage statistics to help us understand how users interact with the Platform (Google Analytics, Hotjar).
• Functional Cookies: Remember your preferences (language, currency, game favorites) to provide a personalized experience.
• Advertising Cookies: Track your browsing activity across websites to deliver relevant ads and measure campaign effectiveness (Google Ads, Facebook Pixel).

8.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when a cookie is being sent. Note that disabling cookies may limit your ability to use certain features of the Platform. To learn more about cookies and how to manage them, visit www.allaboutcookies.org (plain text — not a clickable link).

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Rectification: You may request that we correct inaccurate or incomplete personal information.
• Right to Erasure: You may request that we delete your personal information, subject to legal and contractual retention obligations.
• Right to Restrict Processing: You may request that we limit the processing of your personal information in certain circumstances.
• Right to Data Portability: You may request a machine-readable copy of your personal information to transfer to another service provider.
• Right to Object: You may object to processing based on legitimate interests or direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact us at support@hanwin.cam (plain text — not a clickable link) with the subject line "Privacy Rights Request". We will respond to your request within 30 days. Please note that we may require proof of identity before processing your request to prevent unauthorized access to your personal information.

10. Children's Privacy

The hanwin Platform is intended solely for users who are at least 21 years of age. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal information from a minor, we will take immediate steps to delete such information and terminate the associated account. If you believe that a minor has provided personal information to hanwin, please contact us immediately at support@hanwin.cam.

11. International Data Transfers

hanwin operates internationally, and your personal information may be transferred to, stored in, and processed in jurisdictions outside of Indonesia, including countries that may not provide the same level of data protection as your home jurisdiction. When we transfer personal information across borders, we implement appropriate safeguards to ensure that your data remains protected in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include standard contractual clauses, binding corporate rules, or reliance on adequacy decisions issued by competent data protection authorities.

12. Third-Party Links

The hanwin Platform may contain links to third-party websites, services, or applications that are not operated or controlled by hanwin (e.g., game provider websites, social media platforms, payment processor portals). This Privacy Policy applies only to information collected by hanwin. We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

hanwin reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated to you via email (to the address registered on your account) or through a prominent notice on the Platform at least 30 days before the new policy takes effect. Your continued use of the Platform after the effective date of the revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically.

14. Contact Information

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data handling practices, please contact us using the following methods:

• Email: support@hanwin.cam (plain text — not a clickable link)
• Subject Line: "Privacy Policy Inquiry" or "Data Protection Request"
• Live Chat: Available 24/7 via the hanwin website
• Response Time: We aim to respond to all privacy inquiries within 48 hours during business days (Monday–Friday, 09.00–18.00 WIB).

If you are not satisfied with our response or believe that we are processing your personal information in violation of applicable data protection laws, you have the right to lodge a complaint with your local data protection authority or supervisory body.