Privacy Policy — ky4d Data Protection

Throughout this Privacy Policy, the following terms carry the meanings assigned to them below:

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, including name, email address, phone number, date of birth, financial account details, device identifiers, and IP addresses.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means ky4d, the entity that determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means any third party engaged by ky4d to process Personal Data on our behalf and under our instructions.
• "Platform" means the ky4d website accessible at https://ky4d.cam and all associated services.
• "Player" / "You" means any individual who registers an account on or accesses the Platform.
• "KYC Documents" means identity verification documents including national ID (KTP), passport, proof of address, and selfie verification images.
• "Cookies" means small text files placed on your device by the Platform for the purposes described in Section 9 of this policy.

ky4d acts as the Data Controller for all Personal Data collected through the Platform. This means ky4d is responsible for deciding how and why your data is processed, and is accountable for ensuring that processing is lawful, fair, and transparent.

ky4d operates under an international gaming license and processes data in compliance with the data protection standards required by that licensing regime. While the Platform is specifically designed to serve players in Indonesia — supporting local payment methods including BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja — the Data Controller entity is registered in the licensing jurisdiction, not in Indonesia.

For all privacy-related inquiries, including data access requests, please contact our Data Protection team at [email protected].

ky4d collects Personal Data through three primary channels: information you provide directly, information generated automatically by your use of the Platform, and information received from third-party service providers. The table below summarizes what we collect and why.

ky4d uses your Personal Data exclusively for the following purposes:

• Account Management: To create, maintain, and administer your player account, including processing login sessions and account security alerts.
• Identity Verification (KYC): To verify that you meet the minimum age requirement of 21 years and that your identity matches the payment methods registered to your account.
• Transaction Processing: To facilitate deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, and LinkAja, and to maintain accurate records of your financial history on the Platform.
• Fraud Prevention and Security: To detect and prevent unauthorized account access, money laundering, bonus abuse, multi-accounting, and other forms of prohibited conduct as defined in our Terms & Conditions.
• Responsible Gaming: To monitor gameplay patterns that may indicate problem gambling behavior, to enforce player-requested deposit and loss limits, and to action self-exclusion requests. See our Responsible Gaming Policy for full details.
• Customer Support: To respond to your inquiries, resolve disputes, process complaints, and provide technical assistance.
• Platform Improvement: To analyze aggregated, anonymized usage data to improve Platform performance, game selection, and user experience.
• Legal and Regulatory Compliance: To fulfill obligations imposed by our international gaming license, including record-keeping, anti-money-laundering (AML) reporting, and cooperation with lawful information requests from competent authorities.
• Promotional Communications: To send you relevant bonus offers, tournament notifications, and seasonal promotions (such as those tied to BRI Liga 1 fixtures, Ramadhan, or Idul Fitri) where you have not opted out of marketing communications.

ky4d processes your Personal Data under the following legal bases:

• Contractual Necessity: Processing your registration data, financial data, and KYC documents is necessary to perform the contract between you and ky4d (i.e., to operate your account and provide the services you have requested).
• Legal Obligation: Certain processing activities — particularly KYC verification, AML record-keeping, and cooperation with licensing authority requests — are required by law as conditions of our international gaming license.
• Legitimate Interests: Fraud detection, security monitoring, platform analytics, and responsible gaming interventions are carried out on the basis of ky4d's legitimate interest in operating a safe, fair, and compliant platform. These interests are balanced against your privacy rights.
• Consent: Marketing communications are sent only where you have expressly consented at registration or have not opted out following a clear opt-out opportunity. You may withdraw consent for marketing communications at any time by contacting support.

ky4d does not sell your Personal Data. We share data only in the following strictly defined circumstances:

• Payment Processors: Your financial data is shared with licensed payment processors and banking partners (including those facilitating transfers to and from BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja) solely to the extent necessary to execute transactions.
• KYC Verification Providers: Identity documents may be processed by a contracted third-party KYC verification service. Such providers operate under strict data processing agreements and may not use your data for any purpose other than identity verification on our behalf.
• Game Content Providers: Usage data relevant to specific games (e.g., Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft, NetEnt, Microgaming) may be shared with those studio providers to the extent required to deliver game functionality and resolve game disputes.
• Fraud Prevention Networks: In cases of suspected fraud, money laundering, or multi-accounting, ky4d may share relevant data with industry fraud-prevention consortiums and, where legally required, with law enforcement authorities.
• Licensing Authority: Our licensing authority may require us to provide player records as part of regulatory audits or investigations. We are legally obligated to comply with such requests.
• Legal Proceedings: We may disclose Personal Data where required by a valid court order, subpoena, or other lawful legal process.

As an internationally licensed platform serving players in Indonesia, ky4d may transfer your Personal Data across national borders — specifically between Indonesia and the jurisdiction in which our servers and licensing authority are located.

When your data is transferred internationally, ky4d ensures that appropriate safeguards are in place, including:

• Data Processing Agreements incorporating internationally recognized model clauses for data transfer;
• Storage and processing on servers protected by enterprise-grade physical and logical security controls;
• Encryption of data in transit and at rest throughout the transfer chain.

By registering on the Platform, you acknowledge and consent to the international transfer of your Personal Data under the safeguards described in this section.

ky4d retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected, subject to the minimum retention periods imposed by our licensing obligations. The following schedule applies:

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized so that it can no longer be attributed to any individual.

ky4d uses cookies and similar technologies to operate and improve the Platform. We use only the following categories of cookies:

• Strictly Necessary Cookies: These are essential for the Platform to function. They enable session management, secure login, and core platform features. You cannot opt out of these cookies while using the Platform.
• Functional Cookies: These remember your preferences — such as language settings and display options — to provide a personalized experience across sessions.
• Analytics Cookies: We use anonymized analytics to understand how players navigate the Platform, which pages are most visited, and where technical issues occur. This data cannot be used to identify individual users.
• Fraud Prevention Cookies: These cookies help us detect and block suspicious access patterns, including automated bots and multi-account creation attempts.

ky4d does not use third-party advertising cookies, retargeting pixels, social media tracking scripts, or any tracking technology that follows your activity across other websites.

You may configure your browser to block or delete cookies at any time. Please note that disabling strictly necessary cookies will impair your ability to use the Platform.

You hold the following rights in relation to your Personal Data held by ky4d. To exercise any of these rights, contact us at [email protected]. We will respond to all valid requests within 30 calendar days.

ky4d implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, or disclosure:

• TLS/SSL Encryption: All data in transit between your device and our servers is encrypted using current-generation Transport Layer Security (TLS 1.2 or higher).
• AES-256 Encryption at Rest: Sensitive data — including KYC documents, financial records, and account credentials — is stored in encrypted form using AES-256.
• Access Controls: Access to Personal Data within ky4d is restricted on a strict need-to-know basis. Staff members are granted access only to the data required to perform their specific role.
• Two-Factor Authentication (2FA): All internal administrative systems that can access player data require multi-factor authentication.
• Regular Security Audits: ky4d conducts periodic third-party security assessments and penetration testing of its platform infrastructure.
• Incident Response: In the event of a data breach that poses a risk to your rights, ky4d will notify affected players and the relevant regulatory authority within the timeframe required by applicable law.

While we take every reasonable precaution, no digital platform can guarantee absolute security. You are also responsible for maintaining the security of your own account credentials — do not share your password with anyone, and contact us immediately if you suspect unauthorized account access.

The ky4d Platform is strictly for adults aged 21 years and over. We do not knowingly collect Personal Data from individuals under the age of 21. If ky4d discovers or is notified that a registered account belongs to a person under 21, the account will be immediately suspended, all data associated with it will be retained only as required by our AML obligations, and all other data will be scheduled for deletion in accordance with our retention policy.

If you are a parent or guardian and believe that a minor in your care has registered an account on ky4d, please contact us immediately at [email protected]. We will investigate and act promptly.

The ky4d Platform may contain references to third-party services, such as payment providers (BCA internet banking, OVO app) or game studio portals. ky4d has no control over the privacy practices of those third-party platforms and is not responsible for their content or data handling.

We recommend reviewing the privacy policy of any third-party service you access in connection with your use of ky4d. This Privacy Policy applies solely to the ky4d Platform at https://ky4d.cam.

ky4d reserves the right to update 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 players by email and update the "Last Updated" date at the top of this page.

Your continued use of the Platform following notification of a policy update constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated terms, you should discontinue use of the Platform and contact us to request account closure and data handling instructions.

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data, please reach out to our Data Protection team:

• Email: [email protected]
• Subject Line: "Privacy Request — [Your Registered Email]"
• Response Time: We aim to respond to all privacy-related inquiries within 5 business days, and to fulfill all data rights requests within 30 calendar days.
• Support Hours: 24/7, including Indonesian public holidays such as Idul Fitri, Idul Adha, and Indonesian Independence Day (17 August)
• Languages: English and Indonesian (Bahasa Indonesia)

For responsible gaming concerns, please visit our dedicated Responsible Gaming page for self-help tools and support resources.