Privacy Policy

In this Privacy Policy, the following terms carry the meanings assigned below, consistent with the definitions used in the s9wd Terms & Conditions:

• "s9wd", "we", "us", or "our" — the online gaming platform accessible at https://s9wd.cam and its operating entity.
• "Member", "you", or "your" — any individual who has registered, or is in the process of registering, an account on s9wd, or who otherwise accesses the Platform.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to names, email addresses, phone numbers, financial account details, IP addresses, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the purposes of this policy, s9wd is the Data Controller.
• "Third-Party Processor" — any external service provider that processes Personal Data on behalf of and under the instruction of s9wd.
• "Platform" — the s9wd website, mobile-optimised interface, and all associated technology through which gaming and support services are delivered to Members.

s9wd is the Data Controller responsible for Personal Data collected through and in connection with the Platform. As Data Controller, s9wd determines the purposes for which your data is used and the means by which it is processed.

For all privacy-related enquiries, requests to exercise data rights, or complaints, you may contact our Data Protection contact via the details provided in Section 16 of this policy. All privacy communications are handled in strict confidence and in accordance with applicable data protection standards.

s9wd collects Personal Data across several categories, depending on your interaction with the Platform. The categories of data we collect are set out in the table below:

s9wd does not intentionally collect any special categories of sensitive personal data (such as health, biometric, racial, political, or religious data). If any such data is inadvertently provided, it will be promptly deleted and not processed.

s9wd collects Personal Data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or completing any other form or interaction on the Platform.
• Automated technologies: Technical and usage data collected automatically when you access or interact with the Platform, including through cookies, server logs, and analytics tools. See Section 9 for full cookie details.
• Third-party sources: Identity and fraud-risk data obtained from KYC verification providers, fraud screening services, and payment processors, used to supplement registration information and fulfill our AML obligations.
• Payment processors: Transaction confirmation data (not full card or account numbers) received from payment gateway partners including Indonesian bank transfer gateways and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja).

s9wd processes your Personal Data on one or more of the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions, including operating your account, processing transactions, and delivering gaming services.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, counter-terrorism financing (CTF) obligations, and any regulatory direction.
• Legitimate interests: Processing carried out in pursuit of s9wd's legitimate business interests — including fraud prevention, platform security, service improvement, and responsible gaming monitoring — where these interests are not overridden by your privacy rights.
• Consent: Where we rely on your consent to process Personal Data — for example, for non-essential cookies or direct marketing communications — you may withdraw that consent at any time by contacting us at the details provided in Section 16. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

s9wd uses the Personal Data we collect for the following purposes:

• Account management: Creating, maintaining, and securing your s9wd account, including identity verification and password recovery.
• Service delivery: Processing deposits and withdrawals, settling wagers, crediting bonuses, and operating the full suite of betting and gaming services available on the Platform.
• KYC and AML compliance: Verifying your identity, age (21+), and source of funds to comply with internationally recognised anti-money laundering standards and to prevent fraud, collusion, and financial crime.
• Responsible gaming: Monitoring account activity to identify signs of problem gambling behaviour, applying deposit or loss limits where requested, and administering self-exclusion requests.
• Customer support: Responding to your enquiries, complaints, and requests through live chat and email, and maintaining records of those communications for quality and compliance purposes.
• Platform improvement: Analysing aggregated usage data to understand how Members interact with the Platform, identify technical issues, and develop new features and content.
• Security and fraud prevention: Detecting, investigating, and preventing unauthorised access, fraudulent transactions, bonus abuse, multi-accounting, and other security threats.
• Legal compliance: Meeting our obligations under applicable laws, responding to lawful requests from regulatory or law enforcement authorities, and enforcing our Terms & Conditions.
• Marketing communications: Sending you promotional offers, bonus announcements, and platform updates where you have not opted out of such communications. You may opt out at any time by contacting support.

s9wd does not sell or rent your Personal Data. We share your data only in the circumstances described below, and only to the extent necessary for the stated purpose:

• Payment processors and banking partners: Your financial data is shared with the payment gateways, Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon), and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) required to process your deposits and withdrawals.
• KYC and identity verification providers: Your identity and address documentation may be shared with accredited third-party KYC verification services to authenticate your identity and age as part of our compliance obligations.
• Fraud prevention and AML screening services: Transaction and identity data may be shared with internationally recognised fraud detection platforms and sanctions screening databases to detect and prevent financial crime.
• Technology and infrastructure providers: Providers of hosting, cloud storage, customer support platforms, and analytics tools may have access to Personal Data as Third-Party Processors, operating under strict data processing agreements and subject to confidentiality obligations.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory direction, s9wd will disclose Personal Data to the relevant authority. s9wd will, where legally permissible, notify the affected Member of any such disclosure.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of s9wd's business or assets, Personal Data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third parties with whom Personal Data is shared are required to implement appropriate technical and organisational measures to protect your data and are prohibited from using it for any purpose beyond that which is strictly necessary to perform their contracted services.

s9wd retains Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law. The general retention periods applicable to each category of data are as follows:

Upon the expiry of the applicable retention period, Personal Data will be securely deleted or anonymised such that it can no longer be attributed to any identifiable individual. In cases where data must be retained for an ongoing legal dispute or regulatory investigation, retention will be extended until the matter is resolved.

s9wd uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. The types of cookies we use are described below:

• Strictly necessary cookies: Essential for the Platform to function. These enable account login sessions, security features, and core platform operations. They cannot be disabled without preventing you from using the Platform.
• Functional cookies: Remember your preferences such as language settings, regional display options, and previously entered information to improve your experience across sessions.
• Analytics cookies: Collect aggregated, anonymised data about how Members use the Platform — pages visited, session duration, features used — to help us identify improvements and fix technical issues.
• Security and fraud-detection cookies: Used to identify and flag suspicious session behaviour, automated bot activity, and account takeover attempts.

You may control non-essential cookies through your browser settings. Note that disabling functional or analytics cookies may affect certain Platform features. Strictly necessary cookies cannot be opted out of as they are required for the Platform to operate.

As a data subject whose Personal Data is processed by s9wd, you hold the following rights. You may exercise any of these rights by contacting us using the details in Section 16. s9wd will respond to all valid rights requests within 30 days of receipt.

Please note that certain rights are subject to limitations. For example, the right to erasure does not apply where retention is required by law (such as AML record-keeping obligations). Where s9wd is unable to fulfil a rights request in full, we will provide a clear written explanation of the reason.

s9wd implements a comprehensive set of technical and organisational security measures to protect Personal Data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption: All data transmitted between your device and the s9wd Platform is encrypted using industry-standard SSL/TLS protocols, preventing interception during transit.
• Encryption at rest: Sensitive Personal Data stored on s9wd's servers — including identity documents and financial information — is encrypted using strong cryptographic algorithms.
• Access controls: Access to Personal Data within s9wd's systems is restricted on a strict need-to-know basis. Employee access is logged, audited, and subject to regular review.
• Secure infrastructure: Platform servers are hosted in certified, access-controlled data centres with physical security measures, redundant power, and 24/7 infrastructure monitoring.
• Penetration testing and audits: s9wd conducts regular security assessments, including penetration testing and vulnerability scanning, to identify and remediate potential weaknesses proactively.
• Incident response: s9wd maintains a documented data breach response plan. In the event of a breach likely to result in risk to your rights, affected Members will be notified promptly in accordance with applicable law.

While s9wd takes all reasonable steps to protect your Personal Data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account login credentials and for notifying s9wd immediately if you suspect any unauthorised access to your account.

s9wd is an internationally operating platform. As a result, your Personal Data may be transferred to and processed in countries outside Indonesia, including countries where data protection laws may differ from those applicable in Indonesia.

Where such international transfers occur, s9wd ensures that appropriate safeguards are in place to protect your Personal Data to a standard equivalent to that which applies within Indonesia. These safeguards include:

• Entering into binding data processing agreements with international Third-Party Processors that incorporate internationally recognised standard contractual clauses or equivalent data transfer mechanisms.
• Transferring data only to countries or service providers that maintain demonstrably adequate levels of data protection as assessed against international best practice.
• Conducting transfer impact assessments where required to confirm that transferred data will remain adequately protected in the destination jurisdiction.

You may request further information about the specific safeguards in place for any particular international data transfer by contacting us at the details provided in Section 16.

The s9wd Platform may contain references to third-party services such as payment providers, game studios (Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft, Microgaming, NetEnt), and sports data providers. Where links to third-party sites or services exist, s9wd is not responsible for the privacy practices or content of those third parties.

We strongly encourage you to review the privacy policies of any third-party service you access in connection with your use of s9wd. s9wd's Privacy Policy applies exclusively to Personal Data processed by s9wd through the Platform.

s9wd is strictly an adults-only platform. Access to and use of the Platform is prohibited for any person under the age of 21. s9wd does not knowingly collect, store, or process Personal Data belonging to individuals under 21 years of age.

If s9wd discovers that Personal Data has been collected from a person under 21, the relevant account will be immediately closed, all associated data will be deleted, and any deposits will be returned to the source payment method in accordance with applicable law.

If you are a parent or guardian and believe that your child has accessed s9wd and provided Personal Data, please contact us immediately at the details in Section 16 so that we can take prompt action.

s9wd reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, applicable laws, or operational requirements. The "Last Updated" date at the top of this page indicates when the current version was published.

Where any change to this Privacy Policy is material — meaning it significantly affects how we process your Personal Data or the rights available to you — s9wd will notify registered Members via the email address associated with their account prior to the change taking effect. Non-material changes (such as formatting updates or clarifications that do not alter the substance of the policy) may take effect immediately without prior notice.

Your continued use of the Platform following notification of a material change constitutes your acceptance of the revised Privacy Policy. If you do not agree with any updated version of this policy, you should cease using the Platform and contact us to close your account and arrange the return of any remaining Real Money balance.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by s9wd, please contact our privacy team using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 through the Platform dashboard. Our support agents — including Indonesian-speaking staff — typically respond within five minutes.
• Response time for privacy requests: s9wd will acknowledge your request within 3 business days (WIB, UTC+7) and provide a substantive response within 30 calendar days. For complex requests, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason.

If you are dissatisfied with our response to any privacy request or complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction. s9wd will cooperate fully with any such authority in the resolution of complaints.