Privacy Policy

Introduction

wing4 ("we", "us", "our", "the Company") is committed to protecting the privacy and personal data of every individual who accesses or uses our online gaming platform at https://wing4.cam ("Platform"). This Privacy Policy ("Policy") explains in plain terms what personal information wing4 collects, why we collect it, how we use and share it, how long we keep it, and what rights you hold over your own data.

This Policy applies to all users of the Platform, including registered account holders, visitors who browse without registering, and individuals who contact our customer support team. By creating an account or continuing to use the Platform, you confirm that you have read and understood this Policy and that you consent to the data practices described herein. If you do not agree, please discontinue use of the Platform immediately.

wing4 operates primarily for the Indonesian market. We design our data practices with the needs and expectations of Indonesian players in mind, including compatibility with local banking infrastructure (BCA, BRI, BNI, Mandiri) and popular digital payment services (OVO, DANA, GoPay, ShopeePay, LinkAja).

1. Definitions

• "Personal Data" — any information that identifies or could reasonably be used to identify a living individual, including name, national identity number, email address, IP address, and financial account details.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• "Controller" — wing4, the entity that determines the purposes and means of processing Personal Data.
• "Processor" — a third party that processes Personal Data on behalf of wing4, such as a payment service provider or KYC verification partner.
• "User" — any natural person who accesses the Platform, whether or not they hold a registered account.
• "KYC" — Know Your Customer; the identity verification process required prior to financial transactions.
• "Cookies" — small text files stored on your device by your browser that help us recognize you and remember your preferences.

2. Personal Data We Collect

wing4 collects several categories of Personal Data depending on how you interact with the Platform:

2.1 Identity and Contact Data

• Full legal name as it appears on government-issued identification
• Date of birth and age verification documents
• Indonesian national identity card (KTP) number or passport number
• Residential address in Indonesia
• Email address and mobile phone number
• Profile photograph (where submitted voluntarily)

2.2 Financial Data

• Bank account details for BCA, BRI, BNI, Mandiri, CIMB Niaga, and other supported institutions
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja
• Transaction histories including deposit amounts, withdrawal requests, and processing timestamps
• Source-of-funds declarations required for large or unusual transactions

2.3 Technical and Usage Data

• IP address, device type, operating system, and browser version
• Pages visited, session duration, click paths, and feature usage patterns
• Login timestamps and geographic location derived from IP
• Error logs and crash reports

2.4 Gaming Activity Data

• Bet history, wager amounts, and game results across all categories (sports betting, live casino, slot games, etc.)
• Bonus and promotion participation records
• Responsible gaming settings you have applied (deposit limits, self-exclusion records)

2.5 Communications Data

• Records of customer support conversations via live chat, email, or WhatsApp
• Feedback, complaints, and survey responses you submit voluntarily
• Marketing preference settings and consent records

3. How We Collect Your Data

We collect Personal Data through the following channels:

• Direct submission: information you provide when registering, completing KYC verification, making deposits or withdrawals, contacting support, or updating your Account profile.
• Automated technologies: cookies, web beacons, analytics scripts, and server logs that capture technical and usage data as you interact with the Platform.
• Third-party sources: identity verification partners (KYC providers), payment processors, fraud-prevention services, and publicly available databases used to cross-check the accuracy of your submitted information.
• Device permissions: if you access the Platform via a mobile browser and grant location or camera permissions, we may process that data solely to satisfy regulatory requirements.

4. Purposes of Processing

Purpose	Data Categories Used
Account creation and management	Identity, Contact
KYC and age verification	Identity, Financial
Processing deposits and withdrawals	Financial, Technical
Delivering gaming services and calculating outcomes	Gaming Activity, Technical
Fraud detection and anti-money laundering (AML) compliance	Identity, Financial, Technical
Customer support and dispute resolution	Identity, Communications, Gaming Activity
Responsible gaming monitoring and intervention	Gaming Activity, Financial, Communications
Marketing communications (with consent)	Identity, Contact, Gaming Activity
Platform performance analysis and improvement	Technical, Usage
Legal, regulatory, and tax compliance obligations	All categories as required

5. Legal Basis for Processing

We process your Personal Data under one or more of the following legal bases:

• Contractual necessity: processing required to perform our obligations under the Terms and Conditions you accepted when registering, such as processing deposits, settling bets, and paying out winnings.
• Legitimate interests: fraud detection, responsible gaming monitoring, security audits, and internal analytics that help us maintain a safe and reliable platform for all users.
• Legal obligation: KYC verification, AML reporting, and retention of financial records required by applicable regulations governing online gaming operators.
• Consent: sending you promotional emails, push notifications, or personalized bonus offers. You may withdraw consent at any time through your Account settings or by contacting support, without affecting the lawfulness of processing based on consent before withdrawal.

6. Data Sharing and Third-Party Disclosure

wing4 does not sell your Personal Data to third parties. We may, however, share your data with carefully vetted third parties where necessary to deliver our Services or meet legal obligations:

6.1 Service Providers (Processors)

We engage trusted processors who act strictly on our documented instructions, including payment gateway operators facilitating transactions through BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja; KYC and identity verification partners; gaming software providers including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, and Spribe; cloud hosting and infrastructure providers; customer support platform vendors; and cybersecurity and fraud-detection services. Each processor is bound by a data processing agreement that prohibits them from using your data for any purpose beyond delivering the specified service.

6.2 Legal and Regulatory Disclosure

We may disclose Personal Data to law enforcement authorities, regulatory bodies, or courts of competent jurisdiction where we are required to do so by applicable law, legal process, or to protect the rights, property, or safety of wing4, our users, or the public. We will notify you of any such disclosure where permitted by law.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of wing4's assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will provide notice before your Personal Data becomes subject to a materially different privacy policy and give you the opportunity to opt out where applicable law requires it.

6.4 No Sale of Personal Data

Under no circumstances will wing4 sell, rent, or lease your Personal Data to advertising networks, data brokers, or any other commercial third party for their independent marketing purposes.

7. Data Retention

We retain your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting obligations. The general retention periods wing4 applies are as follows:

• Account and identity data: retained for the duration of your active Account relationship with wing4, plus a minimum of five (5) years following Account closure to meet financial record-keeping obligations.
• Transaction and financial data: retained for a minimum of five (5) years from the date of the transaction, consistent with anti-money laundering record retention requirements.
• Gaming activity data: retained for three (3) years from the date of activity to support dispute resolution and responsible gaming monitoring.
• Customer support communications: retained for two (2) years from the close of the support case.
• Technical and usage data (logs): retained for ninety (90) days for security monitoring, then anonymized or deleted.
• Marketing consent records: retained until you withdraw consent and for a reasonable period thereafter to demonstrate compliance.

When Personal Data is no longer required for any of the above purposes, we securely delete or anonymize it so that it can no longer be associated with you.

8. Security Measures

wing4 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction:

• TLS/SSL encryption: all data transmitted between your browser and our servers is encrypted using industry-standard Transport Layer Security (TLS 1.2 or higher).
• Encryption at rest: sensitive Personal Data stored in our databases is encrypted using AES-256 encryption.
• Access controls: access to Personal Data within wing4 is restricted on a strict need-to-know basis. All staff with access undergo background checks and regular privacy training.
• Two-factor authentication (2FA): available to all users and mandatory for staff accounts accessing production systems.
• Regular security audits: we conduct periodic penetration testing, vulnerability assessments, and independent security audits of our platform infrastructure.
• Incident response: in the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users and relevant authorities promptly in accordance with applicable regulations.

9. Your Data Rights

As a user of wing4's Platform, you hold the following rights in relation to your Personal Data. We will respond to all verified requests within thirty (30) days:

• Right of access: you may request a copy of the Personal Data we hold about you, along with information about how it is being processed.
• Right to rectification: if any Personal Data we hold is inaccurate or incomplete, you have the right to request correction or completion. For basic profile data, you can update this directly within your Account settings.
• Right to erasure: you may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to any overriding legal obligation that requires us to retain it (for example, AML record-keeping requirements).
• Right to restrict processing: you may request that we limit the processing of your Personal Data while a dispute regarding its accuracy or lawfulness is resolved.
• Right to data portability: where processing is based on your consent or contractual necessity and carried out by automated means, you may request your Personal Data in a structured, commonly used, machine-readable format.
• Right to object: you may object to processing carried out on the basis of legitimate interests, including profiling for direct marketing purposes. We will honor such requests unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact our Privacy Team at [email protected] with the subject line "Data Rights Request". We may ask you to verify your identity before processing the request to protect your data from unauthorized disclosure.

10. Cookies and Tracking Technologies

wing4 uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, analyze usage patterns, and deliver a personalized experience. The categories of cookies we use are as follows:

10.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be disabled. They include session authentication tokens, security tokens, load-balancing cookies, and cookies that remember your language and regional settings. No consent is required for these cookies as they are essential to service delivery.

10.2 Performance and Analytics Cookies

These cookies collect anonymized information about how visitors use the Platform — which pages are visited most frequently, where users encounter errors, and how navigation flows perform. This data helps us continuously improve the Platform. These cookies do not identify individual users.

10.3 Functional Cookies

These cookies remember choices you make — such as your preferred deposit method or notification settings — to provide a more convenient and personalized experience on subsequent visits.

10.4 Managing Cookies

You can control cookie behavior through your browser settings. Most browsers allow you to block all cookies, accept only first-party cookies, or receive a prompt before any cookie is stored. Note that disabling strictly necessary cookies will impair core Platform functionality, including the ability to log in and maintain a session. For further guidance on managing cookies in popular browsers, consult your browser's help documentation.

11. Protection of Minors

wing4's Platform and Services are strictly intended for adults aged 21 and above. We do not knowingly collect, solicit, or retain Personal Data from individuals under the age of 21. Our registration process includes mandatory age verification, and we reserve the right to request additional documentary proof of age at any time.

If you are a parent or guardian and believe that your child has provided Personal Data to wing4 without your consent, please contact us immediately at [email protected]. We will investigate the matter promptly, delete any data associated with the minor's account, and close the account without delay.

12. Changes to This Policy

wing4 reserves the right to update or amend this Privacy Policy at any time. We will notify registered users of material changes by email or through a prominent notice on the Platform at least seven (7) days before the revised Policy takes effect. The "Last Updated" date at the top of this page will always reflect the most recent revision.

Your continued use of the Platform after the effective date of any changes constitutes your acknowledgment and acceptance of the updated Policy. If you disagree with any revision, you should discontinue use of the Platform and may request Account closure by contacting our support team.

13. Contact Information

For all privacy-related inquiries, requests to exercise your data rights, or concerns about how wing4 handles your Personal Data, please reach out to us through the channels below. All communications must be directed through the Platform's registered contact points — do not share sensitive personal data through unverified channels:

• Privacy Inquiries Email: [email protected] (subject line: "Privacy Inquiry")
• Data Rights Requests: [email protected] (subject line: "Data Rights Request")
• Live Chat: available 24/7 via your Account dashboard
• WhatsApp Support: available daily 08:00 – 24:00 WIB

We aim to acknowledge all privacy-related correspondence within 48 hours and to provide a substantive response within 30 calendar days. For complex requests that require additional time, we will inform you of the extended timeline and the reason for the delay.