Privacy Policy

1. Introduction

raw90 ("we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, share, and protect information about you when you use our online betting, casino gaming, and lottery services available at https://raw90.cam and through our mobile-optimized platform.

This Privacy Policy applies to all users of raw90 services, including registered members and visitors. By accessing or using raw90, you acknowledge that you have read, understood, and agree to the data practices described in this Privacy Policy. If you do not agree with our practices, please do not use raw90 services.

raw90 operates internationally while serving primarily Indonesian users. We adhere to international data protection standards, including principles aligned with the General Data Protection Regulation (GDPR) and applicable Indonesian data protection regulations. We process personal data lawfully, fairly, and transparently, and we respect your rights as a data subject.

2. Information We Collect

raw90 collects various types of information to provide, maintain, and improve our services, comply with legal obligations, and enhance your user experience. The categories of information we collect include:

2.1 Information You Provide Directly

When you register an account, use our services, or contact customer support, you provide information directly to raw90, including:

• Account Registration Information: Full legal name, date of birth, email address, mobile phone number, residential address, username, password, and security questions
• Identity Verification (KYC) Information: Government-issued identification documents (Indonesian national ID card/KTP), selfie photographs, proof of address documents, and other verification materials required under Know Your Customer regulations
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet information (OVO, DANA, GoPay, ShopeePay, LinkAja account identifiers), transaction history, deposit and withdrawal records, and payment method preferences
• Communication Data: Customer support inquiries, live chat conversations, email correspondence, feedback submissions, and any other communications with raw90 staff
• Preferences and Settings: Language preferences, notification settings, betting preferences, favorite games, and account customization choices

2.2 Information Collected Automatically

When you access and use raw90 services, we automatically collect certain technical and usage information, including:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, advertising ID), and mobile network information
• Connection Data: IP address, internet service provider, connection type, geographic location (country, city, region based on IP address), and timezone
• Usage Information: Pages visited, features accessed, time spent on pages, clickstream data, games played, bets placed, betting patterns, session duration, and navigation paths through the raw90 platform
• Transaction Data: Deposit amounts and timestamps, withdrawal requests and processing times, bonus claims, wagering activity, win/loss records, and account balance history
• Technical Data: Browser cookies, local storage data, crash reports, error logs, and performance metrics

2.3 Information from Third Parties

In certain circumstances, we may receive information about you from third-party sources, including:

• Payment Providers: Transaction verification and processing information from Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet services
• Identity Verification Services: Verification results, fraud detection signals, and authentication data from third-party KYC/AML service providers
• Marketing Partners: Information about how you found raw90, referral sources, and marketing campaign performance data (aggregated and anonymized)

3. How We Use Your Information

raw90 uses your personal information for the following purposes, based on legal grounds including contract performance, legal obligations, legitimate interests, and your consent where applicable:

3.1 Service Provision and Account Management

• Create, maintain, and manage your raw90 account
• Process deposits, withdrawals, and financial transactions
• Enable gameplay across sports betting, casino, slots, and togel (lottery) offerings
• Track betting activity, calculate winnings, and settle bets
• Manage bonuses, promotions, and loyalty rewards
• Provide customer support and respond to inquiries

3.2 Legal and Regulatory Compliance

• Verify your identity and age (21+ requirement) through KYC procedures
• Comply with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations
• Detect and prevent fraud, collusion, money laundering, and other illegal activities
• Enforce our Terms & Conditions and other policies
• Maintain transaction records as required by applicable gaming regulations
• Respond to legal requests from law enforcement or regulatory authorities

3.3 Security and Risk Management

• Monitor account activity for suspicious or unusual behavior
• Detect and prevent unauthorized access, account takeover, and security breaches
• Identify and block duplicate accounts, bonus abuse, and Terms violations
• Protect the integrity of games and betting markets
• Prevent underage gambling and self-excluded users from accessing services

3.4 Service Improvement and Analytics

• Analyze usage patterns to improve platform performance and user experience
• Develop new features, games, and betting markets based on user preferences
• Conduct market research and analyze trends in Indonesian gaming preferences
• Optimize website and mobile platform functionality
• Test new technologies and features

3.5 Marketing and Communications

• Send promotional offers, bonuses, and special promotions (with your consent)
• Notify you about new games, features, and platform updates
• Deliver personalized content and recommendations based on your preferences
• Send important service announcements, security alerts, and policy updates
• Conduct customer satisfaction surveys and feedback requests

You may opt out of promotional communications at any time by adjusting your account settings or clicking unsubscribe links in emails. However, you cannot opt out of essential service communications related to your account security, transactions, or legal notices.

4. Data Sharing and Disclosure

raw90 does not sell your personal information to third parties. We share your information only in the limited circumstances described below, with appropriate safeguards to protect your privacy:

4.1 Service Providers and Business Partners

We share information with trusted third-party service providers who perform services on our behalf, including:

• Payment Processors: Indonesian banks and e-wallet providers to process deposits and withdrawals
• Identity Verification Providers: KYC/AML service providers to verify your identity and comply with regulatory requirements
• Cloud Infrastructure Providers: Hosting services and data storage providers
• Customer Support Tools: Live chat platforms and support ticket management systems
• Game Providers: Casino game suppliers and sports betting data providers
• Analytics Services: Website analytics and performance monitoring tools

These service providers are contractually obligated to use your information only as necessary to provide services to raw90 and to implement appropriate security measures. They are prohibited from using your data for their own purposes.

4.2 Legal Requirements and Protection of Rights

We may disclose your information when required by law or when we believe disclosure is necessary to:

• Comply with court orders, subpoenas, or other legal processes
• Respond to requests from government authorities or law enforcement agencies
• Enforce our Terms & Conditions and other agreements
• Protect the rights, property, or safety of raw90, our users, or the public
• Detect, prevent, or address fraud, security, or technical issues
• Prevent or investigate suspected illegal activities

4.3 Business Transfers

If raw90 is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on our website before your information becomes subject to a different privacy policy.

4.4 With Your Consent

We may share information with third parties when you explicitly consent to such sharing, such as when participating in specific promotions or integrated services.

5. Data Security Measures

raw90 implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security practices include:

5.1 Technical Security

• Encryption: All data transmission between your device and raw90 servers is protected using SSL/TLS 256-bit encryption, the same standard used by banks and financial institutions
• Secure Storage: Personal and financial data is encrypted at rest using industry-standard encryption algorithms
• Firewalls: Advanced firewall systems protect our infrastructure from external threats
• Intrusion Detection: Real-time monitoring systems detect and respond to security threats
• Access Controls: Role-based access restrictions ensure only authorized personnel can access sensitive data

5.2 Administrative Security

• Employee Training: All staff receive regular training on data protection and security best practices
• Confidentiality Agreements: Employees and contractors sign strict confidentiality agreements
• Background Checks: Security-sensitive roles require comprehensive background verification
• Incident Response: Documented procedures for responding to data breaches and security incidents

5.3 Account Security

• Strong Password Requirements: Enforced password complexity standards
• Account Monitoring: Automated detection of unusual login patterns and suspicious activity
• Session Management: Automatic logout after periods of inactivity
• Fraud Prevention: Multi-layered systems to detect and prevent fraudulent transactions

While we implement robust security measures, no system is completely secure. You play an important role in protecting your account by maintaining strong, unique passwords, not sharing login credentials, and promptly reporting suspicious activity to our support team.

6. Data Retention

raw90 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Accounts: Personal and account data is retained for the duration of your active membership and for a reasonable period after account closure to handle disputes, chargebacks, or regulatory inquiries
• Transaction Records: Financial transaction data, including deposits, withdrawals, bets, and winnings, is retained for a minimum of 5 years to comply with financial regulations and tax reporting requirements
• KYC Documentation: Identity verification documents are retained for 5 years after account closure as required by Anti-Money Laundering regulations
• Communication Records: Customer support conversations and correspondence are retained for 3 years for quality assurance and dispute resolution
• Marketing Data: If you opt out of marketing communications, we retain minimal information (email address, opt-out status) to honor your preferences

After applicable retention periods expire, we securely delete or anonymize your personal information. Anonymized data that cannot identify you may be retained indefinitely for statistical analysis and service improvement.

7. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. raw90 respects these rights and provides mechanisms to exercise them:

7.1 Right to Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of your personal information. You can access most of your data directly through your raw90 account dashboard. For additional information, contact our privacy team.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most account information directly in your account settings. For changes to verified information (name, date of birth), contact customer support with supporting documentation.

7.3 Right to Deletion

You may request deletion of your personal information, subject to certain exceptions. We must retain some data to comply with legal obligations, resolve disputes, or enforce agreements. To request account deletion, contact [email protected]. Note that account deletion is permanent and cannot be undone.

7.4 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format. Contact our privacy team to request data export.

7.5 Right to Object and Restrict Processing

You may object to processing of your personal data for marketing purposes or based on legitimate interests. You can opt out of marketing communications in your account settings or by clicking unsubscribe links in emails.

7.6 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw consent at any time. This does not affect the lawfulness of processing before consent withdrawal.

To exercise any of these rights, contact us at [email protected]. We will respond to your request within 30 days. Some requests may require identity verification to protect your privacy.

8. Cookies and Tracking Technologies

raw90 uses cookies and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content. Types of technologies we use include:

8.1 Essential Cookies

These cookies are necessary for the raw90 platform to function properly. They enable core features like account login, session management, security, and transaction processing. Essential cookies cannot be disabled without impairing platform functionality.

8.2 Performance and Analytics Cookies

These cookies collect information about how you use raw90, including pages visited, time spent, and features accessed. We use this data to improve platform performance, identify technical issues, and optimize user experience. Analytics data is typically aggregated and anonymized.

8.3 Functionality Cookies

These cookies remember your preferences and settings, such as language choice, timezone, and display preferences, providing a more personalized experience across sessions.

8.4 Marketing and Advertising Cookies

With your consent, we may use cookies to deliver relevant promotional offers and track the effectiveness of marketing campaigns. You can manage marketing cookie preferences in your account settings.

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. However, disabling cookies may limit your ability to use certain features of the raw90 platform. Refer to your browser's help documentation for instructions on managing cookies.

9. Third-Party Services

raw90 integrates with third-party services to provide comprehensive gaming experiences, process payments, and deliver support services. These third parties have their own privacy policies governing how they collect and use information. We encourage you to review these policies:

• Payment Providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet services (OVO, DANA, GoPay, ShopeePay, LinkAja) operate under their own privacy policies and terms of service
• Game Providers: Casino games and live dealer tables are supplied by third-party providers who may collect gameplay data
• Customer Support Tools: Live chat and communication platforms may collect conversation data

raw90 is not responsible for the privacy practices of third-party services. When you interact with these services through our platform, their privacy policies apply.

10. Children's Privacy

raw90 services are strictly intended for individuals who are at least 21 years of age, as required by Indonesian law and our Terms & Conditions. We do not knowingly collect personal information from individuals under 21 years of age.

If we discover that we have inadvertently collected information from someone under 21, we will immediately delete that information and permanently close the associated account. Parents or guardians who believe their child has provided personal information to raw90 should contact us immediately at [email protected] so we can take appropriate action.

We implement age verification procedures during account registration and may request additional verification at any time. Providing false age information is a serious violation of our Terms & Conditions and may result in legal consequences.

11. Changes to This Privacy Policy

raw90 reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our practices, technologies, legal requirements, or business operations. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Privacy Policy
• Post the revised Privacy Policy on the raw90 website
• Notify registered users via email if changes significantly affect how we process personal information
• Display prominent notices on the raw90 platform for a reasonable period

Your continued use of raw90 services after Privacy Policy changes become effective constitutes acceptance of the updated policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

If you disagree with changes to this Privacy Policy, you must discontinue using raw90 services and may request account closure.

12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or how raw90 handles your personal information, please contact our privacy team:

• Privacy Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the raw90 website
• Response Time: We aim to respond to privacy inquiries within 3 business days, with full resolution within 30 days as required by data protection regulations

For formal complaints or unresolved privacy concerns, you may have the right to lodge a complaint with your local data protection authority or supervisory body, depending on your jurisdiction.