Privacy Policy

1. Information We Collect

ciri4d collects several categories of personal information to provide, operate, and improve our services. The information we collect includes:

1.1 Registration and Account Information

When you create an account on ciri4d, we collect personal information including your full legal name, date of birth, email address, mobile phone number, residential address, and chosen username and password. This information is required to establish your Account, verify your identity, and ensure compliance with age restrictions (21+ only) and anti-money-laundering (AML) regulations.

1.2 Identity Verification (KYC) Documents

As part of our Know Your Customer (KYC) verification process, we collect and store copies of government-issued identity documents such as your Indonesian national ID card (KTP), proof of address documents (utility bills, bank statements), and selfie photographs holding your ID. This information is used to verify your identity, prevent fraud, comply with regulatory requirements, and protect your account from unauthorized access. All documents are stored securely and handled in accordance with data protection standards.

1.3 Financial and Transaction Data

We collect information related to your deposits, withdrawals, bets, winnings, and financial transactions on the Platform. This includes bank account details (bank name, account number, account holder name), e-wallet information (DANA, OVO, GoPay, ShopeePay account identifiers), transaction amounts, timestamps, and payment method preferences. Financial data is collected to process payments, prevent money laundering, detect fraudulent activity, and maintain accurate transaction records for both regulatory compliance and your account history.

1.4 Gameplay and Betting Activity

ciri4d collects data about your betting and gaming activity, including bets placed, games played, wagering patterns, win/loss records, bonus usage, session duration, and game preferences. This information is used to provide personalized game recommendations, tailor promotional offers, detect problem gambling behaviors, ensure fair play, and comply with responsible gaming obligations.

1.5 Device and Technical Information

When you access the Platform, we automatically collect technical information about your device and connection, including IP address, browser type and version, operating system, device type (mobile, desktop, tablet), screen resolution, preferred language settings, referral source, and access times. This data is used to optimize the Platform's performance, improve user experience, detect security threats, and troubleshoot technical issues.

1.6 Communications and Support Interactions

When you contact ciri4d customer support via live chat, email, WhatsApp, or in-app messaging, we collect and store the content of your communications, including your inquiries, complaints, feedback, and any attachments you provide. This information is used to respond to your requests, improve our services, train support staff, and resolve disputes.

1.7 Marketing Preferences and Consent

We collect information about your marketing and communication preferences, including whether you have opted in or out of receiving promotional emails, SMS notifications, push notifications, and other marketing materials. You may update your preferences at any time through your Account settings or by contacting customer support.

2. How We Use Your Data

ciri4d uses the personal information we collect for the following purposes:

• Account Management: To create, maintain, and manage your Account; verify your identity; process KYC documentation; and authenticate your login credentials.
• Transaction Processing: To process deposits, withdrawals, and other financial transactions; reconcile payments with banks and e-wallet providers; and maintain accurate transaction records.
• Service Delivery: To provide access to betting markets, casino games, live dealer tables, togel draws, and other gaming products; calculate and settle bets; award winnings; and manage bonus promotions.
• Fraud Prevention and Security: To detect and prevent fraudulent activity, money laundering, account takeovers, collusion, bonus abuse, and other security threats; monitor for suspicious betting patterns; and comply with AML and counter-terrorism financing (CTF) obligations.
• Regulatory Compliance: To comply with legal obligations under our international gaming license; cooperate with law enforcement and regulatory authorities; maintain audit trails; and enforce age restrictions and responsible gaming policies.
• Customer Support: To respond to your inquiries, resolve disputes, investigate complaints, and provide technical assistance.
• Marketing and Personalization: To send you promotional offers, bonus notifications, newsletters, and other marketing communications (with your consent); personalize game recommendations and user experience; and conduct market research and customer surveys.
• Platform Improvement: To analyze user behavior and preferences; optimize website and app performance; test new features; and enhance the overall quality of our services.
• Responsible Gaming: To monitor for signs of problem gambling; enforce deposit limits and self-exclusion periods; and provide access to responsible gaming tools and support resources.

3. Data Sharing and Disclosure

ciri4d does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your data with the following categories of recipients under specific circumstances:

3.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who assist us in operating the Platform, including payment processors (banks, e-wallet providers, payment gateways), game developers and software providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming), identity verification services (KYC/AML compliance providers), cloud hosting and infrastructure providers, customer support platforms, marketing and analytics tools, and cybersecurity vendors. These service providers are contractually obligated to protect your data and use it only for the purposes we specify.

3.2 Legal and Regulatory Authorities

We may disclose your personal information to law enforcement agencies, regulatory bodies, courts, or government authorities if required by law, legal process, subpoena, or court order; to comply with our licensing obligations; to investigate suspected fraud, money laundering, or illegal activity; to enforce our Terms & Conditions; or to protect the rights, property, or safety of ciri4d, our users, or the public.

3.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor organization. You will be notified of any such transfer, and the new entity will be bound by the terms of this Privacy Policy unless you are provided with notice and an opportunity to opt out.

3.4 With Your Consent

We may share your personal information with other third parties if you provide explicit consent for such disclosure.

4. Data Security Measures

ciri4d takes the security of your personal information seriously and implements industry-standard technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption. Sensitive data such as passwords and financial information is stored in encrypted form in our databases.
• Access Controls: Access to personal data is restricted to authorized personnel only, based on the principle of least privilege. Employees and contractors with access to user data are bound by confidentiality agreements.
• Firewalls and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) to detect and block malicious activity.
• Regular Security Audits: We conduct regular security assessments, vulnerability scans, and penetration testing to identify and remediate potential weaknesses in our systems.
• Incident Response: We maintain an incident response plan to quickly detect, contain, and respond to data breaches or security incidents. In the event of a breach that affects your personal information, we will notify you and relevant authorities in accordance with applicable data protection laws.

While we implement robust security measures, no system is completely immune to attack. You are responsible for maintaining the confidentiality of your login credentials and for notifying us immediately if you suspect unauthorized access to your Account.

5. Data Retention

ciri4d retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods vary depending on the type of data:

• Account and Registration Data: Retained for the duration of your active Account and for a period of seven (7) years after Account closure to comply with AML regulations and licensing requirements.
• Transaction and Financial Data: Retained for a minimum of seven (7) years after the transaction date for audit, tax, and regulatory compliance purposes.
• KYC Documents: Retained for the duration of your Account and for a period of seven (7) years after Account closure or last transaction, whichever is later.
• Marketing and Communications Data: Retained until you withdraw consent or request deletion, subject to legal retention obligations.
• Technical and Log Data: Retained for up to two (2) years for security monitoring, fraud detection, and system optimization.

Once the retention period expires, we will securely delete or anonymize your personal information in accordance with data protection best practices.

6. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information under applicable data protection laws. These rights may include:

• Right to Access: You have the right to request a copy of the personal information we hold about you. You can access most of your Account information directly through your Account dashboard.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal information. You can update your Account details at any time through your Account settings.
• Right to Erasure (Right to be Forgotten): You have the right to request deletion of your personal information, subject to legal and regulatory retention obligations. Note that we may be required to retain certain data for compliance purposes even after Account closure.
• Right to Restrict Processing: You have the right to request that we limit the processing of your personal information in certain circumstances, such as while we verify the accuracy of disputed data.
• Right to Data Portability: You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes or where we rely on legitimate interests as the legal basis for processing.
• Right to Withdraw Consent: Where we process your personal information based on your consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] (displayed as plain text) with the subject line "Privacy Rights Request." We will respond to your request within thirty (30) days. We may require additional information to verify your identity before processing your request.

7. Cookies and Tracking Technologies

ciri4d uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you on subsequent visits.

7.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly. These cookies enable core features such as login authentication, session management, and security.
• Performance Cookies: Collect anonymous information about how you use the Platform, such as which pages you visit and whether you encounter errors. This data helps us optimize performance.
• Functional Cookies: Remember your preferences (language, currency, display settings) to provide a personalized experience.
• Marketing Cookies: Track your activity across the Platform to deliver targeted advertisements and promotions based on your interests.

7.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can choose to block or delete cookies, but doing so may affect the functionality of the Platform. Note that essential cookies cannot be disabled as they are necessary for the Platform to operate.

8. International Data Transfers

ciri4d operates under an international gaming license and may process your personal information on servers located outside of Indonesia. When we transfer your data internationally, we ensure that appropriate safeguards are in place to protect your information in accordance with applicable data protection laws. These safeguards may include standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms.

9. Children's Privacy

The Platform is strictly intended for adults aged 21 and over. ciri4d does not knowingly collect, use, or store personal information from individuals under the age of 21. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete that information and terminate the associated Account. If you believe that we have collected information from a minor, please contact us immediately at [email protected] (displayed as plain text).

10. Changes to This Privacy Policy

ciri4d reserves the right to update, modify, or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Any changes will be effective immediately upon posting to the Platform. We will notify you of material changes by email or through a prominent notice on the Platform. Your continued use of the Platform after changes have been posted constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

11. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact ciri4d's Data Protection Officer:

• Email: [email protected] (displayed as plain text)
• Live Chat: Available 24/7 through the Platform
• WhatsApp: +62 812 3456 7890 (displayed as plain text)

We take all privacy inquiries seriously and will respond to your request as promptly as possible.

Last Updated: January 2026
Effective Date: January 2026