Privacy Policy

1

Definitions Clause 1 — Key Terms Used in This Policy

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

Term	Meaning
"Platform"	The dhk4d website at https://dhk4d.net, including all sub-pages, features, games, and services accessible through it.
"We / Us / dhk4d"	The operator of the Platform and the data controller responsible for your personal data.
"You / Member"	Any individual who accesses the Platform, registers an account, or interacts with any service offered by dhk4d.
"Personal Data"	Any information that identifies or can reasonably identify you as an individual — including your name, email address, mobile number, financial account details, device identifiers, and IP address.
"Processing"	Any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
"KYC"	Know Your Customer — the identity and document verification procedures we conduct to confirm your identity before processing withdrawals or at any other point we deem necessary.
"Cookies"	Small text files placed on your device by the Platform or third-party services to recognise you across sessions and support analytics and functionality.

2

Scope & Data Controller Clause 2 — Who This Policy Applies To

This Privacy Policy applies to all Personal Data collected by dhk4d in connection with your use of the Platform, regardless of how you access it — whether via desktop browser, mobile browser, or any future native application we may release. It applies to registered Members and to unregistered visitors who browse the Platform without creating an account.

dhk4d is the data controller for all Personal Data processed under this policy. As data controller, we determine the purposes and means by which your Personal Data is processed. Where we engage third-party processors — such as payment gateways, KYC verification providers, or analytics platforms — those parties act as data processors on our behalf and are bound by contractual obligations that require them to handle your data in a manner consistent with this policy.

This policy is written primarily for players located in Indonesia. References to Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI), e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and regulatory context reflect the primary market dhk4d serves. If you access the Platform from outside Indonesia, this policy still applies to you in full.

3

Data We Collect Clause 3 — Categories of Personal Data

dhk4d collects the following categories of Personal Data from or about you:

3.1 Registration & Identity Data

Full legal name, date of birth, and gender
Residential address (including city — e.g., Jakarta, Surabaya, Bandung, Medan, Bali)
Email address and mobile phone number
Username and encrypted password
Nationality and, where provided, national identification number (NIK from KTP)

3.2 KYC & Verification Data

Copies of government-issued identity documents (KTP, Passport, SIM)
Proof of residential address documents
Selfie photographs used to match against your identity document
Bank account statements or e-wallet screenshots provided as proof of payment method ownership

3.3 Financial & Transaction Data

Bank account numbers and account holder names associated with BCA, BRI, BNI, Mandiri, CIMB Niaga, or BSI accounts you register for deposits and withdrawals
E-wallet account identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja
Deposit and withdrawal amounts, timestamps, and transaction reference numbers
Full betting and gaming history, including wager amounts, markets selected, and settlement outcomes

3.4 Technical & Device Data

IP address and approximate geolocation derived from it
Device type, operating system, and browser version
Session duration, pages visited, and interaction events within the Platform
Cookie identifiers and similar tracking technologies (see Clause 7)

3.5 Communications Data

Records of live chat conversations with our support team
Email correspondence sent to or received from [email protected]
Feedback, complaint, and dispute submissions

We do not collect or store full payment card numbers (PAN). Where Visa or Mastercard transactions are processed, those details are handled exclusively by our certified payment gateway partners and are never stored on dhk4d's own servers.

4

How We Collect Data Clause 4 — Collection Methods

We collect Personal Data through the following channels:

Directly from you — when you complete the registration form, submit KYC documents, contact support, or provide information in any other interaction with the Platform.
Automatically — when you browse the Platform, our servers and analytics tools automatically record technical and device data including your IP address, session data, and interaction events.
From third-party processors — our KYC verification partners return enriched identity data (e.g., document validity scores) after processing the documents you submit. Our payment processors confirm the status of deposit and withdrawal transactions.
From cookies and tracking technologies — as described in Clause 7, cookies placed on your device collect behavioural data that helps us improve the Platform and serve relevant content.

We do not purchase Personal Data from data brokers or third-party marketing lists. All data we hold about you originates from your direct interactions with the Platform or from the service providers we engage to operate it.

5

Purposes & Legal Basis Clause 5 — Why We Process Your Data

We process your Personal Data only where we have a lawful basis to do so. The table below sets out the primary purposes for which we process your data and the corresponding legal basis for each:

Purpose	Legal Basis
Creating and managing your account	Performance of a contract — necessary to provide the service you have requested.
Processing deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja	Performance of a contract — necessary to execute the financial transactions you initiate.
KYC identity verification and age verification (21+)	Legal obligation — we are required to verify the identity and age of all Members before processing withdrawals.
Anti-money-laundering (AML) monitoring	Legal obligation — we are required to monitor transactions for signs of financial crime.
Fraud prevention and account security	Legitimate interest — protecting our platform and our Members from fraud and unauthorised access.
Customer support and dispute resolution	Performance of a contract — necessary to resolve issues you raise with us.
Responsible gaming monitoring and intervention	Legitimate interest — identifying and supporting Members who may be experiencing problem gambling.
Platform analytics and performance improvement	Legitimate interest — improving the quality, speed, and reliability of the Platform.
Sending promotional communications (with your consent)	Consent — you may opt in to receive marketing emails and notifications; you may withdraw consent at any time.

We will not use your Personal Data for purposes materially different from those listed above without first notifying you and, where required, obtaining your consent.

6

Sharing Your Data Clause 6 — Third-Party Disclosures

dhk4d does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We share your data only in the circumstances described below:

Payment processors — We share the minimum necessary financial data with our payment processing partners (including the gateway services underlying BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja integrations) to execute transactions you initiate. These partners are contractually prohibited from using your data for any purpose other than executing and reconciling your transactions.
KYC verification providers — When you submit identity documents, those documents and associated data are transmitted to our third-party KYC partner for automated and, where required, manual verification. The verification provider retains data only for as long as required to complete the verification and comply with its own legal obligations.
Game studios and content providers — Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive limited technical identifiers (e.g., a pseudonymised player ID) to facilitate game session management and return-to-game functionality. They do not receive your name, contact details, or financial account information.
Analytics and infrastructure providers — We use industry-standard analytics and cloud infrastructure services. These providers may process technical and device data on our behalf to support Platform operations. They are engaged under data processing agreements that restrict their use of your data.
Law enforcement and regulatory authorities — We will disclose Personal Data to competent authorities when legally required to do so, or when we reasonably believe disclosure is necessary to prevent or investigate fraud, money laundering, or other criminal activity.
Business transfers — In the event of a merger, acquisition, or sale of all or substantially all of dhk4d's assets, your Personal Data may be transferred to the acquiring entity. You will be notified of any such transfer and any material change to how your data is processed.

All third-party data processors engaged by dhk4d are required to sign contractual agreements confirming that they will process your Personal Data only on our documented instructions and with equivalent security standards to our own.

7

Cookies & Tracking Technologies Clause 7 — How We Use Cookies

dhk4d uses cookies and similar technologies to operate and improve the Platform. The following categories of cookies may be placed on your device when you visit the Platform:

Cookie Type	Purpose	Required?
Strictly Necessary	Maintain your login session, remember your language preferences, and ensure the Platform functions correctly.	Yes — cannot be disabled
Functional	Remember your preferred deposit method, game category, and display settings to personalise your experience.	Optional
Analytics	Collect aggregated, anonymised data on page views, session length, and navigation paths to help us improve Platform performance.	Optional
Fraud Prevention	Identify suspicious session behaviour, detect automated bot activity, and protect your account from unauthorised access attempts.	Yes — cannot be disabled

You can control optional cookies through your browser settings. Disabling functional or analytics cookies will not prevent you from using the Platform but may reduce the quality of your experience. Strictly necessary and fraud-prevention cookies cannot be disabled without breaking core Platform functionality.

8

Data Retention Clause 8 — How Long We Keep Your Data

We retain your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, to comply with our legal obligations, and to resolve any disputes that may arise. The following retention periods apply as a general guide:

Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after permanent account closure, to satisfy AML record-keeping requirements.
KYC documents: Retained for a minimum of five (5) years from the date of verification or from the date of account closure, whichever is later.
Transaction and betting records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with financial record-keeping best practices.
Support communications: Retained for three (3) years from the date of the interaction, unless the communication relates to an active dispute, in which case it is retained until the dispute is fully resolved plus one (1) year.
Technical and device data: Retained for twelve (12) months from collection, after which it is aggregated and anonymised or deleted.
Marketing consent records: Retained for as long as you remain opted in, plus two (2) years after you withdraw consent, as evidence of your consent history.

When Personal Data is no longer required, we securely delete or irreversibly anonymise it. Anonymised data (which cannot be used to identify you) may be retained indefinitely for statistical and analytical purposes.

9

Security Measures Clause 9 — Protecting Your Personal Data

dhk4d implements a layered set of technical and organisational security measures to protect your Personal Data against unauthorised access, loss, alteration, or disclosure. These measures include:

TLS/SSL encryption on all data transmitted between your device and our servers, ensuring that your login credentials, transaction details, and personal information cannot be intercepted in transit.
AES-256 encryption at rest for sensitive fields including passwords (stored as salted hashes), identity document files, and financial account identifiers.
Access controls limiting access to Personal Data to dhk4d staff who require it to perform their job functions, governed by role-based access control (RBAC) policies.
Two-factor authentication (2FA) available to all Members as an additional layer of account security, and mandatory for all internal staff accounts with access to Member data.
Regular security audits and penetration testing conducted by independent third-party security firms to identify and remediate vulnerabilities before they can be exploited.
Intrusion detection systems (IDS) that monitor network traffic for anomalous patterns indicative of attack or unauthorised access attempts.

Despite our robust security infrastructure, no system is completely immune to risk. If you suspect that your dhk4d account has been compromised, please contact our support team immediately via live chat so we can take protective action on your account without delay.

10

Your Rights Clause 10 — Data Subject Rights

As the person whose data we process, you hold the following rights in relation to your Personal Data. You may exercise any of these rights by contacting us at [email protected] or via live chat. We will respond to all valid requests within thirty (30) days.

👁️ Right of Access Request a copy of all Personal Data we hold about you, along with information on how it is used.

✏️ Right to Rectification Request correction of any inaccurate or incomplete Personal Data we hold about you.

🗑️ Right to Erasure Request deletion of your Personal Data where we no longer have a lawful basis to retain it.

⏸️ Right to Restriction Request that we restrict processing of your data while a dispute about its accuracy or use is resolved.

📦 Right to Portability Request your data in a structured, machine-readable format for transfer to another service provider.

🚫 Right to Object Object to processing based on legitimate interest, including direct marketing communications.

🔔 Withdraw Consent Where processing is based on consent (e.g., marketing), withdraw that consent at any time without penalty.

⚖️ Right to Complain Lodge a complaint with the competent data protection authority in your jurisdiction if you believe your rights have been violated.

Please note that some rights are subject to limitations. For example, we cannot erase data that we are legally required to retain for AML or KYC purposes, and we cannot fulfil a portability request for data that is not technically portable in a structured format. We will explain any such limitations clearly when responding to your request.

11

Children's Privacy Clause 11 — Under-21 Protection

The dhk4d Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect Personal Data from individuals under the age of 21. Our registration process requires all applicants to declare their date of birth, and our KYC verification procedures are designed to confirm this declaration with documentary evidence.

If we discover that we have inadvertently collected Personal Data from a person under the age of 21, we will immediately suspend the associated account, void any transactions conducted from that account, and permanently delete all data collected from that individual. Any funds deposited will be returned via the original payment method where technically possible.

If you are a parent or guardian and believe that a minor in your care has registered an account with dhk4d, please contact us immediately at [email protected]. We take underage gambling extremely seriously and will act on any credible report without delay.

12

International Transfers Clause 12 — Cross-Border Data Flows

dhk4d operates internationally. As a result, your Personal Data may be transferred to and processed in countries other than Indonesia. These countries may have data protection laws that differ from those in Indonesia. Where such transfers occur, we take appropriate safeguards to ensure that your Personal Data remains protected to a standard equivalent to this policy, including:

Entering into data processing agreements with all international processors that incorporate standard contractual clauses or equivalent protections.
Selecting processors located in jurisdictions recognised as providing an adequate level of data protection.
Applying technical security measures (encryption, pseudonymisation) to data before it is transferred internationally.

By using the Platform, you acknowledge that your Personal Data may be transferred internationally in the manner described above. If you have concerns about any specific international transfer, please contact us at [email protected].

13

Third-Party Links Clause 13 — External Content

The Platform may contain references to third-party services such as game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) and payment providers. While we take reasonable steps to ensure that the third-party services we integrate are reputable, dhk4d is not responsible for the privacy practices of any third party. Each third party operates under its own privacy policy, and we encourage you to review those policies independently.

dhk4d does not control, and is not responsible for, the content, privacy policies, or practices of any third-party websites that may be linked to from the Platform — including links in promotional materials from game providers.

14

Policy Updates Clause 14 — Changes to This Privacy Policy

dhk4d reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or improvements to the Platform. When material changes are made, we will update the "Last Updated" date at the top of this document and, where practicable, notify active Members via email or an in-platform notification.

Your continued use of the Platform after any updated Privacy Policy has been posted constitutes your acknowledgment of the revised terms. If you do not agree with any change, you have the right to close your account and request deletion of your Personal Data, subject to the retention obligations described in Clause 8.

We encourage you to review this policy periodically. Archived versions of previous policies are available on request by contacting [email protected].

15

Contact Us Clause 15 — Data Protection Enquiries

If you have any questions, concerns, or requests regarding this Privacy Policy or the way dhk4d handles your Personal Data, please contact our support team through the following channels:

Live Chat: Available 24/7 directly on the Platform. Our Indonesian-speaking agents are on hand at all hours across WIB, WITA, and WIT time zones.
Email: [email protected] — Please allow 2–6 hours for a response during peak periods (WIB). For data subject rights requests, please include "Privacy Request" in the subject line and your registered username to help us process your request efficiently.

We are committed to resolving all privacy-related enquiries promptly and transparently. If you are not satisfied with our response, you retain the right to escalate your complaint to the relevant data protection authority in your jurisdiction.

Our support team includes native Indonesian-speaking agents trained specifically on data protection and privacy matters. All data subject rights requests are handled by a dedicated team member and tracked to ensure timely resolution.

Contents