win4d Privacy Policy

win4d ("we", "our", or "us") operates the online gaming and sports betting platform accessible at win4d.vu (the "Platform"). We are committed to protecting the privacy and personal data of every individual who interacts with our Platform — whether as a registered player, a visitor browsing our site, or a prospective member considering registration.

This Privacy Policy sets out, in clear and transparent terms, the categories of personal data win4d collects, the lawful bases on which we process that data, the purposes for which it is used, the circumstances under which it may be shared, the security measures we apply to protect it, and the rights available to you as a data subject.

win4d's primary player base is located in Indonesia — principally in Jakarta, Surabaya, Bandung, Medan, Bali, and Yogyakarta — and our data practices are designed to reflect the expectations of Indonesian players while maintaining international standards of data protection. All transactions on the Platform are denominated in Indonesian Rupiah (IDR) and conducted through local Indonesian payment channels.

By registering an account, making a deposit, or continuing to use the Platform after this policy has been published, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this policy, you should discontinue use of the Platform and contact us to close your account.

In this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, email address, device identifiers, and financial information.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, erasure, or destruction.
• "Player" / "You" — any individual who accesses, registers on, or uses the Platform in any capacity.
• "Account" — a personal account registered by a Player on the Platform.
• "KYC" — Know Your Customer identity and age verification procedures applied to Player accounts.
• "Cookies" — small text files stored on your device by the Platform to remember preferences, session state, and usage behaviour.
• "Third-Party Processor" — any organisation that processes personal data on win4d's behalf under a contractual arrangement and applicable data protection obligations.
• "Sensitive Data" — a subset of personal data that warrants heightened protection, including identity document images, financial account details, and data relating to health (such as problem gambling indicators).

win4d collects the following categories of personal data, depending on how you interact with the Platform:

Registration & Identity Data

KYC & Verification Data

Financial & Transaction Data

Gaming & Behavioural Data

Technical & Device Data

Communications Data

win4d collects personal data through the following channels:

1. Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, place a bet, contact customer support, or respond to a survey or promotion.
2. Automatically from your device: When you browse or use the Platform, we automatically collect technical data such as your IP address, device identifiers, browser fingerprint, and session behaviour through server logs, cookies, and similar tracking technologies.
3. From payment processors: When you initiate a deposit or withdrawal via BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, DANA, GoPay, ShopeePay, or LinkAja, our payment processing partners share transaction confirmation data with us for reconciliation and fraud-prevention purposes.
4. From identity verification partners: Where we use third-party KYC technology providers to verify the authenticity of identity documents, those providers may return a verification result and associated metadata to win4d.
5. From anti-fraud and risk systems: win4d may receive risk signals or device reputation data from third-party fraud-prevention services to protect the integrity of the Platform.

win4d processes your personal data only where a lawful basis exists. The table below sets out the primary purposes of processing and the corresponding legal basis for each:

win4d does not sell, rent, or trade your personal data. We may share your data with third parties only in the following strictly defined circumstances:

• Payment processors: To facilitate deposits and withdrawals, win4d shares the minimum necessary transaction data with Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja). These processors operate under their own privacy frameworks and applicable Indonesian financial regulations.
• KYC and identity verification providers: To fulfil our age and identity verification obligations, win4d uses third-party KYC technology providers. Document images are transmitted to these providers under contractual data processing agreements.
• Game software providers: Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive anonymised session data to deliver their game content and resolve technical disputes. These providers do not receive personally identifiable information beyond what is technically necessary to deliver the game session.
• Anti-fraud and security vendors: We share technical and behavioural signals with fraud-prevention partners to protect all players and the integrity of the Platform.
• Legal and regulatory authorities: win4d may disclose personal data to law enforcement agencies, regulatory bodies, or courts where required to do so by law, court order, or in connection with any legal proceedings.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of win4d's business, player data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained. Affected players will be notified in advance where practicable.

All third-party processors with whom win4d shares personal data are required to maintain appropriate technical and organisational security measures and to process data only for the specified purposes under our instructions.

win4d retains personal data for as long as is necessary to fulfil the purposes for which it was collected, and in accordance with applicable legal and compliance obligations. The following retention schedule applies:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with financial record-keeping obligations.
• KYC documents: Retained for a minimum of five (5) years following the date of submission or account closure, whichever is later.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming and behavioural logs: Retained for up to three (3) years from the date of the relevant gaming session, unless required for longer retention in connection with a dispute or investigation.
• Support communications: Retained for up to two (2) years from the date of the last communication in a given support case.
• Marketing preferences: Retained for as long as your account is active. Opt-out records are retained indefinitely to ensure suppression is honoured.

When personal data is no longer required under our retention schedule and no legal obligation requires its continued storage, we will securely delete or anonymise it using industry-standard data disposal procedures.

win4d applies a layered approach to data security, incorporating technical, administrative, and physical safeguards proportionate to the sensitivity of the data we process. Key security measures include:

• Encryption in transit: All data transmitted between your browser or device and the Platform is encrypted using TLS 1.2 or higher. HTTPS is enforced site-wide with HTTP Strict Transport Security (HSTS) headers.
• Encryption at rest: Sensitive data stored in our databases — including KYC documents, password hashes, and financial identifiers — is encrypted at rest using AES-256 or equivalent standards.
• Access controls: Internal access to personal data is restricted on a need-to-know basis. Staff are granted the minimum level of access required for their role. Access logs are maintained and reviewed regularly.
• Password security: Player passwords are never stored in plain text. We use strong cryptographic hashing algorithms with salting to protect password data. We encourage all players to use unique, strong passwords and to enable two-factor authentication where available.
• Penetration testing and vulnerability management: The Platform undergoes regular security assessments by independent security professionals. Identified vulnerabilities are remediated on a priority basis.
• Incident response: win4d maintains a documented data breach response procedure. In the event of a breach that is likely to result in risk to affected individuals, we will notify relevant parties in accordance with applicable legal requirements, aiming to do so within 72 hours of becoming aware of the incident.

win4d uses cookies and similar tracking technologies to operate the Platform, personalise your experience, and analyse usage patterns. The following types of cookies are in use:

You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. win4d does not currently respond to Do Not Track (DNT) browser signals, as no universal DNT standard has been adopted.

As a player using the win4d Platform, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We will respond within 30 days of receipt.

win4d is an adults-only platform. You must be at least 21 years of age to register an account and use any of the Platform's services, including sports betting, live casino, slots, and togel (Indonesia's traditional numbers lottery). This age requirement applies regardless of the legal gambling age in your country of residence.

win4d does not knowingly collect, store, or process personal data belonging to individuals under the age of 21. All account registrations are subject to KYC verification, which includes confirmation of date of birth against a government-issued identity document such as an Indonesian National Identity Card (KTP) or passport.

If win4d becomes aware that personal data has been collected from an individual under the age of 21 — whether through a fraudulent registration or any other means — we will immediately suspend the relevant account, reverse any transactions where possible, delete the associated personal data, and escalate the matter to our compliance team for further review.

win4d's Platform is operated internationally, and certain third-party processors with whom we share data may be located in jurisdictions outside Indonesia. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that applicable in the data subject's jurisdiction, win4d takes appropriate safeguards to ensure that the transfer is lawful and that the data remains adequately protected.

Such safeguards may include:

• Entering into contractual data processing agreements that incorporate internationally recognised standard contractual clauses for the transfer of personal data.
• Transferring data only to processors located in countries or regions that have been assessed as providing adequate data protection.
• Applying supplementary technical measures, such as end-to-end encryption, where additional protection is warranted.

By using the Platform, you acknowledge that your personal data may be transferred to, stored, and processed in jurisdictions outside Indonesia, subject to the safeguards described in this section.

win4d reserves the right to update or amend this Privacy Policy at any time. Changes may be made to reflect updates to our data processing practices, changes in applicable law, new product or service launches, or feedback from players and regulators.

When a material change is made to this Privacy Policy, win4d will:

• Update the "Last Updated" date at the top of this page.
• Display a prominent notice on the Platform's homepage or login page for a period of at least 14 days following the change.
• Where required by law or the nature of the change, seek fresh consent from affected players before the updated policy takes effect.

Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you disagree with any changes, you must discontinue use of the Platform and may request account closure by contacting our support team.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way win4d processes your personal data, please reach out to our dedicated privacy and support team through the details below:

win4d is committed to resolving all privacy-related inquiries and complaints fairly, transparently, and promptly. If you remain dissatisfied with our response, you have the right to escalate your complaint to a relevant supervisory authority or seek independent dispute resolution.