Privacy Policy

1. Introduction

se7win is committed to protecting the personal data of every player who uses our platform. As an online gaming service operating in and for the Indonesian market, we handle a range of personal information — from account registration details and payment records to gameplay activity and customer support interactions. This Privacy Policy sets out, in clear and accessible language, precisely how we collect, store, use, share, and ultimately delete that data.

We design our data practices around three core principles: transparency (you always know what we collect and why), proportionality (we collect only what we genuinely need), and security (what we hold is protected to the highest technically feasible standard). These principles are not aspirational — they are operationalized through our technical infrastructure, internal policies, and ongoing staff training.

This policy should be read in conjunction with our Terms & Conditions and our Responsible Gaming policy, all of which govern your use of the se7win platform and collectively constitute the full agreement between you and us.

2. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, either directly (e.g., full name, national ID number) or indirectly (e.g., device fingerprint in combination with other data points).
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, erasure, or any other handling activity.
• "Data Controller" means se7win, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of se7win under a formal data processing agreement.
• "Platform" means the se7win website at https://se7win.cam and all related services, game interfaces, and communication channels.
• "Player" or "you" means any individual who registers an account on or interacts with the Platform.
• "KYC" means the Know Your Customer verification process used to confirm a player's identity prior to processing withdrawals.
• "Cookies" means small text files placed on your device by the Platform or by trusted third-party services integrated into the Platform.

3. Data We Collect

The categories of personal data we collect vary depending on the nature of your interaction with the Platform. The following table provides a comprehensive overview:

4. How We Collect Data

4.1 Directly From You

The majority of your personal data is collected directly when you: complete the account registration form; upload documents as part of the KYC verification process; make a deposit or request a withdrawal; contact our customer support team; participate in promotions or surveys; or update your account profile settings.

4.2 Automatically Through the Platform

When you access the Platform, our servers and analytics systems automatically collect technical data including your IP address, device identifiers, browser information, and gameplay session metrics. This data is collected via server logs, session cookies, and first-party analytics tools. We do not use this data to identify you individually; it is primarily used in aggregate form to improve Platform performance and detect fraudulent access patterns.

4.3 From Third Parties

We may receive personal data about you from third-party sources in specific circumstances:

• Identity verification providers: confirmation of document authenticity and identity match results during KYC.
• Payment processors: transaction confirmation data from Indonesian banks and e-wallet providers.
• Fraud prevention services: risk scores and flagged activity patterns associated with known fraudulent identities or devices.
• Affiliate and referral partners: basic referral tracking data if you arrived at se7win via a registered affiliate channel.

In all cases, we ensure that third parties sharing data with us do so lawfully and under appropriate data-sharing agreements.

5. Purposes of Processing

se7win processes your personal data only for clearly defined, legitimate purposes. We do not use your data in ways that are incompatible with the purposes stated at the point of collection. The primary purposes for which we process personal data are:

• Account management: creating and maintaining your player account, authenticating your identity at login, and managing account security settings.
• Payment processing: facilitating deposits and withdrawals through your chosen Indonesian bank or e-wallet, reconciling transactions, and maintaining accurate financial records.
• Identity verification (KYC): confirming that you meet the minimum age requirement of 21 years, verifying your identity in compliance with anti-money-laundering (AML) obligations, and preventing fraudulent account activity.
• Customer support: responding to your queries, resolving disputes, and maintaining records of support interactions for quality assurance and training purposes.
• Responsible gaming: monitoring gameplay patterns to identify indicators of problem gambling behavior, administering deposit limits and self-exclusion requests, and providing access to responsible gaming resources. See our Responsible Gaming page for full details.
• Fraud prevention and security: detecting and preventing unauthorized account access, bonus abuse, money laundering, and other fraudulent or criminal conduct on the Platform.
• Platform improvement: analyzing aggregate usage data to identify technical issues, optimize game performance, improve user experience, and develop new features.
• Marketing communications: sending promotional offers, bonus notifications, and platform updates to players who have opted in to marketing communications. You may opt out at any time via your account settings or by contacting support.
• Legal and regulatory compliance: meeting our obligations under applicable international gaming regulations, AML laws, and data protection frameworks, including responding to lawful requests from competent authorities.

6. Legal Basis for Processing

se7win processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

6.1 Contractual Necessity

Processing your identity data, contact data, financial data, and KYC documents is necessary for us to perform the contract we have entered into with you — namely, the provision of gaming services as governed by our Terms & Conditions. Without this data, we cannot open or maintain your account or process your transactions.

6.2 Legal Obligation

Certain processing activities — particularly those related to KYC verification, AML monitoring, record-keeping for financial transactions, and responding to regulatory or law-enforcement requests — are required by applicable laws and regulations. We process data for these purposes regardless of your consent because doing so is a legal obligation we must fulfill.

6.3 Legitimate Interests

We process technical data, gameplay data, and communications data on the basis of our legitimate interests in operating a secure, fair, and commercially viable gaming platform. This includes fraud detection, platform security monitoring, and aggregate analytics for product improvement. We balance these interests against your privacy rights and do not use this basis where your interests override ours.

6.4 Consent

Where we send marketing communications or use non-essential cookies, we do so only on the basis of your freely given, informed consent. You may withdraw consent at any time without detriment to your account standing. Withdrawal of marketing consent does not affect the lawfulness of processing carried out before the withdrawal.

7. Sharing Your Personal Data

se7win does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial purposes. We share your data only in the following limited and controlled circumstances:

7.1 Payment Service Providers

To process your deposits and withdrawals, we share necessary financial and identity data with Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), as well as international card networks (Visa, Mastercard) where applicable. These providers receive only the minimum data necessary to process the specific transaction.

7.2 Identity Verification and KYC Providers

We work with accredited third-party identity verification services to authenticate documents and confirm player identities during the KYC process. These providers process your documents under strict data processing agreements and are prohibited from using your data for any purpose beyond verification.

7.3 Game Content Providers

Game studios integrated into our platform — including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft — receive anonymized session tokens and technical data sufficient to deliver their game interfaces. These providers do not receive your personal identity or financial data.

7.4 Fraud Prevention and Security Services

We share technical data (IP addresses, device fingerprints, behavioral patterns) with specialist fraud prevention services that help us identify and block suspicious activity. These services operate as data processors under formal agreements and do not retain your data beyond the period necessary for fraud analysis.

7.5 Regulatory and Law Enforcement Authorities

We will disclose personal data to competent authorities — including financial regulators, law enforcement agencies, and tax authorities — when legally required to do so. We will notify you of such disclosure where we are legally permitted to do so, but we are not always able to provide prior notice when disclosures are compelled by court order or regulatory mandate.

7.6 Corporate Transactions

In the event of a merger, acquisition, reorganization, or sale of assets involving se7win, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the identity of the new data controller before the transfer takes effect, and the new controller will be bound by this Privacy Policy or an equivalent standard.

8. Data Retention

We retain your personal data for as long as is necessary to fulfill the purposes for which it was collected, and to comply with our legal, regulatory, and contractual obligations. The following retention periods apply as general guidelines:

• Account and identity data: retained for the duration of your account plus five (5) years following account closure, in accordance with AML record-keeping requirements.
• Financial transaction records: retained for a minimum of five (5) years from the date of each transaction, consistent with financial regulatory obligations.
• KYC documents: retained for five (5) years following the completion of verification or account closure, whichever is later.
• Gameplay records: retained for three (3) years from the date of each gaming session, used for dispute resolution, responsible gaming monitoring, and regulatory reporting.
• Customer support records: retained for three (3) years from the date of each support interaction.
• Marketing preferences and consent records: retained until you withdraw consent plus two (2) years, to demonstrate compliance with consent obligations.
• Technical and log data: retained for twelve (12) months, primarily for security monitoring and platform diagnostics.

When data is no longer required, it is securely deleted or anonymized in a manner that prevents re-identification. Anonymized, aggregate data may be retained indefinitely for statistical and analytical purposes.

9. Security Measures

se7win applies a multi-layered security architecture to protect your personal data against unauthorized access, accidental loss, alteration, or disclosure. Our key security measures include:

9.1 Encryption

All data transmitted between your browser and our servers is protected by 256-bit TLS (Transport Layer Security) encryption. Sensitive data stored in our databases — including financial records and identity documents — is encrypted at rest using AES-256 encryption. Encryption keys are managed by dedicated key management systems with strict access controls.

9.2 Access Controls

Access to personal data within se7win's systems is restricted on a strictly need-to-know basis. All staff with access to personal data undergo background screening, sign confidentiality agreements, and complete data protection training upon onboarding and annually thereafter. Multi-factor authentication is required for all internal system access.

9.3 Infrastructure Security

Our platform infrastructure is hosted in secure, ISO 27001-aligned data centers with physical access controls, redundant power supplies, and continuous environmental monitoring. Our network is protected by enterprise-grade firewalls, intrusion detection systems, and automated DDoS mitigation.

9.4 Incident Response

We maintain a documented data breach response plan. In the event of a security incident that compromises your personal data, we will notify affected players and relevant authorities within the timeframes required by applicable law. We will provide clear information about the nature of the breach, the data affected, and the steps we are taking to mitigate harm.

10. Cookies & Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the Platform. They allow us to recognize your browser, maintain your session, remember your preferences, and collect information about how you interact with our services. We also use similar technologies such as web beacons, pixel tags, and local storage where appropriate.

10.2 Types of Cookies We Use

• Essential cookies: required for the Platform to function correctly. They maintain your login session, remember your preferred language setting, and ensure secure navigation. These cannot be disabled without breaking core Platform functionality.
• Performance cookies: collect anonymized data about how players use the Platform — which pages are visited most frequently, where errors occur, and how long sessions last. This data is used exclusively to improve Platform performance.
• Functional cookies: remember your preferences such as your preferred deposit method or last-visited game category, so you do not have to re-enter them on each visit.
• Analytics cookies: first-party analytics tools that help us understand aggregate player behavior. We do not use third-party advertising network cookies or cross-site tracking cookies.

10.3 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to view, delete, and block cookies on a per-site or global basis. Please note that disabling essential cookies will impair your ability to log in and use the Platform. For full instructions on managing cookies in your specific browser, refer to your browser's official help documentation.

11. Your Rights Over Your Personal Data

As a player on the se7win Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our Data Protection Officer (DPO) using the contact details provided in Section 15. We will respond to all valid rights requests within thirty (30) days of receipt.

• Right of Access: you may request a copy of all personal data we hold about you, together with information about how it is being used.
• Right to Rectification: if any data we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it without undue delay.
• Right to Erasure: in certain circumstances, you may request the deletion of your personal data. We will honor such requests where there is no overriding legal obligation requiring us to retain the data.
• Right to Restriction: you may request that we restrict the processing of your data in specific circumstances — for example, while the accuracy of data you have disputed is being verified.
• Right to Data Portability: where processing is based on consent or contractual necessity and carried out by automated means, you may request a copy of your data in a structured, commonly used, machine-readable format.
• Right to Object: you may object to the processing of your data where we rely on legitimate interests as our legal basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: where processing is based on your consent — for example, marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing.
• Right to Lodge a Complaint: if you believe we have not handled your personal data in accordance with this policy or applicable law, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

12. Minors and Age Verification

The se7win Platform is strictly intended for adults aged 21 years or older. We do not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in our KYC process, and we will suspend any account where there is a reasonable suspicion that the account holder does not meet the minimum age requirement.

If you are a parent or guardian and you believe that a minor has accessed our Platform and provided personal data without your consent, please contact us immediately at the address in Section 15. We will investigate the matter promptly and delete any data confirmed to belong to a person under the age of 21.

13. Third-Party Links and Embedded Content

The se7win Platform may contain references to third-party game providers, payment gateways, or information resources. Where such references involve accessing a third-party interface or website, please be aware that those third parties operate under their own privacy policies, which are independent of this document. se7win is not responsible for the privacy practices of third-party sites or services, and we encourage you to review their respective privacy policies before providing any personal data to them.

Embedded live game streams provided by studio partners such as Evolution Gaming operate within an iframe hosted on our domain; the data processed within that session is governed by our data sharing arrangements with those studios, as described in Section 7.3.

14. Changes to This Privacy Policy

se7win reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When we make material changes, we will notify you by sending an email to your registered address and by posting a prominent notice on the Platform homepage at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this policy indicates when the most recent revision was made. We encourage you to review this policy periodically to stay informed about how we protect your data. Your continued use of the Platform after the effective date of a revised policy constitutes your acceptance of the updated terms.

The current version of this Privacy Policy is always accessible at https://se7win.cam/privacy-policy.

15. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact our dedicated Data Protection Officer (DPO). Our DPO is responsible for overseeing data protection compliance within se7win and is your primary point of contact for all privacy-related matters.

When submitting a rights request, please include your registered username, a clear description of your request, and any relevant supporting information. This helps us verify your identity and handle your request efficiently. We may need to request additional proof of identity before processing certain requests, particularly erasure and data portability requests, in order to protect your account from unauthorized third-party requests.

For responsible gaming-related data requests — such as activating a self-exclusion record or retrieving your gameplay history for personal review — please refer to our Responsible Gaming page or contact support directly.