pos4d Privacy Policy

1. Introduction

pos4d ("the Platform", "We", "Us", "Our") is committed to protecting and respecting the privacy of every person who visits, registers with, or uses the pos4d platform at pos4d.bio. This Privacy Policy sets out the basis on which any personal data we collect from you — or that you provide to us — will be processed.

This policy applies to all services offered by pos4d, including sports betting, live casino, slots, card games, togel (Indonesia's traditional numbers lottery), and all account management functions accessible on our platform. By registering a pos4d account or continuing to use the Platform after this policy has been published or updated, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

If you do not agree with any aspect of this Privacy Policy, you must discontinue use of the Platform immediately. For questions about our data practices at any time, please refer to Section 15 (Contact Us) below.

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2. Definitions

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, mobile number, national identity number, bank account details, IP address, and device identifiers.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, erasure, or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. pos4d acts as the Data Controller for all member personal data collected via the Platform.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller, under a binding contractual obligation that restricts their use of the data.
• "Member" / "You" — any registered user of the pos4d platform.
• "Cookies" — small text files placed on your device by the Platform to enable functionality, session management, analytics, and personalisation.
• "KYC Data" — identity verification documents submitted by Members as part of the Know Your Customer process, including copies of national identity cards (KTP), passports, and proof of address.

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3. Data We Collect

pos4d collects the following categories of personal data:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identity document
• Date of birth (used to verify the 21+ age requirement)
• Indonesian mobile number
• Email address
• Residential address (collected during KYC or withdrawal verification)
• National identity number (NIK from KTP) or passport number

3.2 Financial Data

• Bank account name, bank name, and account number for withdrawal purposes (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, and others)
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja
• Deposit and withdrawal transaction records denominated in Indonesian Rupiah (IDR)
• Visa / Mastercard partial card data where applicable (card number is never stored in full; only masked representations are retained)

3.3 Gaming & Behavioural Data

• Bet history, game session logs, wagering patterns, and win/loss records
• Sports betting selections including pre-match and live in-play markets
• Bonus and promotion usage records and wagering requirement progress
• Responsible gaming tool activations (deposit limits, session reminders, self-exclusion)

3.4 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, browser type and version
• Session timestamps, page interaction logs, and navigation paths
• Cookie identifiers and similar tracking technologies as described in Section 9

3.5 Communications Data

• Records of live chat sessions, support ticket correspondence, and email exchanges with pos4d support staff
• Voluntary feedback, survey responses, and promotional competition entries

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4. How We Collect Data

pos4d collects personal data through the following means:

• Direct submission: Data you provide when completing the registration form, submitting KYC documents, making a deposit or withdrawal request, or contacting our support team.
• Automated collection: Technical and behavioural data collected automatically through cookies, server logs, and analytics tools when you access and interact with the Platform.
• Third-party sources: Identity verification data returned by KYC/AML service providers when we submit your details for verification against official databases. Payment confirmation data received from Indonesian banks and e-wallet providers when you initiate a transaction.
• Publicly available sources: In limited circumstances, we may supplement profile data with publicly available information to assist in fraud prevention or regulatory compliance reviews.

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5. Purpose & Legal Basis for Processing

The table below summarises the primary purposes for which pos4d processes your personal data, together with the legal basis for each processing activity:

Purpose	Data Categories Used	Legal Basis
Account registration and identity verification (KYC/AML)	Identity, Contact, KYC	Legal obligation; Contractual necessity
Processing deposits and withdrawals to/from Indonesian bank accounts and e-wallets	Financial, Identity	Contractual necessity
Delivering sports betting, casino, slot, and card game services	Gaming, Technical	Contractual necessity
Fraud prevention, security monitoring, and suspicious activity detection	Technical, Financial, Identity	Legitimate interest; Legal obligation
Responsible gaming monitoring and intervention	Gaming, Identity	Legal obligation; Legitimate interest
Personalising your experience and recommending relevant games or promotions	Gaming, Technical	Consent; Legitimate interest
Sending transactional communications (deposit confirmations, withdrawal status)	Contact, Financial	Contractual necessity
Sending promotional communications (bonuses, offers, seasonal promotions)	Contact	Consent (opt-in required)
Customer support and dispute resolution	Communications, Identity, Financial	Contractual necessity; Legitimate interest
Regulatory reporting and legal compliance	All categories as required	Legal obligation

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6. Data Sharing

pos4d does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. We share personal data only in the following circumstances and only to the extent strictly necessary:

6.1 Service Providers (Data Processors)

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

• KYC / AML verification providers — to verify your identity and age against government-issued document databases.
• Payment processors and banking partners — including Indonesian bank transfer gateways and e-wallet integration providers (OVO, DANA, GoPay, ShopeePay, LinkAja), to facilitate deposits and withdrawals.
• Game studio providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft, who receive session tokens and pseudonymous identifiers to deliver game content. These providers do not receive your full personal profile.
• Cloud infrastructure and hosting providers — who store platform data on secure servers and provide content delivery services.
• Customer support platform providers — who host our live chat and ticketing infrastructure.
• Analytics and fraud detection providers — who process technical and behavioural data to identify unusual activity patterns.

6.2 Legal and Regulatory Disclosure

pos4d may disclose personal data to law enforcement agencies, regulatory bodies, or other authorities where we are legally required to do so, where disclosure is necessary to protect the rights or safety of pos4d or its members, or where we are responding to a valid legal process such as a court order or regulatory investigation.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of pos4d's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material change to the data controller's identity via the email address registered to your account.

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7. International Data Transfers

pos4d operates as an internationally licensed online gaming platform. Accordingly, your personal data may be processed in countries outside Indonesia, including countries where data protection laws may differ from those in your home jurisdiction. Where such transfers occur, pos4d ensures that appropriate contractual safeguards are in place — including standard contractual clauses or equivalent data transfer mechanisms — to ensure that your personal data receives a level of protection consistent with the standards described in this Privacy Policy.

By registering a pos4d account, you acknowledge and consent to the international transfer of your personal data as described in this section.

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8. Data Retention

pos4d retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for the lifetime of the active account plus a minimum of 5 years following account closure, to comply with anti-money-laundering record-keeping obligations.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction.
• KYC documents: Retained for a minimum of 5 years following the completion of the KYC review, or longer if required by applicable regulatory obligations.
• Gaming history and session logs: Retained for 3 years from the date of the relevant session.
• Customer support communications: Retained for 2 years from the date of the final communication in a support thread.
• Technical and device data (logs): Retained for 12 months on a rolling basis.
• Marketing consent records: Retained for the duration of active consent plus 1 year following opt-out, to evidence compliance with consent obligations.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to any identifiable individual.

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9. Cookies & Tracking Technologies

pos4d uses cookies and similar tracking technologies to operate the Platform, maintain session state, prevent fraud, analyse traffic patterns, and personalise your experience. The cookies we deploy fall into the following categories:

• Strictly Necessary Cookies: Required for core Platform functionality including login sessions, security tokens, and page navigation. These cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: Store your preferences such as language display settings, preferred sports markets, and responsible gaming limit configurations.
• Analytics Cookies: Collect anonymised or pseudonymised data about how Members navigate the Platform — pages visited, time spent, features used — to help us improve the user experience.
• Marketing & Personalisation Cookies: Enable us to present relevant promotions and game recommendations based on your activity on the Platform. These are only activated where you have given consent.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling certain cookie categories may affect the functionality and performance of the Platform. Strictly necessary cookies cannot be disabled via browser settings without breaking core features.

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10. Security Measures

pos4d implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL / TLS encryption on all data transmitted between your device and our servers.
• Encryption at rest for sensitive personal data fields, including identity document data and financial account details.
• Access controls limiting staff access to personal data on a strict need-to-know basis, enforced through role-based permissions and multi-factor authentication for internal systems.
• Regular penetration testing and vulnerability assessments conducted by qualified independent security professionals.
• Intrusion detection and monitoring systems that flag unusual access patterns and trigger automated incident response procedures.
• Data minimisation practices ensuring that only the minimum necessary personal data is collected and retained for each processing purpose.

While pos4d takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, pos4d will notify affected Members and the relevant authorities in accordance with applicable law.

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11. Your Rights

As a Member of pos4d, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact our support team using the details in Section 15:

• Right of Access: You have the right to request a copy of the personal data pos4d holds about you, together with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data. For name and date-of-birth changes, identity document evidence will be required.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where processing is unlawful. Note that certain data cannot be deleted where retention is required by law (e.g., AML record-keeping obligations).
• Right to Restrict Processing: You may request that we limit the processing of your personal data in certain circumstances, such as while a rectification request is being reviewed.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to request its transfer to another controller where technically feasible.
• Right to Object: You may object to processing based on legitimate interests, including profiling for direct marketing purposes. Where we process your data for marketing, you may opt out at any time by contacting support or using the unsubscribe mechanism in any promotional email.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

pos4d will respond to all verified data rights requests within 30 days. In complex or high-volume cases, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

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12. Protection of Minors

The pos4d platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. Our registration process includes age verification steps, and all accounts are subject to KYC review that confirms the Member's date of birth.

If pos4d becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to close the relevant account, delete all associated personal data, and reverse any financial transactions where possible. Parents and guardians who believe that a minor has registered with pos4d are asked to contact our support team immediately at [email protected].

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13. Third-Party Services

The pos4d platform integrates services from third-party game studios, payment processors, and analytics providers. While we vet our third-party partners and require them to maintain appropriate data protection standards, this Privacy Policy applies only to data processing conducted by pos4d as the Data Controller. Each third-party service provider operates under its own privacy policy in respect of data it independently controls. pos4d does not accept responsibility for the data practices of third parties operating outside the scope of our binding data processing agreements.

The Platform does not contain links to external third-party websites other than those required for integrated payment and gaming services. Where such integrations exist, they are subject to the contractual arrangements described in Section 6.

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14. Policy Amendments

pos4d reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. Material changes will be communicated to Members via the email address registered to their account and/or via a prominent notice on the Platform, with a minimum of 14 days' advance notice before the revised policy takes effect.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed of how pos4d protects your information.

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15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way pos4d processes your personal data, please contact our Data Protection team through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 via the Platform
• Indonesian-Speaking Agents: 08:00–22:00 WIB

All privacy-related enquiries will be acknowledged within 48 hours and substantively addressed within 30 days. If you are not satisfied with pos4d's response to a privacy concern, you have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction.