Privacy Policy

The following defined terms apply throughout this Privacy Policy:

• "ugdewa" / "we" / "us" / "our" — the platform accessible at https://ugdewa.cam and the entity responsible for the processing of personal data described herein.
• "Player" / "User" / "you" / "your" — any individual who accesses, registers on, or uses any service offered through the ugdewa platform.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, date of birth, national identity number, financial data, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For this policy, the Data Controller is ugdewa.
• "Data Processor" — any third party that processes Personal Data on behalf of ugdewa under a written agreement and in accordance with ugdewa's instructions.
• "Consent" — freely given, specific, informed, and unambiguous agreement to the processing of Personal Data for one or more specified purposes.
• "KYC" — Know Your Customer; the identity and document verification process applied to Player accounts.
• "Cookie" — a small data file placed on your device by a website that stores information about your browsing session or preferences.

ugdewa acts as the Data Controller for all Personal Data collected through the platform. As Data Controller, ugdewa determines the purposes for which Personal Data is processed and the means by which that processing takes place.

ugdewa is an internationally operated online gaming platform primarily serving players based in Indonesia. While the platform targets the Indonesian market — accepting deposits in Indonesian Rupiah (IDR / Rp) and supporting local payment channels including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja — ugdewa operates under an international licensing framework.

ugdewa collects Personal Data across several categories depending on how you interact with the platform. The categories and specific data points are set out in the table below:

ugdewa does not collect special categories of sensitive Personal Data (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless specifically required by law or for the administration of responsible gaming self-exclusion tools.

ugdewa collects Personal Data through the following channels and mechanisms:

4.1 Direct Collection

You provide data directly to ugdewa when you:

• Complete the account registration form and submit your details.
• Submit identity and payment documents during KYC verification.
• Contact our customer support team via live chat or email.
• Participate in surveys, promotions, or competitions hosted by ugdewa.
• Update your account profile, set deposit limits, or request self-exclusion.

4.2 Automated Collection

ugdewa automatically collects certain Technical Data whenever you visit the platform, including:

• Your IP address and approximate geographic location (city-level, not precise GPS).
• Browser type, operating system, and device identifiers collected via standard server logs.
• Session duration, pages visited, buttons clicked, and navigation paths through the platform.
• Cookies and similar tracking technologies as described in Section 7 of this policy.

4.3 Third-Party Sources

In limited circumstances, ugdewa may receive Personal Data about you from third-party sources, including:

• Payment processors and banking partners — confirmation of transaction status and account holder details for deposit and withdrawal verification.
• Fraud prevention and identity verification services — supplementary identity checks to validate KYC submissions and detect fraudulent activity.
• Game providers — session and wagering data from integrated third-party game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Pocket Games Soft, and Spribe, used for dispute resolution and account auditing.

ugdewa processes Personal Data only where a recognized legal basis exists for doing so. The purposes of processing and their corresponding legal bases are as follows:

ugdewa does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share Personal Data only in the circumstances described below and only to the minimum extent necessary for each purpose.

6.1 Service Providers and Data Processors

We engage trusted third-party service providers who process Personal Data strictly on ugdewa's behalf and under written data processing agreements:

• Payment processors: To facilitate IDR deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja.
• KYC and identity verification providers: To validate government-issued identity documents and confirm the authenticity of KYC submissions.
• Fraud prevention platforms: To analyze behavioral and technical signals for patterns consistent with fraudulent activity, account takeovers, or bonus abuse.
• Game technology providers: To deliver integrated gaming content and resolve technical or wagering disputes involving specific game sessions.
• Cloud infrastructure and hosting providers: To store platform data securely on encrypted servers.
• Customer communication platforms: To deliver support via live chat and email.

6.2 Legal Disclosures

ugdewa may disclose Personal Data to competent authorities, regulatory bodies, or law enforcement agencies where required to do so by applicable law, court order, or to protect the rights, property, or safety of ugdewa, its players, or the public. In all such cases, ugdewa will disclose only the minimum Personal Data required to satisfy the legal obligation.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ugdewa's business, Personal Data held at the time of the transaction may be transferred to the acquiring entity. Players will be notified by email of any such transfer at least 30 days prior to the effective date, and the acquiring entity will be bound by data protection obligations no less protective than those described in this policy.

ugdewa uses cookies and similar client-side tracking technologies to deliver core platform functionality, improve user experience, and analyze platform usage. The categories of cookies deployed are as follows:

• Strictly Necessary Cookies: Essential for the platform to function. These cookies manage your login session, maintain your account security state, and remember your language preference. They cannot be disabled without impairing core platform functionality.
• Performance and Analytics Cookies: Collect aggregated, anonymized data about how Players navigate the platform — which pages are visited most frequently, where sessions typically begin and end, and how long players engage with specific features. This data is used exclusively for platform improvement.
• Functionality Cookies: Remember your in-platform preferences such as preferred game categories, display settings, and deposit amount suggestions to personalize your experience on return visits.
• Security Cookies: Support fraud detection and responsible gaming monitoring by tracking patterns such as unusual login locations or unusually rapid betting behavior that may indicate account compromise or problem gambling signals.

ugdewa retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal obligations. The retention periods for the principal categories of data are as follows:

• Account and Identity Data: Retained for the duration of the active account relationship and for a minimum of 5 years following account closure, in accordance with standard AML record-keeping requirements.
• Financial Transaction Data: Retained for a minimum of 5 years from the date of each transaction to satisfy financial record-keeping obligations.
• KYC Documents: Retained for the duration of the account relationship and for 5 years post-closure. Original document images are deleted once the minimum retention period has expired.
• Customer Support Communications: Retained for 2 years from the date of the final message in a support thread, unless the communication relates to an unresolved dispute, in which case it is retained until the dispute is fully resolved.
• Technical and Session Data: Retained in aggregated or pseudonymized form for up to 12 months for platform analytics and security purposes.
• Marketing Preference Data: Retained for as long as your account is active. If your account is closed, marketing records are retained for 3 years to demonstrate compliance with opt-in and opt-out requests.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized in accordance with ugdewa's internal data destruction procedures.

ugdewa implements a layered security architecture to protect Personal Data against unauthorized access, accidental loss, destruction, or disclosure. Our technical and organizational security measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the ugdewa platform is encrypted in transit using industry-standard SSL/TLS protocols. The padlock icon displayed in your browser confirms this encryption is active.
• Password Hashing: Passwords are never stored in plain text. ugdewa uses a strong one-way cryptographic hashing algorithm with individual salts to store password credentials.
• Access Controls: Internal access to Personal Data is restricted on a strict need-to-know basis. Staff with access to sensitive data undergo background verification and regular privacy training.
• Infrastructure Security: Platform infrastructure is hosted on enterprise-grade cloud servers with firewalls, intrusion detection systems, and regular penetration testing conducted by independent security auditors.
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication (2FA) on their accounts as an additional layer of login security.
• Incident Response: ugdewa maintains a documented data breach response plan. In the event of a breach affecting your Personal Data, you will be notified within 72 hours of ugdewa becoming aware of the incident, along with details of the nature of the breach and the remediation steps taken.

ugdewa operates as a globally distributed platform. As a result, Personal Data collected from Indonesian players may be transferred to, stored on, and processed on servers located outside of Indonesia. Such transfers may occur when our cloud hosting providers, KYC verification partners, or game technology providers operate infrastructure in jurisdictions other than Indonesia.

Where Personal Data is transferred internationally, ugdewa ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that described in this Privacy Policy. These safeguards include:

• Contractual clauses binding the recipient to data protection obligations aligned with internationally recognized frameworks.
• Transfers exclusively to jurisdictions or organizations that maintain equivalent data protection standards.
• Encryption of data both in transit and at rest during all cross-border transfers.

You may request further information about the specific safeguards applied to international transfers of your Personal Data by contacting our support team at [email protected].

As a Player whose Personal Data is processed by ugdewa, you hold the following rights in relation to your data. You may exercise any of these rights at any time by contacting our support team. ugdewa will respond to all verified data subject requests within 30 calendar days.

If ugdewa becomes aware that Personal Data has been collected from a person under 21 years of age, that account will be immediately suspended, all associated balances will be forfeited, and the Personal Data will be securely deleted from our systems without undue delay.

Parents or guardians who believe that a minor in their care has registered on ugdewa are encouraged to contact us immediately at [email protected]. We will investigate and act on all such reports promptly and treat the matter with strict confidentiality.

The ugdewa platform may contain references or links to third-party websites, game provider portals, or external content. This Privacy Policy applies solely to data collected and processed by ugdewa. We have no control over and accept no responsibility for the privacy practices or content of any third-party website or service.

We strongly recommend reviewing the privacy policies of any third-party website you visit before submitting Personal Data to that site. The inclusion of a reference to a third-party service on the ugdewa platform does not constitute an endorsement of that service's data practices.

ugdewa reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, new legal requirements, or operational changes to the platform. Where an update materially affects your rights or the way your Personal Data is processed, we will provide at least 14 days' advance notice by posting a prominent notice on the platform and, where practicable, by notifying you via email.

The "Last Updated" date displayed at the top of this page reflects when the current version of the Privacy Policy came into effect. Continued use of the ugdewa platform following the effective date of any revision constitutes acceptance of the updated Privacy Policy. If you do not agree with an updated policy, you must stop using the platform and contact our support team to close your account before the effective date of the change.

We encourage you to review this Privacy Policy periodically, particularly before submitting any new Personal Data to the platform.

For any questions, concerns, or requests relating to this Privacy Policy or ugdewa's data processing practices, please contact our Data Protection team using the details below:

• Email: [email protected] — please include "Privacy Request" in the subject line to ensure prompt routing to the appropriate team.
• Live Chat: Available 24 hours a day, 7 days a week, within the ugdewa platform interface. Indonesian-speaking agents are on hand to assist with privacy-related questions in real time.
• Response Time: ugdewa will acknowledge all privacy-related requests within 5 business days (WIB) and provide a substantive response within 30 calendar days of receipt.

If you believe that ugdewa has not handled your Personal Data in accordance with this Privacy Policy or applicable data protection standards, you have the right to raise a formal complaint. We ask that you contact our support team first so we have the opportunity to resolve your concern directly. If you remain dissatisfied with our response, you may escalate the matter to the relevant supervisory authority in your jurisdiction.