slowin Privacy Policy

This Privacy Policy ("Policy") is issued by slowin ("we", "us", "our", "the Company"), the operator of the online gaming platform accessible at https://slowin.cam. It applies to all registered players, visitors, and prospective users — including players located in Jakarta, Surabaya, Medan, Bandung, Bali, and across Indonesia. By accessing or using the slowin platform, you acknowledge that you have read this Policy and consent to the data practices described herein. If you do not agree to this Policy, you must cease using the platform immediately.

Throughout this Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, identification number, location data, IP address, or any other identifier.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure, or destruction, whether automated or manual.
• "Data Controller" — slowin, which determines the purposes and means of processing your Personal Data.
• "Data Processor" — any third party that processes Personal Data on behalf of slowin, including payment service providers, KYC verification partners, and cloud infrastructure providers.
• "Consent" — a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data.
• "KYC" (Know Your Customer) — the identity and age verification process conducted by slowin and its appointed verification partners to confirm account holder identity before processing withdrawals or as otherwise required.
• "Cookies" — small text files placed on your device by the slowin platform that enable session management, preference storage, and analytics tracking.
• "Platform" — the entirety of slowin's online casino and sports betting services, website, and mobile-optimized interface at https://slowin.cam.

2.1 Identity and Registration Data

When you create a slowin account, we collect your full legal name, date of birth, gender, and nationality. This data is essential for age verification (21+ requirement) and fulfilling our KYC obligations.

2.2 Contact Data

We collect your email address and Indonesian mobile phone number at registration. These are used for account communications, security notifications, and optional promotional messages you have opted into.

2.3 Financial Data

To process deposits and withdrawals, we collect payment method details including bank account numbers registered with BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, or Bank Danamon, and e-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja. We do not store full card numbers. All financial data is transmitted via encrypted channels.

2.4 Identity Verification Documents

As part of KYC compliance, we may collect copies of government-issued identification (Indonesian KTP, passport, or SIM), proof of address documents (utility bills or bank statements), and selfie photographs for biometric identity confirmation.

2.5 Technical and Device Data

We automatically collect IP address, device type and operating system, browser type and version, screen resolution, time zone setting (WIB/WITA/WIT), session start and end timestamps, and pages visited within the platform.

2.6 Transaction and Gaming Data

We maintain records of all deposits, withdrawals, wagers, game sessions, bonus activations, and their outcomes. This data is used for account integrity, dispute resolution, frau d detection, and regulatory compliance purposes.

2.7 Communications Data

We retain records of your interactions with our customer support team via live chat and email, including the content of those communications, timestamps, and resolution outcomes. This allows us to maintain service quality and resolve recurring issues effectively.

slowin collects your Personal Data through the following channels and mechanisms:

• Direct submission — information you provide when registering an account, completing KYC forms, making deposits or withdrawals, contacting support, or responding to surveys.
• Automated collection — technical and device data gathered automatically as you browse and interact with the platform, including via cookies, web beacons, pixel tags, and server logs.
• Third-party verification partners — identity and age verification data obtained from licensed KYC service providers who cross-reference your submitted documents against authoritative data sources.
• Payment processors — transaction status and confirmation data relayed from local Indonesian banks and e-wallet providers upon processing deposits and withdrawals.
• Fraud prevention services — risk signals and device fingerprinting data from security partners used to detect suspicious activity and protect account integrity.
• Analytics providers — aggregated behavioral data from platform analytics tools that help us understand usage patterns and improve the user experience.

slowin uses your Personal Data for the following purposes. Each purpose is tied to a specific legal basis described in Section 5.

slowin processes your Personal Data on the following legal bases, consistent with internationally recognized data protection principles:

5.1 Contract Performance

Processing is necessary to fulfill the contractual obligations arising from your registration and use of the slowin platform, including account operation, payment processing, and delivery of gaming services.

5.2 Legal Obligation

Processing is required to comply with applicable legal and regulatory obligations, including anti-money laundering (AML) requirements, KYC verification mandates, responsible gaming regulations, and financial record-keeping obligations.

5.3 Legitimate Interests

Processing is necessary for the legitimate interests of slowin, including fraud prevention, network security, platform improvement, and business analytics — provided these interests are not overridden by your fundamental rights and freedoms.

5.4 Consent

For certain processing activities — specifically the sending of marketing communications and optional responsible gaming self-assessments — we rely on your freely given, specific, and revocable consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6.1 We Do Not Sell Your Data

slowin does not sell, rent, or trade your Personal Data to any third party for their own marketing or commercial purposes. Any sharing of your data is limited to the categories and purposes described in this section.

6.2 Service Providers (Data Processors)

We share your data with carefully vetted third-party service providers who process data strictly on our behalf and under our instructions, including:

• Payment processors — Indonesian banks (BCA, BRI, BNI, Mandiri, and others) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) for transaction processing.
• KYC and identity verification providers — licensed third-party services that cross-reference identity documents to confirm age (21+) and prevent identity fraud.
• Cloud infrastructure and hosting providers — secure cloud platforms that host the slowin platform and its databases, operating under contractual data security obligations.
• Fraud prevention and cybersecurity partners — risk intelligence providers that analyze device and behavioral signals to detect and block fraudulent activity.
• Customer support platform providers — live chat and ticketing system vendors that facilitate communication between players and the slowin support team.
• Analytics providers — platform performance and usage analytics tools operating on anonymized or pseudonymized data sets.

6.3 Game Content Providers

Third-party game studios whose titles are available on the slowin platform — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — may receive limited technical data (such as player session identifiers) necessary to deliver their games. These providers operate under their own data protection frameworks and are contractually prohibited from using your data for purposes beyond game delivery.

6.4 Regulatory and Law Enforcement Disclosure

We may disclose your Personal Data to competent authorities, regulators, law enforcement agencies, or courts where we are required to do so by applicable law, court order, or regulatory mandate. We will notify you of such disclosures where legally permissible.

6.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of slowin's business, your Personal Data may be transferred to the acquiring entity. You will be notified of any such transfer and the privacy practices of the successor entity before your data is subject to a materially different privacy policy.

7.1 What We Use

The slowin platform uses the following categories of cookies and tracking technologies:

7.2 Managing Cookies

Strictly necessary cookies cannot be disabled as they are essential for the platform to function. You may manage functional and analytics cookies via your browser settings. Most modern browsers allow you to block, delete, or receive notifications about cookies. Please note that disabling certain cookies may limit your access to some platform features or require you to re-authenticate more frequently.

7.3 Do Not Track

Some browsers transmit a "Do Not Track" (DNT) signal. The slowin platform does not currently alter its data collection practices in response to DNT signals, as there is no universally accepted standard for interpreting these signals. We will review this position as industry standards evolve.

slowin retains your Personal Data only for as long as necessary to fulfill the purposes outlined in this Policy and to comply with applicable legal and regulatory obligations. The following general retention periods apply:

• Active account data — retained for the full duration of your account's active status plus a minimum of five (5) years following account closure, to satisfy AML and financial record-keeping requirements.
• KYC documents — retained for a minimum of five (5) years from the date of submission, or longer if required by applicable regulations.
• Transaction records — retained for a minimum of five (5) years following the transaction date.
• Customer support communications — retained for two (2) years from the date of last interaction, unless the matter relates to an unresolved dispute.
• Marketing preference records — retained for three (3) years from the date of last consent or opt-out, to demonstrate compliance.
• Cookie and analytics data — retained in accordance with the durations specified in Section 7, subject to periodic review.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized so that it can no longer be associated with you.

slowin implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, disclosure, alteration, and destruction:

• SSL/TLS Encryption: All data transmitted between your device and slowin's servers is encrypted using industry-standard Transport Layer Security (TLS 1.2 or higher).
• Data Encryption at Rest: Sensitive data fields — including identity document copies and financial account details — are encrypted at rest using AES-256 encryption.
• Access Controls: Internal access to Personal Data is restricted on a strict need-to-know basis. All staff with data access undergo background checks and are bound by confidentiality obligations.
• Multi-Factor Authentication (MFA): Administrative systems handling Personal Data are protected by multi-factor authentication to prevent unauthorized internal access.
• Regular Security Audits: slowin's platform and data infrastructure undergo periodic independent security audits and penetration testing.
• Incident Response Plan: We maintain a documented data breach response plan. In the event of a breach that poses a risk to your rights, we will notify affected users within 72 hours of becoming aware of the incident, where practicable.

Subject to applicable law and certain exemptions, you hold the following rights with respect to your Personal Data held by slowin. To exercise any of these rights, please contact our Data Protection team at the details provided in Section 14.

slowin will respond to all valid rights requests within thirty (30) calendar days of receipt. We may request proof of identity before processing your request to prevent unauthorized access to another person's data.

slowin operates internationally, and your Personal Data may be transferred to, stored in, or processed in countries outside Indonesia. Some of our third-party service providers — including cloud infrastructure, analytics, and game studio partners — may operate data centers in jurisdictions that do not have data protection laws equivalent to those applied in Indonesia.

Where such transfers occur, slowin ensures that appropriate safeguards are in place to protect your data, including execution of standard contractual clauses, binding corporate rules, or reliance on adequacy decisions where applicable. By using the slowin platform, you acknowledge and consent to the transfer of your data under these safeguards.

The slowin 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. If we become aware that a user under 21 has registered an account or provided Personal Data, we will immediately suspend the account, delete the associated data, and take appropriate remedial action.

slowin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered users via email to the address associated with their account and display a prominent notice on the platform for a minimum of fourteen (14) calendar days before the amended Policy takes effect.

The "Effective Date" displayed at the top of this page reflects when the current version of the Policy came into force. We encourage you to review this Policy periodically to remain informed of how we protect your data. Your continued use of the platform following the effective date of any amendment constitutes acceptance of the revised Policy.

If you have any questions about this Privacy Policy, wish to exercise your data rights, or wish to raise a complaint about how slowin has handled your Personal Data, please contact our Data Protection team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the chat widget on the slowin platform
• Response Language: English and Indonesian (Bahasa Indonesia)
• Response Time: Within 30 calendar days for rights requests; within 3 business days for general privacy inquiries
• Hours: 24 hours a day, 7 days a week (WIB, UTC+7)

slowin is committed to resolving all privacy complaints fairly and transparently. If you are not satisfied with our response, you retain the right to escalate your complaint to the competent data protection authority or regulatory body applicable in your jurisdiction.