Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by tuwaga through our website located at https://tuwaga.cam, mobile applications, and related services (collectively, the "Platform"). This policy describes how tuwaga ("we," "us," or "our") collects, uses, discloses, stores, and protects personal information of users ("you" or "your") who access or use our online gaming and sports betting services.

tuwaga operates as an online gaming platform specifically serving the Indonesian market, offering casino games, slot games, live dealer services, sports betting including football (bandar bola), mix parlay accumulators, lottery services including togel (Indonesia's traditional numbers lottery), and other gaming products. As part of providing these services, we collect and process various categories of personal data in accordance with applicable data protection laws and regulations.

By creating an account, accessing the Platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with any aspect of this policy, you must immediately cease using our services and close your account.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a tuwaga account or use our services, you voluntarily provide us with personal information including:

• Registration Information: Full legal name, date of birth, gender, nationality, residential address, email address, mobile phone number, and chosen username and password.
• Identity Verification Documents: Copies of your Indonesian National Identity Card (KTP), proof of address (utility bills, bank statements), selfie photographs for facial recognition, and any additional documentation required for Know Your Customer (KYC) compliance.
• Financial Information: Bank account numbers, bank names (BCA, BRI, BNI, Mandiri, etc.), e-wallet account details (OVO, DANA, GoPay, ShopeePay), payment card information, transaction amounts, and deposit/withdrawal history.
• Communication Records: Content of messages sent through live chat, email correspondence with customer support, feedback forms, survey responses, and any other communications with tuwaga.
• Preference Data: Gaming preferences, notification settings, communication preferences, language choices, and platform customization options.

2.2 Information Collected Automatically

When you access and use the tuwaga Platform, we automatically collect certain technical and usage information:

• Device and Browser Information: Device type, operating system, browser type and version, screen resolution, device identifiers (UDID, IMEI), mobile network information, and hardware specifications.
• Connection Data: IP address, internet service provider, geographic location (country, city, region), time zone settings, and connection timestamps.
• Usage Analytics: Pages visited, features used, time spent on platform, navigation paths, click patterns, gaming activity records, bet placements, game outcomes, session duration, and interaction patterns.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, pixel tags, local storage objects, and similar tracking technologies that help us recognize your device and preferences.
• Performance Data: Platform performance metrics, error logs, crash reports, loading times, and technical diagnostics.

2.3 Information from Third-Party Sources

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

• Identity verification service providers who confirm your identity and detect fraud.
• Payment processors who handle deposits and withdrawals on our behalf.
• Marketing partners and affiliate networks through which you may have been referred.
• Publicly available sources such as government registers or databases for regulatory compliance.
• Social media platforms if you choose to connect your account (though we do not currently offer social login).

3. How We Use Your Information

tuwaga uses your personal information for the following legitimate business purposes:

3.1 Service Delivery and Account Management

• Creating and maintaining your gaming account.
• Processing deposits, withdrawals, and other financial transactions.
• Providing access to casino games, sports betting markets, and other gaming services.
• Managing your account balance and transaction history.
• Processing bonus claims and tracking wagering requirements.
• Facilitating participation in tournaments, competitions, and promotions.
• Providing VIP program benefits and tier-based rewards.

3.2 Legal and Regulatory Compliance

• Verifying your identity and age to ensure you meet the 21+ requirement for Indonesian players.
• Conducting Know Your Customer (KYC) and anti-money laundering (AML) checks.
• Detecting and preventing fraud, money laundering, and other illegal activities.
• Complying with legal obligations, court orders, and regulatory requirements.
• Maintaining records as required by gaming licenses and financial regulations.
• Cooperating with law enforcement agencies and regulatory authorities when legally required.

3.3 Platform Security and Integrity

• Protecting the security and integrity of our platform and systems.
• Detecting and preventing unauthorized access, hacking attempts, and cyber attacks.
• Identifying and preventing bonus abuse, collusion, and unfair gameplay.
• Monitoring for multiple accounts and duplicate registrations.
• Investigating suspicious transactions or betting patterns.
• Enforcing our Terms & Conditions and acceptable use policies.

3.4 Customer Support and Communication

• Responding to your inquiries, complaints, and support requests via live chat, WhatsApp, and email.
• Providing technical assistance and troubleshooting account issues.
• Sending transactional notifications about deposits, withdrawals, and account activity.
• Communicating important platform updates, policy changes, and service announcements.
• Resolving disputes and investigating customer complaints.

3.5 Marketing and Personalization

• Sending promotional offers, bonus announcements, and marketing communications (with your consent).
• Personalizing your gaming experience based on preferences and activity history.
• Recommending games, betting markets, and features that may interest you.
• Conducting surveys and collecting feedback to improve our services.
• Analyzing user behavior to optimize platform design and functionality.

3.6 Business Analytics and Improvement

• Analyzing platform usage patterns and user demographics.
• Measuring the effectiveness of marketing campaigns and promotional offers.
• Conducting research to develop new features and gaming products.
• Improving website performance, loading speeds, and user interface design.
• Generating anonymized aggregate statistics for business reporting.

4. Legal Basis for Processing (GDPR Compliance)

For users in jurisdictions with comprehensive data protection laws, we process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (providing gaming services, processing transactions, managing your account).
• Legal Obligation: Processing is required to comply with legal and regulatory obligations including KYC, AML, age verification, and licensing requirements.
• Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, platform security, service improvement, business analytics) provided these interests do not override your fundamental rights.
• Consent: Where required by law, we obtain your explicit consent for specific processing activities such as marketing communications and non-essential cookies.

5. Data Sharing and Disclosure

tuwaga does not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may share your data with the following categories of recipients under specific circumstances:

5.1 Service Providers and Business Partners

• Payment Processors: Financial institutions and payment service providers who facilitate deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and other supported methods.
• Identity Verification Services: Third-party KYC and AML compliance providers who verify your identity and screen for fraud.
• Game Providers: Software studios and gaming content suppliers whose games are featured on our platform.
• Technology and Hosting Providers: Cloud infrastructure providers, content delivery networks, and technical service providers who support our platform operations.
• Customer Support Tools: Live chat service providers and communication platforms used to deliver customer support.
• Marketing and Analytics Partners: Analytics providers, marketing platforms, and advertising networks (subject to your consent where required).

5.2 Legal and Regulatory Authorities

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

• Required by law, legal process, or court order.
• Necessary to comply with gaming license obligations and regulatory reporting requirements.
• Responding to lawful requests for information from authorities.
• Necessary to detect, prevent, or address fraud, security issues, or illegal activities.
• Required to protect the rights, property, or safety of tuwaga, our users, or the public.

5.3 Business Transfers

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

5.4 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with third parties for research, analytics, marketing, or other business purposes. Such data does not constitute personal information under applicable privacy laws.

6. Data Security Measures

tuwaga implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, loss, alteration, or disclosure:

6.1 Technical Security Controls

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption protocols.
• Secure Storage: Personal data is stored on secure servers with restricted access controls, encrypted databases, and regular security audits.
• Firewall Protection: Advanced firewall systems protect our infrastructure from external threats and unauthorized access attempts.
• Intrusion Detection: Real-time monitoring systems detect and respond to suspicious activity, potential breaches, and cyber attacks.
• Regular Security Updates: Our systems receive continuous security patches, vulnerability assessments, and penetration testing.
• Secure Authentication: Password hashing, multi-factor authentication options, and secure session management protect account access.

6.2 Organizational Security Measures

• Access Controls: Personal data is accessible only to authorized personnel who require it for legitimate business purposes, subject to strict confidentiality obligations.
• Employee Training: Staff members receive regular training on data protection, privacy regulations, and security best practices.
• Third-Party Agreements: All service providers and partners who process personal data on our behalf are contractually bound to maintain appropriate security standards.
• Incident Response Plan: We maintain a comprehensive data breach response plan to address security incidents promptly and effectively.
• Regular Audits: Independent security audits and compliance assessments verify the effectiveness of our security measures.

6.3 Limitations and User Responsibilities

While we implement robust security measures, no system is completely impenetrable. You play a crucial role in protecting your account by:

• Creating a strong, unique password and keeping it confidential.
• Never sharing your login credentials with anyone.
• Logging out after each session, especially on shared or public devices.
• Notifying us immediately if you suspect unauthorized account access.
• Keeping your contact information up to date so we can reach you regarding security matters.

7. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal data. tuwaga respects these rights and provides mechanisms to exercise them:

To exercise any of these rights, please contact our privacy team at [email protected] with your request. We will respond within 30 days of receiving a valid request. Note that certain requests may require identity verification before we can proceed.

8. Data Retention

tuwaga retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Account Data: Retained for the duration of your account relationship plus a reasonable period after account closure.
• Transaction Records: Retained for 7 years from the date of transaction for financial and regulatory compliance purposes.
• Identity Verification Documents: Retained for 7 years after account closure to comply with anti-money laundering regulations.
• Gaming Activity Logs: Retained for 5 years for responsible gaming monitoring, dispute resolution, and regulatory requirements.
• Marketing Communications: Retained until you opt out or withdraw consent, plus a suppression period to honor your preferences.
• Technical and Usage Data: Retained for up to 2 years for analytics and platform improvement purposes.
• Customer Support Records: Retained for 3 years to maintain service quality and resolve potential disputes.

After the applicable retention period expires, we securely delete or anonymize your personal data in accordance with data protection best practices. Some data may be retained in aggregated, anonymized form for statistical and research purposes.

9. Cookies and Tracking Technologies

The tuwaga platform uses cookies and similar tracking technologies to enhance your user experience, analyze platform usage, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize you on subsequent visits.

9.1 Types of Cookies We Use

• Essential Cookies: Necessary for platform functionality, account login, session management, and security. These cannot be disabled.
• Performance Cookies: Collect anonymous information about how visitors use the platform to help us improve website performance and user experience.
• Functionality Cookies: Remember your preferences (language, currency, display settings) to provide a personalized experience.
• Advertising Cookies: Track your browsing activity to deliver relevant promotional offers and measure marketing campaign effectiveness (with consent).

9.2 Managing Cookie Preferences

You can control cookie settings through your browser preferences. Most browsers allow you to refuse all cookies, accept only certain cookies, or receive notifications when cookies are set. Note that disabling essential cookies may impair platform functionality and prevent you from accessing certain features. Refer to your browser's help documentation for specific instructions on managing cookies.

10. International Data Transfers

tuwaga operates an international platform, and your personal data may be transferred to, stored, and processed in countries outside Indonesia where our servers, service providers, or business partners are located. These countries may have data protection laws that differ from Indonesian regulations.

When we transfer your personal data internationally, we implement appropriate safeguards including:

• Standard contractual clauses approved by relevant data protection authorities.
• Ensuring service providers maintain adequate data protection standards.
• Implementing technical and organizational security measures during transfer.
• Conducting due diligence on data protection practices in destination countries.

By using tuwaga services, you consent to the international transfer of your personal data as described in this policy.

11. Children's Privacy

tuwaga services are strictly intended for individuals who are at least 21 years of age, which is the legal gambling age in Indonesia. We do not knowingly collect personal information from anyone under 21 years old. Our Terms & Conditions explicitly prohibit underage individuals from creating accounts or using our services.

If we become aware that a user is under 21 or that we have inadvertently collected personal information from a minor, we will immediately:

• Terminate the account and prohibit further access to the platform.
• Delete all personal information associated with the account.
• Refund any deposits to the payment method used, after deducting any withdrawals.
• Report the incident to relevant authorities if required by law.

If you believe we have collected information from someone under 21, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

tuwaga 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:

• Post the updated policy on our website with a revised "Last Updated" date.
• Send email notification to your registered email address if changes significantly affect your rights.
• Display a prominent notice on the platform upon your next login.
• Where required by law, obtain your explicit consent for material changes.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Continued use of tuwaga services after policy changes constitutes acceptance of the updated terms. If you do not agree with modifications, you should discontinue use and close your account.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact our privacy team:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Live Chat: Available 24/7 through the platform for general inquiries
• WhatsApp: Contact details available on the platform

For formal data subject access requests or privacy complaints, please email us with "DSAR" or "Privacy Complaint" in the subject line. We will acknowledge receipt within 5 business days and provide a substantive response within 30 days.

For further information about your data protection rights and relevant regulations, you may also wish to consult the data protection authority in your jurisdiction.