Privacy Policy — sawo4d

The following terms carry the meanings assigned to them throughout this Privacy Policy. Capitalised terms not defined here carry the meanings given to them in the sawo4d Terms & Conditions.

sawo4d operates as an internationally licensed online gaming platform serving Players in Indonesia and select international markets. As the operator of the Platform, sawo4d acts as the Data Controller in respect of all Personal Data collected from Players and visitors to https://sawo4d.app.

All data-processing activities conducted by sawo4d are carried out in accordance with internationally recognised data-protection principles, including purpose limitation, data minimisation, storage limitation, integrity, and confidentiality.

For all privacy-related enquiries, Players may contact our dedicated data protection contact point at: [email protected] — please note this address is displayed as plain text only and is not a clickable link.

sawo4d collects the minimum Personal Data necessary to deliver its services securely and in compliance with applicable anti-money laundering and responsible gaming obligations. The categories of data we collect are outlined below.

sawo4d collects Personal Data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or use responsible gaming tools on the Platform.
• Automatically — through server logs, session cookies, and analytics software as you browse and interact with the Platform. See Section 9 for full details on cookies and tracking technologies.
• From third-party Data Processors — such as KYC verification providers, payment gateway operators, and fraud-detection services, who may supply or cross-reference data as part of their contracted service to sawo4d.
• From game providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft, whose game platforms may transmit session and result data to sawo4d's systems in real time.

sawo4d processes Personal Data only where a valid legal basis exists. The primary purposes and corresponding bases are as follows:

sawo4d does not sell, rent, or trade your Personal Data to third parties for commercial purposes. We may share your data only in the following limited circumstances:

• Data Processors: Third-party service providers who process data on our behalf under binding data-processing agreements, including KYC verification firms, payment gateway operators (supporting BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja transactions), cloud infrastructure providers, fraud detection services, and customer support platform providers.
• Game Studios: Integrated game providers such as Pragmatic Play, Evolution Gaming, Spribe, Microgaming, NetEnt, and Pocket Games Soft receive session tokens and anonymised Player identifiers necessary to deliver their games within the Platform. These providers are contractually prohibited from using such data for independent marketing purposes.
• Legal and Regulatory Authorities: Where sawo4d is required by applicable law, court order, or the lawful direction of a competent regulatory or law-enforcement authority to disclose Personal Data, we will comply with such requirements and, where legally permitted, notify the affected Player.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of sawo4d's business, Player data may be transferred to the successor entity, subject to equivalent data-protection obligations applying to the recipient.

sawo4d retains Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following indicative retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised so that it can no longer be attributed to an identified or identifiable individual.

sawo4d takes the security of your Personal Data seriously. We implement a layered set of technical and organisational security controls designed to protect your data against unauthorised access, loss, alteration, and disclosure:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the sawo4d Platform is protected by industry-standard Transport Layer Security (TLS) encryption. Look for the padlock icon in your browser's address bar when using the Platform.
• Data Encryption at Rest: Sensitive Personal Data — including KYC documents and financial records — is encrypted at rest using AES-256 encryption on our secure cloud infrastructure.
• Access Controls: Access to Personal Data within sawo4d's internal systems is granted on a strict need-to-know basis. All staff with access to Player data undergo security awareness training and are bound by confidentiality obligations.
• Intrusion Detection & Monitoring: Our platform infrastructure is monitored continuously for unusual activity, intrusion attempts, and anomalous data-access patterns. Security events are logged and reviewed by our technical security team.
• Penetration Testing: sawo4d's platform undergoes regular penetration testing conducted by independent security specialists to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the unlikely event of a Personal Data breach that poses a material risk to Players, sawo4d will notify affected individuals and relevant authorities in accordance with applicable data-protection requirements.

sawo4d uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, and analyse usage patterns. The categories of cookies we use are described below:

You may manage your cookie preferences through your browser settings at any time. Note that disabling cookies beyond strictly necessary ones may affect the functionality of certain Platform features. As the Platform is designed for Players in Indonesia using the Western Indonesia Time (WIB, UTC+7) time zone, session cookies are set with server timestamps aligned to WIB by default.

As a Player whose Personal Data is processed by sawo4d, you have the following rights in respect of your data. To exercise any of these rights, please contact us at [email protected] (plain text — not a clickable link). We will respond to all verified requests within thirty (30) days.

• Right of Access: You have the right to request a copy of the Personal Data that sawo4d holds about you, together with information about how it is being processed.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. For name or date-of-birth changes, documentary evidence may be required.
• Right to Erasure: You may request that sawo4d delete your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent. This right is subject to our legal retention obligations — for example, AML regulations require us to retain certain data for a minimum of five years.
• Right to Restrict Processing: You may request that sawo4d restrict the Processing of your Personal Data in certain circumstances, such as where you contest its accuracy or have objected to its use.
• Right to Data Portability: Where Processing is based on your consent or on contract performance and is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to the Processing of your Personal Data where it is based on sawo4d's legitimate interests. You also have an unconditional right to object to the Processing of your data for direct marketing purposes at any time.
• Right to Withdraw Consent: Where Processing is based on your consent (e.g., for marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of Processing carried out prior to withdrawal.

Age verification is a mandatory step in our KYC process. Any account found to have been registered by an individual under the age of 21 will be immediately suspended, all balances will be frozen pending investigation, and any Personal Data collected in the course of that registration will be securely deleted in accordance with our data minimisation obligations, except where retention is required for regulatory reporting purposes.

If you are a parent or guardian and believe that a minor in your care has registered an account on sawo4d, please contact our support team immediately at [email protected] (plain text — not a clickable link). We will investigate and take prompt remedial action.

The sawo4d Platform integrates games and services from third-party providers, including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. These providers operate their own game platforms within the sawo4d interface under their own privacy and data-security policies. sawo4d contractually requires all integrated providers to maintain appropriate security standards for any Player data they handle.

Payment processing for local Indonesian bank transfers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet transactions (OVO, DANA, GoPay, ShopeePay, LinkAja) is facilitated through contracted payment gateway processors. These processors handle your financial data under their own regulatory obligations and privacy frameworks. sawo4d shares only the minimum data necessary to complete each transaction.

sawo4d is not responsible for the privacy practices of third-party entities whose services are accessed independently of the Platform. Players are encouraged to review the privacy policies of any third-party service they use in connection with their sawo4d account.

sawo4d may update this Privacy Policy from time to time to reflect changes in our data-processing practices, applicable law, or Platform functionality. The "Last Updated" date at the top of this page will be revised whenever a material change is made.

Where changes are material — for example, where we introduce a new purpose for Processing your data or share data with a new category of third party — sawo4d will provide advance notice to registered Players via email or a prominent notice within the Platform, allowing you a reasonable period to review the changes before they take effect.

Your continued use of the Platform following the effective date of any update constitutes your acknowledgment of the revised Privacy Policy. If you do not agree with any changes, you may exercise your rights as described in Section 10, including the right to request account closure and erasure of your data (subject to applicable legal retention obligations).

For any questions, concerns, or requests relating to this Privacy Policy or the Processing of your Personal Data, please contact the sawo4d data protection team through the channels below:

If you are not satisfied with sawo4d's response to a privacy complaint, you have the right to escalate your complaint to an appropriate data-protection authority or independent dispute resolution body in your jurisdiction. sawo4d will cooperate fully with any such authority in the course of a legitimate investigation.

sawo4d is committed to resolving all privacy concerns fairly and transparently. We encourage Players to contact us directly in the first instance so that we have the opportunity to address concerns before any formal escalation is required.