Privacy Policy

1. Introduction

This Privacy Policy explains how winfly ("we", "us", "our") collects, uses, discloses, and protects your personal information when you access and use our online gaming platform at winfly.cam. By creating an account or using winfly services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. This policy applies to all users of the winfly platform, including visitors, registered players, and anyone who interacts with our services. We are committed to protecting your privacy and handling your personal data with transparency and in accordance with international data protection standards and applicable Indonesian regulations.

winfly operates as an online gaming platform serving Indonesian players who prefer international-standard gaming experiences delivered in English. We understand the importance of maintaining the confidentiality and security of your personal information, particularly given the sensitive nature of financial transactions and gaming activities. This Privacy Policy should be read in conjunction with our Terms and Conditions and Responsible Gaming policies, which together govern your use of the platform.

2. Information We Collect

2.1 Personal Information You Provide

When you register for a winfly account, we collect personal information necessary to create and maintain your account, verify your identity, process transactions, and comply with regulatory requirements. This information includes:

• Identity information: Full legal name, date of birth, gender, and nationality as shown on your government-issued identification documents.
• Contact information: Residential address in Indonesia, email address, and mobile phone number for account communications and security verification.
• Verification documents: Copies of government-issued ID (KTP or passport), proof of address documents (utility bills or bank statements dated within the last three months), and proof of payment method ownership (bank account statements showing your name and account details).
• Financial information: Bank account details for Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, Bank Permata) used for deposits and withdrawals, including account holder name and account number.
• Account credentials: Username, password (stored in encrypted form), and security questions you set for account recovery purposes.

2.2 Information Automatically Collected

When you use the winfly platform, we automatically collect certain technical and usage information through cookies, log files, and similar tracking technologies:

• Device information: Device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages visited, features used, time spent on pages, games played, bet history, transaction history, login times, and interaction patterns with platform features.
• Location data: IP address and general geographic location (city/region level) to verify you are accessing the platform from within Indonesian territory as required by our terms of service.
• Communication records: Records of your communications with our customer support team, including live chat transcripts, email correspondence, and WhatsApp messages for quality assurance and dispute resolution purposes.

2.3 Information from Third Parties

winfly may receive information about you from third-party sources including payment processors, fraud prevention services, identity verification providers, and game providers to verify your identity, prevent fraud, and ensure compliance with anti-money laundering regulations.

3. How We Use Your Information

winfly uses your personal information for the following legitimate business purposes:

• Account management: Creating and maintaining your player account, authenticating your identity when you log in, and managing your account settings and preferences.
• Transaction processing: Processing your deposits and withdrawals through Indonesian bank transfers, recording all financial transactions, and maintaining accurate financial records for your account.
• Service delivery: Providing access to sports betting, casino games, live dealer tables, and other gaming services; tracking your gameplay history and bet results; calculating and crediting winnings to your account.
• Compliance and security: Verifying your age (21+ requirement), verifying your identity and address to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, detecting and preventing fraud, money laundering, and other illegal activities, and ensuring compliance with responsible gaming policies.
• Customer support: Responding to your inquiries, resolving technical issues, investigating disputes, and providing assistance through our 24/7 Indonesian-speaking support team.
• Communication: Sending account-related notifications (transaction confirmations, security alerts, policy updates), promotional offers and bonus information (with your consent), and responsible gaming reminders.
• Platform improvement: Analyzing usage patterns to improve platform functionality, optimizing game selection based on player preferences, enhancing user interface and mobile experience, and identifying and fixing technical issues.
• Marketing and personalization: Recommending games based on your preferences, personalizing promotional offers, and conducting market research (only with your consent).

4. Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contract performance: Processing is necessary to fulfill our contract with you when you register and use winfly services.
• Legal obligation: Processing is required to comply with legal and regulatory obligations including age verification, KYC/AML compliance, and financial record-keeping.
• Legitimate interests: Processing is necessary for our legitimate business interests in preventing fraud, ensuring platform security, and improving our services, provided these interests do not override your privacy rights.
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

5. Information Sharing and Disclosure

winfly does not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information only in the following limited circumstances:

• Service providers: We share information with trusted third-party service providers who assist us in operating the platform, including payment processors (for Indonesian bank transfers), game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, etc.), identity verification services, fraud prevention services, cloud hosting providers, and customer support tools. All service providers are contractually required to protect your information and use it only for the specific services they provide to us.
• Legal requirements: We may disclose your information if required by law, court order, or government regulation, or if we believe disclosure is necessary to protect our rights, prevent fraud or illegal activity, or protect the safety of users or the public.
• Business transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

6. Data Security

winfly implements industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and our servers is protected by SSL/TLS encryption (the same security technology used by banks). Sensitive data including passwords and financial information is encrypted in our databases.
• Access controls: Access to personal information is restricted to authorized employees who need the information to perform their job functions. All employees are trained on data protection principles and bound by confidentiality agreements.
• Network security: Our systems are protected by firewalls, intrusion detection systems, and regular security audits to identify and address vulnerabilities.
• Secure payment processing: Financial transactions are processed through secure payment gateways that comply with banking industry security standards.

While we implement robust security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but remain committed to protecting your information using industry best practices.

7. Cookies and Tracking Technologies

winfly uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze platform usage.

7.1 Types of Cookies We Use

• Essential cookies: Required for platform functionality including login authentication, session management, and security features. These cookies cannot be disabled as they are necessary for the platform to function.
• Performance cookies: Collect anonymous information about how you use the platform, which pages are most popular, and error messages encountered. This helps us improve platform performance.
• Functionality cookies: Remember your preferences such as language settings, layout preferences, and favorite games to provide a personalized experience.
• Analytics cookies: Help us understand user behavior, measure traffic patterns, and analyze which features are most used to improve our services.

7.2 Managing Cookies

You can control cookie settings through your browser preferences. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may affect platform functionality and your ability to use certain features. For more information about cookie management, consult your browser's help documentation.

8. Data Retention

winfly retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy and comply with legal obligations. Specific retention periods include:

• Active accounts: Information is retained while your account remains active and for a reasonable period afterward to handle any disputes or inquiries.
• Transaction records: Financial transaction records are retained for a minimum of seven years to comply with financial record-keeping regulations and tax requirements.
• Closed accounts: After account closure, we retain limited information (primarily for compliance and fraud prevention) for the period required by applicable laws, typically 5-7 years.
• Marketing data: If you opt out of marketing communications, we retain a record of your opt-out preference indefinitely to ensure we do not contact you again.

9. Your Privacy Rights

As a winfly user, you have the following rights regarding your personal information:

• Right to access: You may request a copy of the personal information we hold about you.
• Right to correction: You may request correction of inaccurate or incomplete personal information.
• Right to deletion: You may request deletion of your personal information, subject to our legal obligations to retain certain records.
• Right to object: You may object to processing of your personal information for marketing purposes or other legitimate interests.
• Right to data portability: You may request a copy of your personal information in a structured, machine-readable format.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time.

To exercise any of these rights, please contact our customer support team at [email protected]. We will respond to your request within a reasonable timeframe, typically within 30 days. We may require verification of your identity before processing requests to protect your privacy.

10. Children's Privacy

winfly is an adult-only platform. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have collected information from a person under 21, we will delete that information immediately and close the associated account. If you believe we have inadvertently collected information from a minor, please contact us immediately at [email protected].

11. Third-Party Links

The winfly platform may contain links to third-party websites, game providers, or services. This Privacy Policy applies only to information collected by winfly. We are not responsible for the privacy practices of third-party websites or services. We encourage you to review the privacy policies of any third-party sites you visit.

12. International Data Transfers

Your personal information may be transferred to and processed in countries outside Indonesia where our service providers and data centers are located. When we transfer information internationally, we ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable data protection laws.

13. Changes to This Privacy Policy

winfly may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated policy on this page with a revised "Last Updated" date. If we make material changes that significantly affect your privacy rights, we will notify you by email or through a prominent notice on the platform. Your continued use of winfly services after changes to this policy constitutes acceptance of the revised policy.

14. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact us:

• Email: [email protected]
• Customer Support: Available 24/7 via live chat and WhatsApp with Indonesian-speaking agents

We take privacy concerns seriously and will investigate and respond to all inquiries promptly. For formal privacy complaints, we will acknowledge receipt within 48 hours and provide a substantive response within 30 days.

Last Updated: January 2026