Privacy Policy — dew11

This Privacy Policy applies to all individuals who visit, browse, register on, or otherwise interact with the dew11 platform at https://dew11.pro (the "Platform"). It covers all personal data processed by dew11 in connection with the delivery of its sportsbook, live casino, slot games, togel (Indonesia's traditional numbers lottery), and related services.

This policy should be read alongside dew11's Terms & Conditions, which govern the overall relationship between dew11 and its Members. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters of data processing, this Privacy Policy shall prevail.

dew11 is committed to handling your personal data responsibly, transparently, and in accordance with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, and integrity and confidentiality. We process personal data only where we have a legitimate reason to do so, and we never collect more information than is necessary for the stated purpose.

For the purposes of this Privacy Policy, the data controller — the entity that determines the purposes and means of processing your personal data — is dew11, operating the Platform at https://dew11.pro. All data protection enquiries, subject access requests, and formal complaints should be directed to the dew11 Privacy team via the contact details set out in Section 14 of this policy.

Where dew11 engages third-party service providers — such as game studios (e.g., Evolution Gaming, Pragmatic Play, PG Soft), payment processors (e.g., BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay), or technical infrastructure providers — those parties act as data processors operating under dew11's instruction and under contractual obligations that mirror the protections described in this policy.

dew11 collects and processes the following categories of personal data. We collect only what is necessary and proportionate to the purpose for which it is used:

dew11 collects personal data through the following channels:

• Direct Submission: Data you provide when completing the registration form, submitting KYC documents, initiating a deposit or withdrawal, contacting customer support, or filling in any other form on the Platform.
• Automated Collection: Technical and usage data collected automatically when you browse or interact with the Platform, through server logs, session tracking, and first-party analytics tools.
• Payment Providers: Transaction confirmation data (amount, timestamp, reference number, payment method) received from BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, and LinkAja when you complete a deposit or withdrawal.
• Game Providers: Bet settlement data, RTP records, and session logs transmitted by certified game studios (Evolution Gaming, Pragmatic Play, PG Soft, Spribe, and others) to populate your Account history and resolve any disputes.
• Cookies & Similar Technologies: As described in Section 9 below, dew11 uses first-party cookies to maintain session continuity, remember your preferences, and gather aggregate usage analytics. We do not use third-party advertising cookies.
• Third-Party Verification Services: Where identity documents are verified using automated document-scanning technology, the relevant scanning provider processes your KYC documents on dew11's behalf and transmits only a pass/fail verification result along with the data fields required to update your Account status.

dew11 processes personal data only where there is a clear, documented purpose and a legitimate legal basis. The following table sets out the primary processing activities, the purpose of each, and the legal basis on which we rely:

dew11 does not sell, rent, or trade your personal data to third parties for their own commercial or marketing purposes. We share personal data only in the following limited and controlled circumstances:

• Payment Processors: We share your name, account number, and transaction amount with the relevant Indonesian bank (BCA, BRI, BNI, Mandiri, CIMB Niaga) or e-wallet provider (OVO, DANA, GoPay, ShopeePay, LinkAja) solely to execute your deposit or withdrawal request. These providers are not permitted to use your data for any other purpose.
• Game Studios: Your Account identifier and wager data are shared with certified game providers (Evolution Gaming, Pragmatic Play, PG Soft, Spribe, and similar) to deliver game content and settle bets. Game providers act as data processors under binding agreements and do not receive more data than is necessary to operate the game.
• KYC & Identity Verification Providers: Where automated document verification is used to process your KTP, SIM, or passport, your document images and identity data are transmitted to a certified verification service provider operating under a strict data processing agreement. Verified results are returned to dew11; your raw documents are not stored by the third-party provider beyond the period required for verification.
• Regulatory & Law Enforcement Authorities: dew11 will disclose personal data to competent regulatory bodies, financial intelligence units, or law enforcement agencies where we are legally required to do so, or where disclosure is necessary to prevent, detect, or prosecute fraud, money laundering, or other serious criminal offences.
• Professional Advisers: dew11 may share data with auditors, legal advisers, accountants, and compliance consultants who are bound by professional confidentiality obligations and who process such data only to the extent necessary to provide their professional services to dew11.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of dew11's business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the applicable privacy terms before it takes effect.

dew11 retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable legal or regulatory obligations. The following retention periods apply as a general guide:

When the applicable retention period expires, personal data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual. Anonymised, aggregated data (for example, aggregate betting volumes or platform usage statistics) may be retained indefinitely for analytical and business planning purposes.

dew11 takes the security of your personal data seriously and has implemented a layered set of technical and organisational measures to protect it against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-Bit SSL Encryption: All data transmitted between your browser or device and the dew11 Platform is encrypted using TLS 1.2 or higher with 256-bit symmetric encryption. The padlock icon visible in your browser address bar confirms this protection is active.
• Encrypted Data Storage: Personal data and financial records stored on dew11's servers are encrypted at rest. Database access is restricted to authorised personnel operating under strict role-based access controls.
• Two-Factor Authentication (2FA): Members are encouraged — and may in certain high-risk scenarios be required — to enable two-factor authentication on their Account. 2FA requires a one-time code delivered to your registered mobile number in addition to your password at login.
• Intrusion Detection & Monitoring: dew11's infrastructure is monitored 24/7 by automated intrusion detection systems that flag unusual access patterns, brute-force attempts, and other indicators of compromise for immediate investigation.
• Access Controls: Only dew11 staff members with a documented, role-specific need to access personal data are granted such access. All staff with access to personal data undergo data protection awareness training and are bound by confidentiality agreements.
• Penetration Testing: dew11 commissions regular independent security assessments of its Platform infrastructure to identify and remediate vulnerabilities before they can be exploited.

dew11 uses cookies and similar client-side storage technologies to ensure the Platform functions correctly, to remember your preferences, and to gather aggregate analytics that help us improve the service. We use only first-party cookies — we do not place third-party advertising or tracking cookies on your device.

You may control or delete cookies at any time through your browser settings. Most modern browsers allow you to block all cookies, accept only first-party cookies, or delete existing cookies. Please note that disabling strictly necessary cookies will prevent you from logging in to your dew11 Account and using core Platform features. Disabling analytics cookies will not affect your ability to use the Platform in any way.

As a data subject, you hold a set of rights in relation to the personal data dew11 processes about you. dew11 is committed to honouring these rights promptly and without undue bureaucratic friction. The following rights apply:

• Right of Access: You may request a copy of all personal data dew11 holds about you, together with information about how it is processed, who it has been shared with, and how long it will be retained. We will respond to access requests within thirty (30) calendar days.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update most of your Account details directly via your Account profile page; for changes to identity-verified fields (e.g., legal name, date of birth), please contact our support team.
• Right to Erasure ("Right to Be Forgotten"): You may request that dew11 delete your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and no other legal basis applies. This right is subject to dew11's legal obligations to retain certain data (e.g., AML records for five years), and erasure requests that conflict with those obligations will be partially fulfilled — dew11 will delete all data it is legally permitted to delete and retain only what it is legally required to keep.
• Right to Restriction of Processing: You may request that dew11 restrict the processing of your data in certain circumstances — for example, while a dispute about data accuracy is being resolved, or where you have objected to processing and a determination is pending.
• Right to Data Portability: Where processing is based on your consent or on a contract with you, and is carried out by automated means, you may request that dew11 provide your personal data to you in a structured, commonly used, machine-readable format (e.g., CSV or JSON) so that you can transfer it to another service provider if you wish.
• Right to Object: You may object at any time to the processing of your personal data where dew11 relies on legitimate interest as its legal basis. You may also object to receiving marketing communications at any time via your Account settings, regardless of the legal basis for marketing.
• Rights Related to Automated Decision-Making: dew11 may use automated systems to flag potentially suspicious betting patterns or to make eligibility decisions for certain bonus offers. Where such automated decisions produce significant effects on you, you have the right to request human review of the decision and to contest the outcome.

To exercise any of the rights above, please contact the dew11 Privacy team via live chat or by email at [email protected] (plain text — not a clickable link). We may ask you to verify your identity before processing any request that relates to personal data held in a specific Account. We aim to respond to all requests within thirty (30) calendar days; if a request is particularly complex, we will notify you within that period and provide an updated timeline.

During the registration process, dew11 collects your date of birth and uses it to verify that you meet the minimum age requirement. Where there is any reason to doubt a Member's age, dew11 will request documentary proof of age (KTP, passport, or SIM) before allowing further use of the Platform.

If dew11 discovers that personal data has been collected from an individual who was under 21 at the time of registration, the Account will be immediately closed, all associated funds will be handled in accordance with applicable responsible gaming policies, and the personal data of the underage individual will be deleted as promptly as legally possible. Parents or guardians who believe a minor has registered on dew11 are urged to contact our support team immediately via live chat.

dew11 operates internationally, and some of the third-party service providers it engages — particularly game studios such as Evolution Gaming and Pragmatic Play, and cloud infrastructure providers — may process personal data on servers located outside Indonesia. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that available in Indonesia, dew11 ensures that appropriate safeguards are in place, including:

• Contractual Safeguards: Standard contractual clauses or equivalent data transfer agreements with all third-party data processors located outside Indonesia, obligating them to protect your data to the same standard as dew11 does.
• Adequacy Decisions: Where transfers are made to countries that have been formally recognised as providing adequate data protection, dew11 relies on that adequacy determination as the transfer mechanism.
• Binding Corporate Rules: Where applicable, dew11 may rely on a third-party processor's approved binding corporate rules as a transfer mechanism for intra-group data flows.

You may request further information about the specific safeguards in place for any particular international transfer by contacting the dew11 Privacy team as described in Section 14.

dew11 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, new legal obligations, new product features, or feedback from Members. When we make material changes — changes that affect your rights or the way we use your personal data in a significant way — we will:

• Update the "Last Reviewed" and "Effective Date" fields at the top of this document.
• Send a notification to the email address or mobile number registered on your Account, summarising the key changes.
• Display a prominent notice on the Platform homepage for a period of at least fourteen (14) days following the effective date of the change.

Your continued use of the Platform following the effective date of any update constitutes your acknowledgement of the revised Privacy Policy. If you do not agree with any material change, you have the right to close your Account before the effective date of the change by contacting our support team. Minor editorial changes (spelling corrections, reformatting, clarifications that do not alter the substance of any provision) may be made without prior notice.

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or want to raise a concern about how dew11 has handled your personal data, please contact us using one of the following methods:

dew11 takes all privacy complaints seriously. Upon receiving a complaint, our Privacy team will acknowledge receipt within three (3) business days, investigate the matter thoroughly, and provide a substantive written response within thirty (30) calendar days. If your complaint is particularly complex, we will inform you of this and provide a revised timeline. If you remain dissatisfied with our response, you retain the right to escalate your complaint to a relevant supervisory authority or seek independent legal advice.