Privacy Policy — wak189 Data Protection Commitment

Definitions

The following defined terms are used throughout this Privacy Policy. Familiarity with these definitions will help you understand precisely how your personal data is handled by wak189.

• "Company", "we", "us", or "our" refers to wak189, the operator of the online gaming platform accessible at wak189.app.
• "Member", "you", or "your" refers to any natural person who has registered an account on the wak189 Platform, or who accesses the Platform without registration.
• "Platform" means the wak189 website at wak189.app and all associated subdomains, mobile-optimized pages, and game interfaces operated by the Company.
• "Personal Data" means any information that identifies or could reasonably be used to identify you as a natural person, including your name, date of birth, email address, Indonesian mobile number, national identity number, bank account details, IP address, and device identifiers.
• "Special Category Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data used for unique identification, health data, or data concerning a person's sex life or sexual orientation. wak189 does not intentionally collect Special Category Data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, and destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, wak189.
• "Data Processor" means any third party that processes Personal Data on behalf of wak189 under a written data processing agreement, such as our payment gateway providers, KYC verification service, and cloud hosting provider.
• "Cookies" means small text files placed on your device by the Platform to store session information and usage preferences.
• "KYC" means Know Your Customer — the identity and document verification process required before a Member's first withdrawal is processed.

Data Controller

wak189 acts as the Data Controller for all Personal Data collected through the Platform. As Data Controller, wak189 determines the purposes for which your Personal Data is processed and takes responsibility for ensuring that Processing is carried out lawfully, fairly, and transparently in accordance with this Privacy Policy and applicable international data protection standards.

Where wak189 engages third-party service providers to process Personal Data on its behalf — for example, payment processors, identity verification providers, and cloud infrastructure services — those providers act as Data Processors and are bound by written agreements that require them to process your data only on wak189's instructions, to maintain appropriate security measures, and not to use your data for any independent purpose.

Personal Data We Collect

wak189 collects the following categories of Personal Data about you. The specific data collected depends on the nature of your interaction with the Platform:

How We Collect Your Data

wak189 collects Personal Data through the following channels and mechanisms:

• Direct Submission: Data you provide voluntarily when registering an Account, completing the KYC verification process, submitting a deposit or withdrawal request, contacting customer support, or responding to surveys or promotions.
• Automated Technical Collection: Data collected automatically when you visit the Platform, including your IP address, device identifiers, browser fingerprint, and session behavior, via server logs, cookies, and similar tracking technologies. See Clause 10 for full details on our cookie use.
• Payment Processors: Transaction confirmation data returned by our payment gateway partners following a successful deposit or withdrawal. This includes transaction reference numbers, amounts, timestamps, and payment method identifiers — but never raw card numbers.
• KYC Verification Providers: Verification status and risk-scoring data returned by our third-party KYC service provider following document verification checks.
• Fraud Prevention Services: Device risk scores and fraud signals from our anti-fraud technology partners, used to protect the integrity of the Platform and the security of Members' accounts.
• Game Providers: Anonymized session and outcome data shared by our licensed game providers (Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft, NetEnt, Microgaming) for the purposes of dispute resolution and responsible gaming monitoring.

Legal Basis for Processing

wak189 processes your Personal Data on one or more of the following lawful bases, consistent with internationally recognized data protection principles:

• Contractual Necessity: Processing that is necessary to perform the contract between you and wak189 — specifically, to create and manage your Account, process deposits and withdrawals, provide access to games, and deliver customer support.
• Legal Obligation: Processing that wak189 is required to carry out in order to comply with applicable legal obligations, including anti-money laundering (AML) checks, KYC identity verification, and the retention of financial transaction records.
• Legitimate Interests: Processing that is necessary for wak189's legitimate business interests, provided those interests are not overridden by your rights and interests. This includes fraud detection and prevention, platform security, IT system maintenance, business analytics, and improving our product and service offering.
• Consent: Where wak189 relies on your consent as the legal basis for processing — specifically for sending you promotional communications and marketing messages — you may withdraw that consent at any time by updating your communication preferences within your Account settings or by contacting our support team. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Purposes of Processing

wak189 uses your Personal Data for the following specific purposes, each of which is matched to a lawful basis set out in Clause 5:

• Account Creation and Management: To create your Member account, maintain accurate account records, process changes to your account details, and provide you with access to the full range of wak189 products. (Contractual Necessity)
• Payment Processing: To process your deposit and withdrawal requests via your chosen Payment Method, including Indonesian local banks such as BCA, BRI, BNI, and Mandiri, e-wallets such as OVO, DANA, GoPay, ShopeePay, and LinkAja, and cryptocurrency networks including USDT TRC-20, Bitcoin, and Ethereum. (Contractual Necessity)
• Identity Verification (KYC): To verify your identity and age prior to processing your first withdrawal, as required by our international licensing obligations and AML compliance framework. (Legal Obligation)
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, bonus abuse, and other prohibited conduct as defined in our Terms & Conditions. (Legitimate Interests / Legal Obligation)
• Customer Support: To respond to your inquiries, complaints, and support requests submitted via live chat, email, or any other supported channel. (Contractual Necessity)
• Responsible Gaming Monitoring: To proactively identify behavioral patterns that may indicate problem gambling, and to deliver timely interventions, self-help tools, or support resources in accordance with our Responsible Gaming commitments. (Legitimate Interests / Legal Obligation)
• Platform Improvement: To analyze aggregated usage patterns, game performance, and Member feedback to improve the usability, stability, and content offering of the Platform. (Legitimate Interests)
• Promotional Communications: To send you bonus offers, tournament announcements, and platform news via email or SMS, where you have opted in to receive such communications. (Consent)
• Legal Compliance: To comply with court orders, regulatory requests, subpoenas, or other legally mandated disclosures. (Legal Obligation)

Data Sharing

wak189 does not sell your Personal Data. We share Personal Data only in the following limited and controlled circumstances:

• Payment Processors: We share the minimum necessary financial and identity data with our payment gateway partners to facilitate deposits and withdrawals. These partners operate under written data processing agreements and are bound by PCI-DSS and equivalent security standards.
• KYC and Identity Verification Providers: We share your identity documents and personal details with our certified KYC verification partner solely for the purpose of verifying your identity and age before your first withdrawal is released.
• Game Providers: Your Member account identifier and session data are shared with our licensed third-party game providers (including Pragmatic Play, Evolution Gaming, and Spribe) to the extent necessary to deliver and maintain their game content on the Platform. These providers do not receive your full identity or financial data.
• Fraud Prevention and AML Services: We share device and behavioral data with our fraud intelligence and AML screening partners to protect the Platform against financial crime. These providers process data strictly on our instructions.
• Cloud Infrastructure Providers: Our Platform data, including Personal Data, is hosted on secure cloud servers operated by enterprise infrastructure providers. These providers act as Data Processors and have no independent right to use your data.
• Legal and Regulatory Authorities: We will disclose Personal Data to law enforcement agencies, regulatory bodies, or courts when required to do so by applicable law, a valid court order, or a regulatory mandate. Where legally permissible, we will notify you of such a disclosure.
• Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of all or part of the Company's business assets, your Personal Data may be transferred to the acquiring or merged entity. You will be notified of any such transfer and of any resulting change to this Privacy Policy in advance.

Data Retention

wak189 retains your Personal Data only for as long as is necessary to fulfill the purposes set out in this Privacy Policy, or as required by applicable law. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your active membership plus a minimum of five (5) years following account closure, in compliance with international AML record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by applicable financial regulations.
• KYC Verification Documents: Retained for a minimum of five (5) years following successful verification or account closure, whichever is later.
• Customer Support Communications: Retained for a minimum of two (2) years from the date of the last communication in a support thread, to enable effective dispute resolution.
• Technical and Usage Data: Retained in identifiable form for a maximum of thirteen (13) months, after which it is aggregated and anonymized for statistical analysis purposes.
• Marketing Preferences and Consent Records: Retained for the duration of your membership, and for a further three (3) years following account closure, to demonstrate consent compliance.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized in accordance with wak189's data destruction policy. Anonymized data may be retained indefinitely for statistical and product development purposes, as it can no longer be used to identify you.

Data Security

wak189 implements a comprehensive suite of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your device and the wak189 Platform is encrypted using TLS 1.2 or higher. The Platform enforces HTTPS across all pages and does not fall back to unencrypted HTTP connections.
• Encryption at Rest: All Personal Data stored on wak189 servers — including identity documents, financial records, and account credentials — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data is restricted to authorized wak189 personnel on a strict need-to-know basis. All staff with access to Personal Data undergo background screening and are bound by confidentiality obligations. Access is controlled via role-based permissions and multi-factor authentication.
• Password Security: Member passwords are stored as salted cryptographic hashes. wak189 staff cannot view your password in plaintext at any time. If you suspect your password has been compromised, please change it immediately via your Account settings.
• Infrastructure Security: The Platform is hosted on enterprise-grade cloud infrastructure with dedicated firewall protection, intrusion detection systems, and regular third-party penetration testing.
• Incident Response: wak189 maintains a documented data breach response procedure. In the event of a Personal Data breach that poses a risk to your rights and freedoms, wak189 will notify affected Members without undue delay and will take all reasonable steps to mitigate the impact of the breach.

Cookies & Tracking Technologies

wak189 uses cookies and similar technologies on the Platform. This clause explains what cookies we use, why we use them, and how you can manage your cookie preferences.

wak189 does not use third-party advertising or cross-site tracking cookies. You will not be tracked across other websites for the purpose of serving you targeted advertisements based on your wak189 activity.

You can manage or delete cookies at any time via your browser settings. Please note that disabling Strictly Necessary cookies will prevent you from logging in to your wak189 Account. For detailed instructions on managing cookies in your specific browser, refer to your browser's official help documentation.

Your Rights

wak189 respects your rights over your Personal Data. As a Member, you are entitled to exercise the following rights at any time:

• Right of Access: You may request a copy of all Personal Data that wak189 holds about you, including the categories of data, the purposes for which it is processed, and the third parties to whom it has been disclosed. We will respond to access requests within 30 days.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data held on your Account. For standard contact and address updates, you may make changes directly in your Account settings. For identity and KYC data corrections, please contact our support team.
• Right to Erasure ("Right to Be Forgotten"): You may request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where processing is unlawful. Note that wak189 is required by law to retain certain financial and identity records for a minimum of five years following account closure; this legal obligation takes precedence over erasure requests in respect of those specific data points.
• Right to Restriction of Processing: You may request that wak189 restrict the processing of your Personal Data in certain circumstances — for example, while the accuracy of data is being verified, or where you have objected to processing based on legitimate interests.
• Right to Data Portability: You may request a machine-readable copy of the Personal Data you have provided to wak189, in a structured, commonly used format (CSV or JSON), to allow transfer to another service provider where technically feasible.
• Right to Object: You may object to the processing of your Personal Data where it is based on wak189's legitimate interests. You may also object at any time to the use of your data for direct marketing purposes, with immediate effect.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

Minors

The wak189 Platform is strictly intended for adults aged 21 years and older. wak189 does not knowingly collect Personal Data from any person under the age of 21. This age threshold applies specifically to our primary market, Indonesia, in accordance with locally recognized standards for adult entertainment services.

If wak189 becomes aware that Personal Data has been collected from a person under the age of 21 — whether through the registration process, KYC verification, or any other means — the following actions will be taken immediately:

• The relevant Account will be closed without notice.
• All Personal Data associated with the underage registration will be permanently deleted from our systems, except where retention is required by law.
• Any funds deposited by the underage individual will be returned via the original deposit method, subject to identity verification of the account holder.

Parents and legal guardians who believe their child may have accessed the wak189 Platform are urged to contact our support team immediately at support at wak189.app so that the matter can be investigated and resolved without delay. wak189 takes its 21+ obligation seriously and employs automated age verification checks at the point of registration as a first line of defense.

International Data Transfers

wak189 operates on a globally distributed cloud infrastructure. As a result, your Personal Data may be processed and stored on servers located outside Indonesia. When we transfer Personal Data internationally, we ensure that appropriate safeguards are in place to maintain a level of data protection equivalent to internationally recognized standards. These safeguards include:

• Contractual clauses that obligate the receiving party to process your data in accordance with data protection standards consistent with GDPR principles and comparable international frameworks.
• Transfers only to countries or infrastructure providers that maintain demonstrably high technical and organizational security standards, including ISO 27001-certified data centers.
• Written data processing agreements with all third-party processors, regardless of their country of operation, that explicitly restrict the use of your data to the purposes specified by wak189.

By registering an Account on the wak189 Platform, you acknowledge that your Personal Data may be transferred, stored, and processed internationally as described in this clause, subject always to the protections described above.

Third-Party Links

The wak189 Platform may, from time to time, contain references to or integrations with third-party services — for example, the game interfaces provided by our licensed game studio partners. While wak189 carefully vets all game providers it works with, once you interact with a third-party game interface, you may be subject to that provider's own privacy practices in respect of the data processed within their gaming environment.

wak189 is not responsible for the privacy practices of third-party service providers operating within the Platform, and this Privacy Policy does not govern the data collection activities of those third parties beyond what is described in Clause 7 (Data Sharing). We encourage you to review the privacy policies of any third-party game studios whose games you play if you have concerns about how those parties handle your data.

Changes to This Privacy Policy

wak189 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, our service offering, or our technology infrastructure. When material changes are made — meaning changes that significantly affect how your Personal Data is processed or your rights as a data subject — wak189 will:

• Publish a notice on the Platform homepage at least seven (7) days before the revised Policy takes effect.
• Where practicable, send an email notification to your registered email address summarizing the key changes.
• Update the "Last Updated" date at the top of this Privacy Policy to reflect the date of the most recent revision.

Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must cease using the Platform and request Account closure prior to the effective date of the change. The most current version of this Privacy Policy will always be accessible at wak189.app/privacy-policy.

Contact Us

For any questions, concerns, or formal requests relating to this Privacy Policy or the processing of your Personal Data by wak189, please contact our privacy and compliance team through the following channels:

If you feel that your data protection rights have not been adequately respected by wak189, you have the right to raise a complaint with a relevant data protection supervisory authority in your jurisdiction. wak189 nonetheless encourages Members to contact us directly in the first instance, as we are committed to resolving all privacy concerns promptly and transparently.