sawer4 Privacy Policy

01 Definitions

The following definitions apply throughout this Privacy Policy:

• "sawer4" / "we" / "us" / "our" — the online betting platform operating at sawer4.cam and its internationally registered operating entity.
• "Member" / "you" / "your" — any individual who has registered a verified account on sawer4 or who browses the sawer4 website without registration.
• "Personal Data" — any information that identifies or could reasonably be used to identify a natural person, including name, date of birth, residential address, contact details, payment information, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, and deletion.
• "KYC" — Know Your Customer; the identity and age verification process that members must complete before withdrawing funds from sawer4.
• "Cookies" — small text files placed on a user's device by a website to store session and preference information.
• "Third-Party Processor" — any external service provider that processes Personal Data on behalf of sawer4 under a data-processing agreement, such as payment gateways, fraud-detection services, and cloud hosting providers.
• "AML" — Anti-Money Laundering; regulatory requirements that obligate sawer4 to verify the source of funds and monitor transactions for suspicious activity.

02 Data Controller

sawer4 acts as the data controller in respect of all Personal Data collected from Members and website visitors. As data controller, sawer4 determines the purposes and means of processing your Personal Data and is responsible for ensuring that processing is carried out lawfully, fairly, and transparently.

sawer4 operates as an internationally licensed betting platform serving members primarily resident in Indonesia. While sawer4 does not hold a specific Indonesian government-issued online gambling licence — online gambling regulation in Indonesia remains a developing area — we comply with internationally recognised data-protection standards applicable to our operating jurisdiction, including requirements substantively equivalent to those of the EU General Data Protection Regulation (GDPR) where operationally feasible.

03 Data We Collect

sawer4 collects Personal Data through multiple touchpoints during the account lifecycle. The categories of data we collect, and the circumstances in which we collect them, are set out in the table below:

sawer4 does not collect sensitive personal data categories such as racial or ethnic origin, religious beliefs, health data, or biometric data, except where a document submitted for KYC purposes incidentally contains such information (e.g., a national identity card displaying religion). Such incidentally collected sensitive data is used solely for identity verification and is not processed for any other purpose.

04 Legal Basis for Processing

sawer4 processes Personal Data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between sawer4 and a Member — including account creation, transaction processing, and customer support — is carried out on the basis of contractual necessity. Without this processing, sawer4 cannot provide its services.
• Legal Obligation: Processing required to comply with applicable legal obligations — including AML screening, KYC verification, fraud prevention, and regulatory reporting — is carried out on the basis of legal obligation compliance.
• Legitimate Interests: Processing for fraud detection, platform security, responsible gaming monitoring, and service improvement is carried out on the basis of sawer4's legitimate interests, balanced against the rights and freedoms of Members. Members may object to processing on this basis (see Clause 10).
• Consent: Where sawer4 sends optional marketing communications to Members, this is done on the basis of explicit consent. Members may withdraw consent for marketing communications at any time by contacting support.

05 How We Use Your Data

sawer4 uses your Personal Data for the following specific purposes:

1. Account Management: Creating, maintaining, and managing your sawer4 account; processing login authentication; enforcing the single-account policy.
2. Transaction Processing: Processing deposits and withdrawals via local Indonesian bank channels (BCA, BRI, BNI, Mandiri) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja); reconciling transaction records; resolving payment disputes.
3. KYC and AML Compliance: Verifying member identity and age (21+); screening transactions against AML risk thresholds; reporting suspicious activity where legally required.
4. Customer Support: Responding to support queries, complaints, and dispute-resolution requests via live chat and email.
5. Responsible Gaming: Monitoring betting patterns to identify potentially problematic gambling behaviour; enforcing member-set deposit limits, loss limits, and self-exclusion periods; sending reality-check notifications.
6. Platform Security: Detecting and preventing fraud, unauthorised access, multi-accounting, and bonus abuse; maintaining system integrity.
7. Service Improvement: Analysing aggregated, anonymised usage data to improve platform features, betting markets, and user experience. Individual members are not identified in this analysis.
8. Marketing Communications (Consent-Based): Sending Members information about promotions, seasonal bonuses (e.g., Ramadhan, Idul Fitri, Imlek specials), and new platform features — only where the Member has provided explicit consent and not subsequently withdrawn it.

06 Data Sharing

sawer4 does not sell, rent, or trade your Personal Data. We share data only in the following limited circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: Financial data is shared with certified payment gateway partners that facilitate deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallets. These partners are contractually bound to process data only for the purpose of transaction execution and are PCI-DSS compliant.
• KYC Verification Providers: Identity documents are shared with certified third-party KYC verification service providers for automated or manual identity and age verification. These providers operate under strict data-processing agreements.
• Fraud and AML Screening Services: Transaction and behavioural data may be shared with fraud-detection and AML compliance platforms to fulfil our regulatory obligations .
• Cloud Infrastructure Providers: Member data is stored on secure cloud servers operated by internationally recognised hosting providers. These providers act as data processors under binding contractual agreements and do not access Member data for their own purposes.
• Legal and Regulatory Authorities: sawer4 may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts where required to do so by a valid legal order, court order, or applicable law. sawer4 will notify affected Members of such disclosures where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of sawer4's business, Member data may be transferred to the acquiring entity. Members will be notified of any such transfer and of any material changes to data-processing arrangements at least 30 days in advance.

All Third-Party Processors engaged by sawer4 are subject to due-diligence assessment prior to engagement and are contractually required to implement data-security measures consistent with those described in Clause 9 of this Policy.

07 Cookies & Tracking

sawer4 uses cookies and similar tracking technologies to operate the platform, maintain session security, and gather aggregated analytics data. The categories of cookies used are as follows:

sawer4 does not use third-party advertising cookies or tracking pixels that share data with external advertising networks. Members may manage cookie preferences through their browser settings. Disabling strictly necessary cookies will impair platform functionality and may prevent account login.

08 Data Retention

sawer4 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention period required by applicable law or regulatory obligation. The following retention schedule applies:

• Active Account Data: Retained for the full duration of the Member's account and for a minimum of five (5) years following voluntary account closure, to fulfil AML and regulatory record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification, in compliance with internationally recognised AML standards. Where an account was closed due to fraud or suspected money laundering, documents may be retained for up to ten (10) years.
• Transaction Records: Full transaction history — including deposit and withdrawal records denominated in IDR — is retained for a minimum of five (5) years, consistent with standard financial record-keeping obligations.
• Betting Records: Bet history and game participation records are retained for a minimum of three (3) years from the date of the bet, and for the full duration of any unresolved dispute relating to that bet.
• Support Communications: Live chat transcripts and email correspondence are retained for a minimum of two (2) years from the date of the most recent communication in a given support thread.
• Technical and Log Data: Server logs containing IP addresses and access timestamps are retained for a maximum of twelve (12) months, unless a specific security investigation requires extended retention of specific log entries.
• Marketing Consent Records: Records of consent for marketing communications are retained for the duration of the consent plus five (5) years, to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Anonymised, aggregated data derived from Member activity may be retained indefinitely for platform analytics purposes, as it no longer constitutes Personal Data.

09 Security Measures

sawer4 implements a layered security framework to protect Member Personal Data against unauthorised access, disclosure, alteration, and destruction. Our technical and organisational security measures include:

• 256-Bit SSL Encryption: All data transmitted between a Member's device and sawer4's servers is encrypted using TLS 1.2 or higher with 256-bit AES encryption. Connections over unencrypted HTTP are automatically redirected to HTTPS.
• Encrypted Data Storage: Personal Data and KYC documents stored on sawer4's servers are encrypted at rest using industry-standard encryption protocols. Payment card data is not stored on sawer4 servers; it is processed exclusively by our PCI-DSS certified payment gateway partners.
• Access Controls: Access to Member Personal Data within sawer4's internal systems is restricted on a strict need-to-know basis. Staff access is authenticated via multi-factor authentication (MFA) and is logged for audit purposes.
• Intrusion Detection and Monitoring: sawer4's platform is monitored continuously for security anomalies, unauthorised access attempts, and suspicious data-access patterns. Automated alerts are triggered by abnormal activity.
• Penetration Testing: sawer4 engages independent security specialists to conduct periodic penetration tests of the platform. Critical vulnerabilities identified are remediated within 48 hours of discovery.
• Two-Factor Authentication (2FA) for Members: Members are strongly encouraged to enable 2FA on their sawer4 accounts via the account settings panel. 2FA significantly reduces the risk of unauthorised account access.

10 Your Rights

As a data subject, you hold the following rights in respect of your Personal Data held by sawer4. To exercise any of these rights, contact our Privacy Officer at [email protected] with the subject line "Privacy Request":

• Right of Access: You may request a copy of all Personal Data sawer4 holds about you, along with information about how it is processed. sawer4 will respond to access requests within 30 days.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data. For identity-critical data (name, date of birth, KTP number), corrections require submission of supporting KYC documentation.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent. This right is subject to sawer4's legal obligation to retain certain data (see Clause 8); erasure requests will be partially fulfilled where full erasure is prohibited by law.
• Right to Restriction: You may request that sawer4 restrict processing of your Personal Data while a rectification or objection request is under review.
• Right to Data Portability: You may request a copy of Personal Data you have provided to sawer4 in a structured, commonly used, machine-readable format (JSON or CSV), where processing is carried out by automated means on the basis of consent or contract.
• Right to Object: You may object to processing carried out on the basis of sawer4's legitimate interests (see Clause 4). sawer4 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

sawer4 will acknowledge all privacy rights requests within 48 hours and provide a substantive response within 30 calendar days. Where a request is complex or numerous, this period may be extended by a further 30 days with notice to the Member.

11 Minors

sawer4 is strictly an adults-only platform. Individuals under the age of 21 are not permitted to register an account, place bets, or use any feature of the sawer4 platform. sawer4 does not knowingly collect Personal Data from individuals under the age of 21.

Age verification is a mandatory step in the KYC process. All Members must provide government-issued identity documentation confirming they are at least 21 years of age before their first withdrawal is processed. Where sawer4 has reasonable grounds to suspect that a Member may be under 21, the account will be suspended pending KYC completion, regardless of the account's current balance or betting activity.

If you are a parent or guardian and believe that a minor under your care has registered an account on sawer4, please contact our support team immediately at [email protected]. sawer4 will investigate promptly, close the account, and delete any Personal Data collected from the minor in accordance with applicable data-protection standards.

12 International Transfers

sawer4 operates as an internationally licensed platform. Some of the Third-Party Processors engaged by sawer4 — including cloud infrastructure providers and KYC verification services — may process Member data in jurisdictions outside Indonesia. Where such international transfers occur, sawer4 ensures that appropriate safeguards are in place, including:

• Contractual data-processing agreements that impose data-protection obligations substantively equivalent to internationally recognised standards.
• Selection of processors located in jurisdictions that provide an adequate level of data protection as assessed by sawer4's data-protection review process.
• Standard contractual clauses or equivalent transfer mechanisms where transfers occur to jurisdictions without an adequacy determination.

Members may request details of the international transfer safeguards applicable to their Personal Data by contacting the sawer4 Privacy Officer at [email protected].

13 Policy Amendments

sawer4 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, data-processing practices, or platform services. When material changes are made, sawer4 will notify active Members via a platform notification or email to the registered address on file, with a minimum of 14 days' notice before the changes take effect.

The current version number and last-updated date are displayed prominently at the top of this page. Members are encouraged to review this Privacy Policy periodically. Continued use of the sawer4 platform following the effective date of any revision constitutes acceptance of the updated Policy.

Previous versions of this Privacy Policy are available on request by contacting our Privacy Officer. Historical versions are retained for a minimum of five (5) years from the date of supersession.

14 Contact & Complaints

For all privacy-related enquiries, data subject rights requests, and formal complaints regarding sawer4's data-processing practices, Members should contact our designated Privacy Officer using the details below. Our support team is available 24 hours a day, seven days a week, including all Indonesian public holidays.

• Privacy Officer Email: [email protected] — please use the subject line "Privacy Request" for all data-protection matters. Displayed as plain text only; not a clickable link.
• Live Chat: Available within your sawer4 account dashboard for general queries. For formal privacy rights requests, written email correspondence is recommended to create an auditable record.

sawer4 will acknowledge all privacy enquiries within 48 hours and provide a substantive response within 30 calendar days, in accordance with the Member rights outlined in Clause 10. If you are not satisfied with sawer4's response to a privacy complaint, you may escalate the matter through the dispute resolution process outlined in sawer4's Terms & Conditions.