Privacy Policy

This Privacy Policy ("Policy") applies to all personal data processed by pele4d in connection with your use of the website at pele4d.cam and all associated mobile interfaces, APIs, and gaming environments (collectively, the "Platform"). By registering an Account or continuing to use the Platform, you acknowledge that you have read, understood, and consent to the practices described in this Policy.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. Where this Policy conflicts with any other document, this Policy governs with respect to privacy and personal data matters.

1Definitions

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Account" — the registered user profile created by a Member on the pele4d Platform.
• "Consent" — any freely given, specific, informed, and unambiguous indication of agreement by which a data subject signifies acceptance of the processing of their personal data.
• "Data Controller" — the entity that determines the purposes and means of processing personal data; in this context, pele4d.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller pursuant to a written data processing agreement.
• "Member" — any individual who has completed account registration on the Platform and is subject to the Terms & Conditions.
• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, phone number, Indonesian national identification number, payment account details, IP address, device identifiers, and behavioral data.
• "Processing" — any operation performed on personal data, whether by automated means or otherwise, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Sensitive Data" — a subset of personal data that warrants heightened protection, including financial account information, identity document numbers, and data revealing health status or religious affiliation.

2Data Controller

pele4d acts as the Data Controller for all personal data collected through and processed in connection with the Platform. As Data Controller, pele4d is responsible for determining the purposes for which your personal data is processed and for ensuring that processing is carried out lawfully, fairly, and transparently.

For all data protection enquiries, requests to exercise your rights, or complaints regarding the handling of your personal data, please contact our dedicated Data Protection team using the details provided in Section 15 of this Policy.

3Data We Collect

pele4d collects only the personal data necessary to provide you with a safe, compliant, and personalized gaming experience. The categories of data we collect are as follows:

3.1 Registration Data

• Full legal name (as it appears on government-issued identification).
• Date of birth (to verify you are 21 years of age or older).
• Valid email address.
• Indonesian mobile phone number.
• City and province of residence within Indonesia (e.g., Jakarta, Surabaya, Medan, Bandung, Bali).
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (KTP — Kartu Tanda Penduduk, passport, or driving license).
• Proof of residential address (utility bill, bank statement, or official correspondence dated within the last three months).
• Selfie photograph for liveness checks where required by our verification provider.
• Source-of-funds declaration for transactions exceeding defined thresholds.

3.3 Financial Data

• Bank account name, number, and bank code for BCA, BRI, BNI, Mandiri, CIMB Niaga, or Bank Permata.
• E-wallet account details for OVO, DANA, GoPay, and ShopeePay.
• Transaction history: deposit amounts, withdrawal amounts, dates, and payment method used.
• Betting and wagering history, including game type, stake amount, and outcome.

3.4 Technical and Usage Data

• IP address and geolocation data derived therefrom.
• Device type, operating system version, browser type, and unique device identifiers.
• Session logs: login timestamps, pages visited, features accessed, and session duration.
• Game interaction data: bets placed, games launched, and feature triggers.
• Crash reports and error logs submitted automatically by the Platform client.

3.5 Communication Data

• Contents of messages sent to pele4d support via live chat, email, or any in-Platform messaging feature.
• Records of promotional communications you have opted in to receive.
• Call recordings (where applicable) if telephone support is used.

4How We Collect Data

pele4d collects personal data through the following channels:

4.1 Directly From You

• When you complete the account registration form on the Platform.
• When you submit KYC verification documents to our support team or automated verification portal.
• When you make a deposit or request a withdrawal via any supported Indonesian payment channel.
• When you contact our customer support team via live chat or email.
• When you opt in to receive promotional emails, SMS notifications, or in-Platform push notifications.
• When you participate in surveys, competitions, or promotional campaigns run by pele4d.

4.2 Automatically Through the Platform

• Via server logs that record your IP address, browser type, and device information each time you access the Platform.
• Via cookies and similar tracking technologies embedded in the Platform (see Section 7 for full details).
• Via game engine telemetry that records gameplay interactions for fraud detection, game integrity, and personalization purposes.
• Via analytics tools that aggregate session behavior across the Platform to improve user experience.

4.3 From Third Parties

• From our KYC and identity verification partners, who return structured identity-match scores and document authenticity assessments.
• From payment processors and Indonesian banking partners (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay) who confirm transaction status and account ownership.
• From fraud-detection and anti-money-laundering screening services that flag high-risk profiles against watchlists.
• From game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) that return game session metadata to our platform systems.

5Purpose & Legal Basis for Processing

pele4d processes your personal data only where a valid legal basis exists. The table below summarizes each processing purpose, the data categories involved, and the corresponding legal basis.

6Data Sharing & Disclosure

pele4d does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following limited circumstances:

6.1 Service Providers (Data Processors)

We engage carefully selected third-party service providers who process personal data strictly on our behalf and under binding data processing agreements. These include:

• KYC and identity verification providers — to authenticate your identity documents and perform age verification.
• Payment processors and Indonesian banking partners — including infrastructure connecting to BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and ShopeePay — to execute deposit and withdrawal transactions.
• Game content studios — Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive the minimum session data necessary to deliver their game content and maintain game integrity.
• Cloud infrastructure and hosting providers — who store Platform data in secure, access-controlled data centers.
• Fraud prevention and AML screening services — who cross-reference Member data against international watchlists and risk databases.
• Customer support platform providers — who power our live chat and ticketing systems.

6.2 Legal and Regulatory Disclosure

pele4d may disclose personal data to competent authorities, law enforcement agencies, or regulatory bodies where required to do so by applicable law, court order, or regulatory directive. In such cases, we will disclose only the minimum data necessary to satisfy the legal requirement and, where permitted, will notify the affected Member.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of pele4d's assets, Member personal data may be transferred to the acquiring entity as part of that transaction. We will provide reasonable advance notice of any such transfer and the acquiring entity will be required to honor the commitments made in this Policy.

7Cookies & Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files placed on your device by the Platform when you visit. They allow the Platform to recognize your device on subsequent visits, remember your preferences, maintain your login session, and collect analytics data about how the Platform is used.

7.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for core Platform functionality, including maintaining your authenticated session, processing transactions, and remembering your language preferences. These cannot be disabled without breaking core features.
• Performance and Analytics Cookies: Collect anonymized information about how Members navigate the Platform — pages visited, features used, and session duration — to help us improve the user experience. No personally identifiable information is captured by these cookies.
• Functionality Cookies: Remember your preferences such as preferred payment method, notification settings, and display configuration to provide a more personalized experience.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and session hijacking attempts. These cookies are essential for Platform security and cannot be disabled.

7.3 Managing Cookies

You may configure your browser settings to refuse or delete cookies at any time. Please note that disabling strictly necessary or security cookies will significantly impair your ability to use the Platform. Detailed instructions for managing cookies in common browsers (Chrome, Firefox, Safari, Edge) are available in each browser's help documentation. Your cookie preferences on the pele4d Platform can also be managed through your Account settings.

8Data Security

pele4d implements a comprehensive, layered security framework designed to protect your personal data against unauthorized access, accidental loss, alteration, or disclosure. Our key security measures include:

• TLS/SSL Encryption: All data transmitted between your device and our servers is encrypted using industry-standard TLS 1.2 or higher protocols.
• Data Encryption at Rest: Sensitive data stored in our databases — including KYC documents, financial account details, and identity information — is encrypted using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized pele4d personnel on a strict need-to-know basis. Access is logged, audited, and reviewed regularly.
• Two-Factor Authentication (2FA): Available to all Members for Account login, and mandatory for all internal administrative access to Member data.
• Regular Security Audits: Our Platform infrastructure undergoes regular penetration testing and security audits conducted by independent third-party security firms.
• Data Breach Response Plan: In the event of a confirmed personal data breach that poses a risk to Members, pele4d will notify affected Members within 72 hours of becoming aware of the breach, consistent with applicable data protection obligations.

9Data Retention

pele4d retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Where anonymization is used, the resulting aggregated data may be retained indefinitely for statistical and analytical purposes, as it can no longer be linked to any individual.

10International Data Transfers

pele4d operates a globally distributed infrastructure and engages service providers located in various countries. As a result, your personal data may be transferred to and processed in countries outside Indonesia. Such countries may have data protection laws that differ from those applicable in Indonesia.

Where such transfers occur, pele4d ensures that appropriate safeguards are in place to protect your personal data, including:

• Binding contractual clauses with all international service providers that require them to uphold data protection standards equivalent to those described in this Policy.
• Transfers only to service providers located in jurisdictions that maintain recognized adequacy standards for personal data protection.
• Regular review and audit of international data processing arrangements to ensure continued compliance.

You may request further information about the specific safeguards in place for any international transfer of your personal data by contacting our Data Protection team at [email protected].

11Your Privacy Rights

As a Member of pele4d, you hold the following rights in respect of your personal data. To exercise any of these rights, contact our Data Protection team at [email protected] with the subject line "Privacy Rights Request". We will respond within 30 calendar days.

• Right of Access: You have the right to request a copy of all personal data we hold about you, together with information about how it is being processed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to legal retention obligations that may require us to retain certain records regardless.
• Right to Restriction of Processing: You may request that we restrict processing of your data in certain circumstances, such as while a rectification request is being assessed.
• Right to Data Portability: Where processing is based on consent or contract performance and is carried out by automated means, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interest grounds, including profiling for marketing purposes. Upon receipt of a valid objection, pele4d will cease that processing unless compelling legitimate grounds can be demonstrated that override your interests.

12Minors & Age Restrictions

pele4d strictly prohibits the use of the Platform by any person under the age of 21 years. We do not knowingly collect personal data from individuals under 21. If we become aware that personal data has been collected from a person below this age threshold, we will immediately suspend the associated Account, delete all related personal data, and return any deposited funds to the originating payment method.

Parents and guardians who believe that a minor may have registered an Account on pele4d using false age information are encouraged to contact us immediately at [email protected]. We treat all such reports as urgent and will investigate within 24 hours.

13Third-Party Services

The pele4d Platform integrates with a number of third-party services to deliver core functionality. While we conduct due diligence on all third-party partners and require them to maintain data protection standards consistent with this Policy, please note that this Policy does not govern the privacy practices of third parties operating under their own terms. Third-party services integrated with pele4d include:

• Game Studios: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft each operate their game engines subject to their own privacy and data security policies. Their processing of in-game session data is limited to what is strictly necessary for game delivery and integrity.
• Payment Gateways: Transactions processed via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and ShopeePay are subject to the respective institution's privacy policy in addition to this Policy.
• Analytics Providers: We use privacy-configured analytics tools that collect only anonymized, aggregated behavioral data and do not track individual Members across third-party websites.

pele4d is not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party service that you interact with through the Platform.

14Policy Amendments

pele4d reserves the right to update, revise, or replace this Privacy Policy at any time to reflect changes in our data processing practices, operational requirements, or applicable legal and regulatory obligations. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page.
• Send a notification to your registered email address at least 7 calendar days before the revised Policy takes effect.
• Display a prominent banner on the Platform drawing your attention to the updated Policy.

Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with any changes, you must discontinue use of the Platform and may request Account closure by contacting [email protected].

15Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by pele4d, please contact our Data Protection team using the details below. Our support team operates 24 hours a day, 7 days a week, with native Indonesian-speaking agents available at all times (WIB, UTC+7).

• Email: [email protected] — Subject line: "Privacy Rights Request" or "Data Protection Enquiry"
• Live Chat: Available directly through the Platform interface — average response time under 3 minutes.
• Response Commitment: All written privacy requests acknowledged within 48 hours; fully resolved within 30 calendar days.

If you are not satisfied with our response to any privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction. pele4d will cooperate fully with any such regulatory inquiry.