Privacy Policy

1 Definitions

The following terms carry the meanings set out below throughout this Privacy Policy:

• "dwmo" / "we" / "us" / "our" — the online gaming platform operated at https://dwmo.cam.
• "Platform" — the dwmo website, mobile interface, and all associated applications and services.
• "Player" / "User" / "you" — any individual who accesses, visits, or uses the Platform.
• "Personal Data" — any information that identifies or can reasonably be used to identify a natural person, including name, email address, device identifiers, and financial data.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data; in this context, dwmo.
• "Data Processor" — any third party that processes Personal Data on behalf of dwmo under a contractual arrangement.
• "KYC" — Know Your Customer identity verification procedures required before withdrawals and at other account activity thresholds.
• "Cookie" — a small text file placed on your device by the Platform to enable functionality, analytics, or personalisation.

2 Data Controller

dwmo acts as the Data Controller for all Personal Data collected through the Platform. As Data Controller, dwmo determines the purposes for which and the means by which Personal Data is processed, and assumes responsibility for ensuring that such processing complies with applicable data protection laws.

For all privacy-related enquiries, data subject access requests, or complaints, please contact our Data Protection team:

• Email: [email protected]
• Subject line: "Privacy / Data Protection Request"
• Response time: Within 30 calendar days of receipt

3 Data We Collect

dwmo collects Personal Data across several categories depending on how you interact with the Platform. The table below summarises the primary data categories, specific data points, and the context in which each is collected:

3.1 Data You Provide Directly

The majority of Personal Data we hold is provided directly by you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or respond to a survey or promotion.

3.2 Data Collected Automatically

When you access the Platform, certain technical and usage data is collected automatically through server logs, cookies, and similar technologies. This data helps us maintain Platform security, diagnose technical issues, and understand how players navigate the site so we can improve their experience.

3.3 Data from Third Parties

In limited circumstances, dwmo may receive Personal Data about you from third parties, including identity verification service providers used during KYC, fraud prevention and anti-money laundering screening agencies, and payment processors facilitating your deposits and withdrawals.

4 Legal Basis for Processing

dwmo processes your Personal Data on one or more of the following legal bases:

• Contract performance: Processing necessary to operate your account, process your transactions, and deliver the gaming services you have requested — including verifying your identity, crediting winnings, and resolving disputes.
• Legal obligation: Processing required to comply with applicable anti-money laundering (AML) regulations, know-your-customer (KYC) requirements, tax reporting obligations, and lawful orders from competent authorities.
• Legitimate interests: Processing carried out to pursue dwmo's legitimate business interests, including fraud prevention, Platform security monitoring, responsible gaming programme management, and internal analytics — provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we rely on your consent — for example, for optional marketing communications — we will seek that consent explicitly and separately. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 How We Use Your Data

dwmo uses your Personal Data for the following purposes:

5.1 Account Management

To create and maintain your player account, authenticate your identity at login, manage your preferences and account settings, and communicate important account-related updates such as password resets, security alerts, and policy changes.

5.2 Transaction Processing

To process deposits and withdrawals in IDR via your chosen local bank (BCA, BRI, BNI, Mandiri, CIMB Niaga) or e-wallet (OVO, DANA, GoPay, ShopeePay), verify payment method ownership, and maintain accurate financial records for audit and regulatory purposes.

5.3 Identity Verification & Compliance

To fulfil our KYC obligations, conduct AML screening, verify that all players are at least 21 years of age, and comply with any lawful regulatory or law enforcement requests received by dwmo.

5.4 Responsible Gaming

To monitor gaming activity for signs of problem gambling, enforce deposit limits, cooling-off periods, and self-exclusions requested by players, and to flag accounts that may benefit from proactive responsible gaming outreach.

5.5 Platform Security & Fraud Prevention

To detect, investigate, and prevent fraudulent activity, account takeover attempts, bonus abuse, money laundering, and any other activity that violates our Terms & Conditions or applicable law. Technical and usage data plays a central role in our security monitoring systems.

5.6 Customer Support

To respond to your enquiries, resolve disputes, and improve the quality and efficiency of our support operations. Support interactions may be recorded and retained for quality assurance and training purposes.

5.7 Analytics & Platform Improvement

To understand how players use the Platform, identify performance bottlenecks, test new features, and make data-driven improvements to the overall user experience. Where possible, analytics are conducted on aggregated or anonymised datasets.

5.8 Marketing Communications

Where you have given explicit consent, to send you promotional offers, seasonal bonuses (such as Ramadhan specials or Indonesian Independence Day promotions), and newsletters relevant to your gaming interests. You may opt out of marketing communications at any time by emailing [email protected] with the subject line "Unsubscribe".

6 Data Sharing & Disclosure

dwmo does not sell, rent, or trade your Personal Data. We share data only in the following limited circumstances:

• Service Providers (Data Processors): We engage trusted third-party companies to perform services on our behalf, including payment processing, identity verification, cloud hosting, fraud detection, and customer support platform operation. These processors are contractually bound to process your data only on our instructions and to maintain appropriate security standards.
• Regulatory & Law Enforcement Bodies: Where required by applicable law or in response to a valid legal request from a competent authority, dwmo will disclose Personal Data to the extent strictly necessary to comply with that obligation.
• Anti-Money Laundering & Fraud Agencies: We may share data with licensed AML screening services and cross-industry fraud prevention networks to protect all players and the integrity of the Platform.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of dwmo's assets, your Personal Data may be transferred to the successor entity. We will provide reasonable advance notice of any such transfer and the privacy terms that will apply thereafter.
• With Your Explicit Consent: In circumstances not described above, we will share your Personal Data with third parties only where you have provided clear, informed, and freely given consent.

7 Data Retention

dwmo retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Anonymised datasets may be retained indefinitely for statistical and research purposes.

8 Security Measures

dwmo implements a multi-layered security framework to protect your Personal Data against unauthorised access, accidental loss, destruction, or alteration. Key measures include:

• Transport Security: All data transmitted between your browser or app and dwmo servers is encrypted using TLS 1.3 with forward secrecy.
• Storage Encryption: Personal Data and financial records stored on our servers are encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data within dwmo is restricted on a strict need-to-know basis. Staff members who require access for legitimate operational reasons are subject to background checks and confidentiality obligations.
• Two-Factor Authentication: Player accounts support two-factor authentication (2FA) to reduce the risk of unauthorised access resulting from compromised credentials.
• Penetration Testing: dwmo engages independent security professionals to conduct regular penetration tests and vulnerability assessments of the Platform infrastructure.
• Incident Response: In the event of a confirmed personal data breach that is likely to result in risk to affected individuals, dwmo will notify the relevant supervisory authority and affected players within the timeframes prescribed by applicable law.

9 Cookies & Tracking Technologies

dwmo uses cookies and similar tracking technologies (including local storage objects and session tokens) to operate the Platform effectively. The following cookie categories are in use:

• Strictly Necessary Cookies: Essential for core Platform functionality including session management, login authentication, and security token handling. These cannot be disabled without disrupting Platform operation.
• Functional Cookies: Used to remember your preferences such as language settings, display options, and your most recently used payment method, so we can provide a personalised experience on your return visits.
• Analytics Cookies: Used to collect aggregated information about how players navigate the Platform, which pages are most visited, and where errors occur. This data is used solely to improve Platform performance and user experience.
• Security Cookies: Support our fraud detection and account security systems by tracking unusual access patterns and flagging potentially compromised sessions.

You can manage cookie preferences through your browser settings. Blocking strictly necessary cookies may impair your ability to use the Platform. Blocking analytics or functional cookies will not prevent you from accessing core services but may reduce personalisation features.

dwmo does not use third-party advertising cookies or behavioural advertising trackers that share your data with external ad networks.

10 Your Data Rights

Depending on applicable law and the specific circumstances of your request, you may exercise the following rights in relation to your Personal Data held by dwmo:

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data. For basic account details, you can update many fields directly within your account settings.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations. Note that certain data must be retained for regulatory compliance even after account closure.
• Right to Restriction: You may request that we restrict processing of your Personal Data in certain circumstances — for example, while the accuracy of data you have contested is being verified.
• Right to Data Portability: Where processing is based on consent or contract performance and is carried out by automated means, you may request a structured, machine-readable copy of your Personal Data.
• Right to Object: You may object to processing based on legitimate interests, including any direct marketing communications. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 5 business days and respond in full within 30 calendar days. In complex cases, the response period may be extended by a further 60 days, in which case we will inform you of the extension and the reason for it.

11 Minors & Age Policy

The dwmo Platform is strictly intended for adults aged 21 and over. We do not knowingly collect Personal Data from individuals under the age of 21. Age verification is a mandatory component of our KYC process, and accounts found to belong to persons under 21 will be suspended immediately, with all balances returned to the verified payment source after investigation.

If you believe that a minor has registered on the Platform or that Personal Data of a person under 21 has been inadvertently collected, please notify us immediately at [email protected]. We will investigate and take prompt action to delete any such data.

12 International Data Transfers

dwmo operates globally and may transfer your Personal Data to servers and service providers located outside of Indonesia. Wherever such transfers occur, we take steps to ensure that your data receives an equivalent level of protection to that afforded within Indonesia, including by:

• Entering into data processing agreements with all Data Processors that incorporate recognised standard contractual clauses or equivalent safeguards.
• Transferring data only to jurisdictions that maintain an adequate level of data protection as recognised by relevant international standards.
• Applying additional technical and organisational safeguards — including encryption and pseudonymisation — where transfers involve higher-risk data categories.

By using the Platform, you acknowledge that your Personal Data may be transferred to, stored in, and processed in countries outside Indonesia, and you consent to such transfers taking place under the safeguards described above.

13 Third-Party Services

The Platform may integrate with or reference third-party services whose privacy practices are governed by their own policies and are outside dwmo's control. These may include:

• Payment Processors: Banks such as BCA, BRI, BNI, and Mandiri, and e-wallet providers including GoPay, OVO, DANA, ShopeePay, and LinkAja, each of which operates under its own privacy and data-handling framework.
• Game Studios: Live casino and slot game providers such as Evolution Gaming, Pragmatic Play, Microgaming, Spribe, and Pocket Games Soft may collect limited technical data necessary to deliver their games. Their data practices are governed by their own privacy policies.
• Identity Verification Providers: Third-party KYC platforms used to verify identity documents may process a subset of your identity data on our behalf under strict contractual controls.

dwmo is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party service with which you interact in connection with your use of the Platform.

14 Policy Amendments

dwmo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the scope of our services. When material changes are made, we will:

• Publish the revised Policy on this page with an updated "Last Updated" date at the top.
• Notify registered players by email or in-platform notification at least 7 days before the changes take effect, where reasonably practicable.
• In cases of significant changes that affect your rights or the legal basis for processing, request fresh consent where required by law.

Your continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Privacy Policy. We recommend reviewing this page periodically to stay informed of how dwmo protects your data.

15 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or your Personal Data, please contact the dwmo Data Protection team:

• Email: [email protected] (plain text — not a clickable link)
• Subject line: "Privacy / Data Protection Request"
• Response time: Acknowledgement within 5 business days; full response within 30 calendar days
• Support hours: 24 hours a day, 7 days a week, including Indonesian public holidays (WIB)

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the relevant data protection supervisory authority in the jurisdiction governing dwmo's operations. We will provide details of the applicable authority upon request.