Privacy Policy

1. Introduction

This Privacy Policy applies to all personal data processed by klub4d ("we," "us," "our") through the website located at https://klub4d.cam and all associated mobile and web-based services (collectively, the "Platform"). It governs the relationship between klub4d and any individual ("User," "you," "your") who visits, registers, or interacts with the Platform.

By accessing our website or creating an account, you acknowledge that you have read and understood this Privacy Policy and that you consent to the data practices described herein. If you do not agree with any part of this policy, you should discontinue use of the Platform immediately and contact us to close your account.

This policy should be read alongside our Terms & Conditions and our Responsible Gaming guidelines, which together form the complete framework governing your use of klub4d services.

2. Definitions

• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, directly or indirectly. This includes names, identity card numbers, email addresses, telephone numbers, IP addresses, and device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, modification, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means klub4d, 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 klub4d in accordance with our instructions and this policy.
• "Consent" means freely given, specific, informed, and unambiguous agreement to the processing of your personal data for a stated purpose.
• "KYC" (Know Your Customer) means the identity verification procedures we use to comply with anti-money-laundering regulations and to confirm your age and identity.

3. Information We Collect

3.1 Information You Provide Directly

When you register for an account, verify your identity, or contact our support team, you may provide us with the following categories of personal data:

• Identity Information: Full legal name, date of birth, gender, and nationality, as recorded on your Indonesian KTP (national identity card) or passport.
• Contact Information: Email address, Indonesian mobile phone number, and residential address (including city, province, and postal code).
• Financial Information: Indonesian bank account details (bank name, account number, account holder name) for deposit and withdrawal purposes — for example, accounts at BCA, BRI, BNI, Mandiri, CIMB Niaga, or OCBC NISP. E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, or LinkAja.
• Verification Documents: Copies of government-issued identity documents submitted during KYC verification, including photographs where required.
• Communications: Records of correspondence when you contact our customer support team, including live chat transcripts, email exchanges, and support ticket records.

3.2 Information Collected Automatically

When you access our Platform, certain technical data is collected automatically by our systems and third-party analytics tools:

• Usage Data: Pages visited, time spent on each page, links clicked, games played, bets placed, deposit and withdrawal history, and session duration.
• Device & Technical Data: IP address, browser type and version, operating system, device type (mobile, tablet, desktop), screen resolution, and time zone settings.
• Geolocation Data: Approximate location derived from your IP address, used to verify that you are accessing our Platform from Indonesia and to comply with geographic access controls.
• Cookies and Similar Technologies: Session cookies, persistent cookies, local storage data, and pixel tags used to maintain your session, remember preferences, and analyze traffic patterns. See Section 7 for full details.

3.3 Information from Third Parties

In certain circumstances, we may receive information about you from third parties, including:

• Payment processors and Indonesian banks, confirming the status and details of transactions.
• Identity verification service providers used to authenticate your KYC documents.
• Fraud prevention agencies and credit reference bureaus, where permitted by law.
• Responsible gaming registries, where you have self-excluded from gambling services.

4. How We Use Your Personal Data

klub4d processes your personal data for the following purposes:

5. Legal Basis for Processing

We process your personal data only when we have a valid legal basis to do so. The primary legal bases we rely on are:

• Contract Performance: Processing is necessary to deliver the services you have signed up for — including account management, gameplay, and transaction processing. Without this data, we cannot provide our services.
• Legal Obligation: Certain processing is required to comply with Indonesian law, including anti-money-laundering regulations, age verification requirements, and financial record-keeping obligations. We must collect and retain this data regardless of your preferences.
• Legitimate Interest: We process some data to pursue our legitimate business interests — such as preventing fraud, improving the Platform, and ensuring network security — provided those interests do not override your fundamental rights.
• Consent: For non-essential processing — such as sending prom otional emails or using optional analytics cookies — we will ask for your explicit consent. You may withdraw consent at any time by contacting us, though this will not affect the lawfulness of processing carried out before withdrawal.

6. Data Sharing and Disclosure

klub4d does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following limited circumstances:

6.1 Service Providers and Data Processors

We engage trusted third-party service providers to assist in delivering our Platform. These processors act only on our instructions and are contractually bound to protect your data. Categories of processors include:

• Payment processing providers and Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja) for deposit and withdrawal handling.
• Identity verification and KYC service providers for document authentication.
• Cloud hosting and infrastructure providers that store Platform data on secure servers.
• Customer support software providers that power our live chat and ticketing systems.
• Analytics and fraud detection platforms that monitor usage patterns and suspicious activity.
• Game software providers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and Spribe, to the extent needed to deliver game sessions and resolve disputes.

6.2 Legal and Regulatory Disclosure

We may disclose your personal data to government authorities, regulatory bodies, law enforcement agencies, or courts where we are legally required to do so — for example, in response to a valid court order, subpoena, or regulatory investigation under Indonesian law. We will notify you of such disclosures where we are legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business assets, your personal data may be transferred to the acquiring entity. We will notify you before your data is transferred and becomes subject to a different privacy policy.

6.4 Protection of Rights

We may share your data where we reasonably believe disclosure is necessary to protect the rights, property, or safety of klub4d, our users, or the public — including for fraud prevention, anti-money-laundering compliance, and enforcement of our Terms & Conditions.

7. Cookies and Tracking Technologies

klub4d uses cookies and similar technologies to operate the Platform, maintain your session, remember your preferences, and analyze how users interact with our services. By using the Platform, you consent to our use of cookies as described below.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. They enable core features such as secure login sessions, remembering items in your betting slip, and maintaining your account state as you navigate the site. These cookies cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies: These collect aggregated, anonymized data about how visitors use the Platform — which pages are most visited, where users drop off, and how long sessions last. We use this data to improve user experience and Platform performance.
• Functional Cookies: These remember your preferences — such as language settings, preferred odds format, and deposit method — so you do not need to reconfigure them on each visit.
• Security Cookies: Used to detect fraudulent activity, prevent unauthorized account access, and support our fraud monitoring systems. These are classed as strictly necessary and cannot be disabled.

7.2 Managing Cookies

You may control non-essential cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies via their privacy or settings menus. Please note that blocking certain cookies may reduce the functionality of the Platform — for example, you may need to log in on every visit or re-enter preferences each session. Strictly necessary and security cookies cannot be disabled while you use the Platform.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Our general retention periods are as follows:

• Active Account Data: Retained for the duration of your account relationship with klub4d and for a period of five (5) years following account closure, in accordance with Indonesian financial record-keeping requirements.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of verification, or longer if required by anti-money-laundering regulations.
• Transaction Records: Deposit, withdrawal, and betting history records are retained for five (5) years to comply with Indonesian financial and tax regulations.
• Customer Support Records: Communications records are retained for two (2) years following the resolution of the relevant query or complaint.
• Marketing Consent Records: Records of your consent to or opt-out from marketing communications are retained for the duration of your account relationship plus three (3) years.
• Technical Logs: Server logs and security logs are retained for up to twelve (12) months for fraud investigation and platform security purposes.

When data is no longer required and no legal obligation requires its retention, we securely delete or anonymize it in accordance with industry best practices.

9. Data Security

klub4d implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security practices include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard Transport Layer Security (TLS) with a 256-bit encryption key — the same standard used by major international banks.
• Encrypted Data Storage: Sensitive personal and financial data stored on our servers is encrypted at rest. Encryption keys are stored separately from the data they protect.
• Access Controls: Access to personal data within our organization is granted on a strict need-to-know basis. Staff with access to personal data undergo background checks and mandatory data protection training.
• Two-Factor Authentication (2FA): Available for all user accounts as an additional layer of protection against unauthorized access. We strongly encourage all users to enable 2FA.
• Intrusion Detection Systems: We employ automated systems to detect and respond to suspicious activity, unauthorized access attempts, and potential data breaches in real time.
• Regular Security Audits: Our Platform and security infrastructure undergo periodic third-party security assessments and penetration testing to identify and address vulnerabilities proactively.
• Data Breach Response: In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected users and relevant authorities within the timeframes required by applicable law.

While we take every reasonable precaution to protect your data, no method of electronic transmission or storage is entirely risk-free. We encourage you to maintain strong, unique passwords, enable 2FA, and contact us immediately if you suspect unauthorized access to your account.

10. Your Privacy Rights

Subject to applicable Indonesian law and certain legal exceptions, you have the following rights regarding your personal data held by klub4d:

• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is used and with whom it has been shared.
• Right to Rectification: If any personal data we hold is inaccurate or incomplete, you have the right to request that we correct or update it.
• Right to Erasure: In certain circumstances, you may request that we delete your personal data. Note that this right may be limited where we are legally required to retain data — for example, to comply with anti-money-laundering regulations or pending dispute resolution.
• Right to Restrict Processing: You may request that we restrict the processing of your data in certain situations — for example, while we verify the accuracy of data you have disputed.
• Right to Data Portability: Where processing is based on your consent or a contract, you may request that we provide your data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
• Right to Object: You may object to processing based on legitimate interest, including profiling for direct marketing purposes. Where you object to direct marketing, we will cease that processing immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact our support team at [email protected] (plain text, not a link). We will respond to all verified requests within 30 days. We may need to verify your identity before processing a request to protect against unauthorized access to your data.

11. Children's Privacy

klub4d's services are strictly intended for adults. You must be at least 21 years of age to register an account and use our Platform. We do not knowingly collect personal data from individuals under 21 years of age. If we become aware that we have inadvertently collected data from a person under 21, we will immediately close the associated account, void any transactions, and delete the personal data in question.

If you are a parent or guardian and believe that a minor has accessed or registered on our Platform, please contact us immediately at [email protected] so that we can take prompt remedial action.

12. Third-Party Links and Services

Our Platform may contain references to third-party game providers (such as Pragmatic Play, Evolution Gaming, and Microgaming) and payment service providers. While we work only with reputable partners, we are not responsible for the privacy practices of these third parties. Each third-party provider operates under its own privacy policy. We encourage you to review the privacy policies of any third-party service you interact with through our Platform.

klub4d does not embed third-party advertising networks or social media tracking pixels on our Platform. We do not share your data with advertising platforms for behavioral targeting or retargeting purposes.

13. Changes to This Privacy Policy

We reserve the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform functionality. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page.
• Display a prominent notice on the Platform homepage for a minimum of 14 days following the change.
• Where feasible, notify registered users via the email address on file.

Your continued use of the Platform after the effective date of any revised policy constitutes your acceptance of the updated terms. If you object to any changes, you should close your account and cease using our services before the revised policy takes effect.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our Data Protection team using the details below. We take all privacy inquiries seriously and aim to respond within 5 business days (WIB, Western Indonesia Time, UTC+7):

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly on the Platform
• Response Time: Within 5 business days for privacy-related requests; within 30 days for formal data subject access requests