Privacy Policy

This Privacy Policy ("Policy") describes how fyrwin ("we", "us", "our", "Platform") collects, processes, stores, and protects the personal information of users ("you", "User", "Player") who access or use the fyrwin website at https://fyrwin.cam. We are committed to handling your personal data with the highest standards of transparency, security, and respect for your rights.

By registering an Account or continuing to use the fyrwin Platform, you acknowledge that you have read, understood, and agreed to the practices described in this Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately. This Policy should be read alongside our Terms & Conditions and Responsible Gaming page.

1. Definitions

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, date of birth, and financial information.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" refers to fyrwin, which determines the purposes and means of processing your Personal Data.
• "Data Processor" refers to any third party that processes Personal Data on behalf of fyrwin.
• "KYC" refers to Know Your Customer procedures, including identity verification and document checks required by applicable regulations.
• "Cookies" refers to small text files placed on your device by the Platform to collect browsing and session data.
• "IDR" refers to Indonesian Rupiah, the currency in which all Platform transactions are conducted.

2. Information We Collect

fyrwin collects Personal Data from you through several channels. The categories of information we collect include:

2.1 Information You Provide Directly

• Registration data: full legal name, email address, mobile phone number, date of birth, country of residence (Indonesia), and preferred username.
• KYC verification documents: Indonesian National Identity Card (KTP), passport, proof of address (utility bill or bank statement), and a live selfie or photograph for facial verification.
• Financial information: bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja) used for deposits and withdrawals. Note: we do not store full card numbers or bank account credentials — payment processing is handled by our certified payment partners.
• Communications: messages, queries, and feedback you submit to our customer support team.
• Responsible gaming information: deposit limits, time-out requests, and self-exclusion preferences you set within your Account.

2.2 Information Collected Automatically

• Device and technical data: IP address, browser type and version, operating system, device identifiers, screen resolution, and language settings.
• Usage data: pages visited, time spent on pages, betting activity (markets accessed, bets placed, game sessions started), login timestamps, and navigation paths.
• Cookies and tracking data: session identifiers, preference cookies, analytics cookies, and performance tracking data as described in Section 6.
• Geolocation data: approximate geographic location derived from your IP address, used to enforce eligibility restrictions and deliver regionally relevant content.

2.3 Information from Third Parties

• Identity verification data returned from KYC service providers upon document and facial verification checks.
• Fraud detection signals and risk scores from our payment processors and anti-fraud service partners.
• Data shared by affiliated partners under data-sharing agreements, subject to their own privacy policies.

3. How We Use Your Information

We process your Personal Data for the following purposes:

• Account management: creating, maintaining, and managing your fyrwin Account, including authentication and password recovery.
• Service delivery: enabling betting, gaming, and all related platform features; processing deposits and withdrawals in IDR; settling bets and distributing winnings.
• Identity verification (KYC): verifying your identity, confirming that you are at least 21 years of age, and preventing underage or fraudulent access.
• Regulatory compliance: meeting our obligations under applicable gaming regulations, anti-money laundering (AML) laws, and counter-terrorism financing (CTF) requirements.
• Fraud prevention and security: detecting, investigating, and preventing fraudulent transactions, bonus abuse, account takeover, and other prohibited activities.
• Customer support: responding to your inquiries, resolving disputes, and providing technical assistance in English and Bahasa Indonesia.
• Responsible gaming: monitoring for signs of problem gambling, enforcing deposit limits and self-exclusion requests, and sending responsible gaming reminders as appropriate.
• Marketing and promotions: sending you promotional offers, bonus notifications, and platform updates, where you have provided explicit consent. You may opt out at any time.
• Platform improvement: analyzing usage data to enhance site performance, user experience, and game library curation.
• Legal compliance: meeting data retention obligations, responding to lawful requests from authorities, and enforcing our Terms & Conditions.

4. Legal Basis for Processing

We process your Personal Data on the following legal grounds:

• Contractual necessity: processing required to deliver the services outlined in our Terms & Conditions (e.g., Account creation, bet settlement, withdrawal processing).
• Legal obligation: processing required to comply with applicable laws, including AML/CTF regulations, KYC requirements, and licensing conditions.
• Legitimate interests: processing necessary for fraud prevention, platform security, and business operations, provided such interests are not overridden by your rights.
• Consent: processing for marketing communications, non-essential cookies, and analytics, which you may withdraw at any time.

5. Data Sharing and Disclosure

fyrwin does not sell, rent, or trade your Personal Data to unaffiliated third parties for their own marketing purposes. We may share your data in the following limited circumstances:

• Service providers: payment processors (handling IDR transactions via BCA, BRI, OVO, DANA, etc.), KYC verification providers, fraud detection services, IT infrastructure providers, and customer support platforms. All such providers are bound by data processing agreements and may only process your data on our instructions.
• Regulatory and legal authorities: where required by law, court order, or lawful governmental request — including disclosures mandated by anti-money laundering regulators or gaming licensing authorities.
• Group entities: affiliate entities within the fyrwin corporate group, where such sharing is necessary for service delivery, compliance, or risk management.
• Business transactions: in the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to equivalent privacy protections.
• With your consent: in any other circumstance where you have explicitly authorized the disclosure.

Where we transfer Personal Data outside Indonesia to international service providers, we ensure adequate data protection safeguards are in place, including contractual clauses consistent with applicable data protection standards.

6. Cookies and Tracking Technologies

The fyrwin Platform uses cookies and similar tracking technologies to operate effectively and improve your experience. We use the following categories of cookies:

• Strictly necessary cookies: essential for the Platform to function, including session management, authentication, and security features. These cannot be disabled.
• Functional cookies: store your preferences such as language settings, preferred payment method, and display options to personalize your experience.
• Analytics cookies: collect aggregated data about how you use the Platform (pages visited, session length, bet types) to help us improve functionality. Analytics data is anonymized where possible.
• Marketing and targeting cookies: used to deliver relevant promotional offers and measure campaign effectiveness. These are only deployed with your consent.

You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality. Strictly necessary cookies are exempt from consent requirements.

7. Data Retention

We retain your Personal Data for as long as your Account is active and for a reasonable period thereafter to meet our legal obligations. Specifically:

• Account and transaction data are retained for a minimum of five (5) years after Account closure to satisfy AML/CTF record-keeping requirements.
• KYC documents are retained for the duration of the business relationship and for five (5) years following Account closure.
• Customer support correspondence is retained for two (2) years from the date of the last interaction.
• Marketing consent records are retained for as long as necessary to demonstrate compliance with applicable regulations.

Once the applicable retention period expires, we securely delete or anonymize your Personal Data so it can no longer be associated with you.

8. Your Privacy Rights

Subject to applicable law, you have the following rights with respect to your Personal Data held by fyrwin:

• Right of access: the right to request a copy of the Personal Data we hold about you.
• Right to rectification: the right to request correction of any inaccurate or incomplete Personal Data.
• Right to erasure: the right to request deletion of your Personal Data, subject to our legal retention obligations.
• Right to restriction: the right to request that we limit processing of your Personal Data in certain circumstances.
• Right to data portability: the right to receive your Personal Data in a structured, machine-readable format, where technically feasible.
• Right to withdraw consent: where processing is based on your consent (e.g., marketing emails), you may withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to object: the right to object to processing based on legitimate interests, including profiling for direct marketing purposes.

To exercise any of these rights, please contact our Data Protection team using the contact details in Section 13. We will respond to all verified requests within 30 calendar days. We may need to verify your identity before processing a request.

9. Data Security

fyrwin implements a comprehensive set of technical and organizational security measures to protect your Personal Data from unauthorized access, loss, alteration, or disclosure:

• 256-bit SSL/TLS encryption on all data transmitted between your device and our servers.
• Encrypted data storage for all sensitive Personal Data, including KYC documents and financial identifiers, using industry-standard encryption at rest.
• Access controls ensuring that only authorized personnel can access Personal Data, on a strict need-to-know basis.
• Multi-factor authentication (MFA) for internal systems access and available as an optional security layer for your Account.
• Regular security audits and penetration testing conducted by independent third-party security firms to identify and remediate vulnerabilities.
• Intrusion detection systems that monitor our infrastructure continuously for suspicious activity.
• Staff training on data protection and information security best practices, conducted on a regular basis.

While we apply rigorous security standards, no method of transmission over the internet or electronic storage is entirely infallible. We strongly recommend that you use a strong, unique password for your Account, enable any available two-factor authentication, and notify us immediately at [email protected] if you suspect any unauthorized access to your Account.

10. Third-Party Services

The fyrwin Platform integrates with a number of third-party service providers to deliver a complete and secure betting experience. These include:

• Payment processors: providers facilitating IDR transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, and other local Indonesian payment rails. Each provider operates under its own privacy policy and data handling practices.
• Game content studios: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft supply game content delivered via secure APIs. Gameplay data may be processed by these studios for integrity and audit purposes.
• KYC and identity verification providers: third-party services used to verify your identity documents and perform biometric checks during onboarding and withdrawal processing.
• Analytics platforms: aggregated, anonymized usage data may be processed by analytics providers to help us understand Platform performance and user behavior.

We are not responsible for the privacy practices of third-party services that operate independently of the Platform. We encourage you to review the privacy policies of any third-party providers you interact with directly.

11. Minors and Age Restriction

The fyrwin Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect Personal Data from any individual under the age of 21. Our registration process includes mandatory date-of-birth verification, and KYC procedures confirm age eligibility before any account becomes fully active.

If we become aware that Personal Data has been collected from a person under 21 years of age, we will immediately suspend the relevant Account, delete the associated data to the extent permitted by law, and investigate how the data was submitted. If you believe a minor has registered on the Platform, please notify us at [email protected] without delay.

Parents and guardians are encouraged to use parental control tools and internet filtering software to prevent underage access to online gambling platforms. For guidance on responsible gaming and protecting young people, please visit our Responsible Gaming page.

12. Amendments to This Policy

fyrwin reserves the right to update or amend this Privacy Policy at any time. Any material changes will be reflected by updating the "Effective Date" at the top of this document. Where changes are significant, we may also notify registered users via email or an in-platform notification prior to the changes taking effect.

Your continued use of the Platform following the publication of any revised Policy constitutes your acceptance of those changes. We encourage you to review this Policy periodically to stay informed about how we protect your information. Archived versions of previous Privacy Policies are available upon request.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or your Personal Data held by fyrwin, please contact our Data Protection team using the details below:

Our support team is fully bilingual and available to assist you in both English and Bahasa Indonesia, serving players across Jakarta, Surabaya, Medan, Bandung, Bali, and the wider Indonesian archipelago.