Privacy Policy — pbowin

1 Introduction & Scope

1.1 This Privacy Policy ("Policy") is published by pbowin and governs the collection, use, storage, disclosure, and protection of personal data submitted by or generated from users ("Members") of the pbowin online betting platform, accessible at pbowin.cam ("Platform").

1.2 This Policy applies to all personal data processed in connection with Member registration, account management, financial transactions, use of betting and gaming services (including sports betting, live casino, togel (Indonesia's traditional numbers lottery), and slot gacor (high-RTP slot games)), customer support interactions, and Platform analytics.

1.3 By registering an account on pbowin or continuing to use the Platform after this Policy has been updated, you acknowledge that you have read, understood, and consented to the practices described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately and contact our support team to close your account.

1.4 This Policy should be read together with pbowin's Terms & Conditions, which govern your overall use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions regarding data matters, this Policy shall prevail.

2 Data Controller

2.1 For the purposes of this Policy, pbowin acts as the data controller in respect of all personal data collected from Members. This means pbowin determines the purposes for which your personal data is processed and the manner in which it is processed.

2.2 All data-related inquiries, access requests, correction requests, and deletion requests should be directed in writing to:

pbowin will acknowledge all data-related requests within five (5) business days and will endeavor to resolve them fully within thirty (30) calendar days of receipt.

3 Data We Collect

3.1 pbowin collects the following categories of personal data from Members:

3.2 pbowin does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data (other than where required for KYC), or health data, unless specifically required by applicable anti-money laundering (AML) regulations or responsible gaming procedures.

4 How We Collect Your Data

pbowin collects personal data through the following channels:

• Direct submission: data you provide when registering, completing KYC verification, making a deposit or withdrawal request, or contacting our support team;
• Automated collection: technical and usage data collected automatically via cookies, server logs, and analytics tools when you access or interact with the Platform;
• Third-party sources: identity verification data received from KYC service providers; fraud-screening data from payment processors; and publicly available information used to validate account details where required by AML procedures.

5 Purposes of Processing

5.1 pbowin processes your personal data for the following specific purposes:

5.2 pbowin will not process your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

6 Legal Basis for Processing

6.1 pbowin processes your personal data on the following legal grounds:

• Contractual necessity: processing your identity data, contact data, and financial data is necessary to perform the contract between you and pbowin (as set out in our Terms & Conditions) — specifically, to register your account, process your transactions, and deliver the Services you have requested;
• Legal obligation: processing data for KYC verification, AML screening, and retention of transaction records is required to comply with applicable international regulatory obligations;
• Legitimate interests: processing technical and usage data for fraud prevention, platform security, and product improvement serves pbowin's legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms;
• Consent: processing your data for marketing communications is based on your freely given, specific, and informed consent at the point of registration or through your account settings. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7 Data Sharing & Disclosure

7.1 pbowin does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your personal data only in the following limited circumstances:

• KYC and identity verification providers: trusted third-party identity verification services that assist us in confirming the age and identity of Members as required by AML obligations. These providers are contractually bound to process your data solely for verification purposes and may not use it for any other purpose;
• Payment processors and banking partners: local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to the extent necessary to process your deposit and withdrawal transactions;
• Game content providers: third-party game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive a session token and anonymized player identifier to initialize game sessions. These providers do not receive your full name, address, or financial details;
• IT infrastructure and hosting providers: cloud hosting, data storage, and cybersecurity service providers that support the operation of the Platform, all of whom are bound by data processing agreements with pbowin;
• Legal and regulatory authorities: where pbowin is required by law, court order, or formal regulatory request to disclose Member data to a competent authority. pbowin will, where legally permitted, notify the affected Member before complying with such a request;
• Business transfers: in the event that pbowin undergoes a merger, acquisition, or sale of all or substantially all of its assets, Member data may be transferred to the acquiring entity, subject to equivalent privacy protections remaining in place.

8 Data Retention

8.1 pbowin retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Our standard retention periods are as follows:

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with an identifiable individual. Anonymized, aggregated data may be retained indefinitely for statistical and analytical purposes.

9 Cookies & Tracking Technologies

9.1 pbowin uses cookies and similar technologies (including local storage, session tokens, and browser fingerprinting) to support the operation and improvement of the Platform. The types of cookies we use are as follows:

• Strictly necessary cookies: essential for the Platform to function correctly — including session management, login state persistence, and security tokens. These cannot be disabled without breaking the Platform;
• Functional cookies: remember your preferences, such as your preferred language, odds format, and default betting view, to personalize your experience on return visits;
• Analytics cookies: collect aggregated, anonymized data about how Members use the Platform — including pages visited, time on page, and navigation paths — to help us improve the user experience. We use only privacy-respecting analytics tools with IP anonymization enabled;
• Security cookies: detect unusual login activity, prevent cross-site request forgery (CSRF), and support our fraud prevention systems.

9.2 pbowin does not use third-party advertising cookies or retargeting pixels. We do not share cookie data with external advertising networks.

9.3 You may control or delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies may prevent certain features of the Platform from functioning correctly. For detailed guidance on managing cookies, refer to your browser's help documentation.

10 Data Security

10.1 pbowin implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data in transit between your browser and our servers;
• AES-256 encryption for sensitive data stored at rest, including financial credentials and identity documents;
• Role-based access controls (RBAC) ensuring that only authorized pbowin personnel with a documented business need can access Member data;
• Multi-factor authentication (MFA) required for all internal administrative access to systems containing Member data;
• Regular penetration testing and vulnerability scanning conducted by independent third-party security specialists;
• 24/7 intrusion detection systems (IDS) monitoring platform infrastructure for anomalous activity;
• Secure data center facilities with physical access controls, CCTV monitoring, and redundant power and connectivity.

10.2 In the event of a data breach that is likely to result in a risk to Member rights and freedoms, pbowin will notify affected Members without undue delay and will take all reasonable steps to contain, investigate, and remediate the breach.

10.3 While pbowin maintains robust security measures, no system is completely immune to security incidents. You are responsible for maintaining the security of your own account credentials. pbowin recommends using a strong, unique password for your pbowin account and enabling any available two-factor authentication (2FA) features.

11 Your Data Rights

11.1 As a Member of pbowin, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us in writing at [email protected] with the subject line "Data Privacy Request":

11.2 pbowin will respond to all data rights requests within thirty (30) calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.

11.3 Please note that certain rights — particularly the right to erasure — are subject to override where pbowin is required to retain data to comply with a legal obligation (for example, AML record-keeping requirements). In such cases, pbowin will clearly explain which data must be retained and on what legal basis.

12 Third-Party Links

12.1 The pbowin Platform may contain references to or integrations with third-party game studios and payment providers. While pbowin takes care to work only with reputable partners, we are not responsible for the privacy practices of third-party websites or services that operate independently of the pbowin Platform.

12.2 If you navigate away from the pbowin Platform to a third-party service, we strongly encourage you to review the privacy policy of that service before submitting any personal data. pbowin's Privacy Policy applies exclusively to data processed within the pbowin Platform.

13 Children's Privacy

13.1 The pbowin Platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. If pbowin becomes aware that a Member account has been registered by a person under 21 years of age, the account will be immediately suspended and all personal data associated with it will be securely deleted, with any deposited funds returned to the originating payment method.

13.2 If you are a parent or guardian and have reason to believe that a person under 21 in your care has registered an account with pbowin, please contact us immediately at [email protected]. We will act swiftly to investigate and close the account.

14 Changes to This Policy

14.1 pbowin reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. The updated Policy will be published on this page with a revised "Last Updated" date at the top of the document.

14.2 For material changes — meaning changes that significantly affect how we process your personal data or that alter your rights as a data subject — pbowin will provide advance notice via email to your registered address, or via a prominent notification within the Platform, at least fourteen (14) days before the changes take effect.

14.3 Your continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you must stop using the Platform and request account closure before the changes take effect.

15 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or pbowin's data processing practices, please reach out to our dedicated support team using the contact details below. All privacy-related correspondence should be submitted in English or Indonesian.

pbowin's support team includes Indonesian-speaking data privacy staff available 24 hours a day, seven days a week. We are committed to handling all privacy inquiries with the seriousness, discretion, and speed that your personal data deserves.