PRIVACY POLICY

1. Introduction and Scope

clan4d ("we," "us," or "our") operates the online gaming platform accessible at https://clan4d.cam. This Privacy Policy applies to all individuals who visit our website, create an account, or otherwise interact with our services, regardless of the device or method of access used. It covers personal data collected through the website, mobile-optimized interfaces, customer support channels, and any other touchpoint through which you communicate with clan4d.

This policy is intended to be comprehensive and transparent. We have drafted it in accordance with internationally recognized data protection principles, including the principle of purpose limitation (data is collected only for specific, legitimate purposes), data minimization (we collect only what we genuinely need), storage limitation (data is not kept longer than necessary), integrity and confidentiality (data is processed securely), and accountability (we take responsibility for our data practices).

If you are a resident of Indonesia, you should also be aware that Indonesian data protection legislation — including the Personal Data Protection Law (Undang-Undang Perlindungan Data Pribadi) enacted in 2022 — recognizes your right to know what personal data is being processed about you and to have inaccurate data corrected. We respect and support those rights fully.

2. Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, identification number, location data, online identifiers, or factors specific to the physical, economic, cultural, or social identity of that person.
• "Processing" means any operation performed on personal data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" refers to clan4d as the entity that determines the purposes and means of processing your personal data.
• "Data Processor" refers to any third party that processes personal data on behalf of clan4d under a data processing agreement.
• "KYC" (Know Your Customer) refers to the identity verification process through which clan4d confirms the identity, age, and address of each registered player.
• "Cookies" refers to small text files placed on your device by our website to facilitate functionality, analytics, and personalization.

3. Information We Collect

3.1 Information You Provide Directly

When you register an account, use our services, or contact us for support, you provide us with the following categories of personal data:

• Registration Data: Full legal name, date of birth, email address, mobile phone number, and residential address. This information is required to create your account and verify your identity.
• Identity Verification Documents: Photographs or scans of your Indonesian National Identity Card (KTP), passport, driver's license, proof of residential address (utility bill, bank statement dated within three months), and a selfie photograph taken alongside your identification document.
• Financial Information: Bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, or other approved payment methods; e-wallet identifiers for OVO, DANA, GoPay, or other approved e-wallets. We do not store full credit or debit card numbers; any card data is processed directly by our payment service providers.
• Communication Records: Messages sent to our customer support team via live chat, email ([email protected]), or any other communication channel, including chat transcripts and email correspondence.
• Responsible Gaming Preferences: Deposit limits, loss limits, wager limits, session time limits, and self-exclusion preferences that you configure through your account dashboard.

3.2 Information Collected Automatically

When you access the clan4d platform, our systems automatically collect certain technical and behavioral information:

• Device and Technical Data: IP address, device type, operating system and version, browser type and version, screen resolution, time zone, and language settings.
• Usage and Behavioral Data: Pages visited, time spent on each page, games played, bets placed, wager amounts, deposit and withdrawal history, session start and end times, in-game actions, and navigation patterns within the platform.
• Location Data: Approximate geographic location inferred from IP address. We use this to verify that you are accessing from a permitted jurisdiction and to comply with geofencing obligations under our gaming license.
• Cookies and Tracking Technologies: As detailed in Section 9 of this policy.

3.3 Information From Third Parties

In certain circumstances, we receive personal data about you from trusted third parties:

• Payment Processors: Transaction confirmation details, fraud risk scores, and payment status updates from banking partners and e-wallet providers.
• Identity Verification Services: Results of automated document authentication and facial matching services used to supplement our KYC process.
• Fraud Prevention Agencies: Risk indicators and fraud flags that help us protect the integrity of our platform and prevent financial crime.

4. How We Use Your Information

We process your personal data only for specific, legitimate purposes. The table below summarizes our key processing activities, their legal basis, and the data categories involved:

We do not use automated decision-making — including profiling — to make decisions that produce significant legal effects on you without human review being available. Where automated tools flag an account for security review, a qualified member of our compliance team will review and make the final determination.

5. Disclosure and Sharing of Personal Data

5.1 Third-Party Service Providers

We engage carefully selected third-party service providers who process personal data on our behalf. All such providers are bound by data processing agreements that require them to handle your data only as instructed by clan4d, implement appropriate security measures, and refrain from processing your data for their own independent purposes. Categories of providers include: payment processors and banking partners, identity verification service providers, customer support platform operators, cloud hosting and infrastructure providers, analytics services (operating on anonymized or aggregated data), and fraud detection services.

5.2 Law Enforcement and Regulatory Authorities

We may disclose personal data to law enforcement agencies, regulatory bodies, courts, or other government authorities when: required by applicable law, court order, or legal process; necessary to investigate, prevent, or respond to suspected illegal activity, fraud, or security incidents; or necessary to protect the rights, property, or safety of clan4d, our players, or the public. We will notify you of such disclosures where legally permissible to do so.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, personal data held by clan4d may be transferred to the acquiring entity as part of the transaction. We will notify you by email and through a prominent notice on our website prior to such a transfer, and you will have the right to request deletion of your data if you do not wish it to be transferred.

5.4 No Sale of Personal Data

clan4d does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. Any data sharing arrangement with third parties is strictly limited to the purposes described in this Privacy Policy and is governed by contractual data protection obligations.

6. International Data Transfers

As an internationally operated gaming platform serving Indonesian players, some of your personal data may be transferred to and processed in countries outside Indonesia. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Indonesian data protection law. These safeguards include: contractual clauses imposing data protection obligations on the receiving party; transfer to countries recognized as providing an adequate level of data protection; and implementation of supplementary technical and organizational measures where required.

Our primary data processing infrastructure is hosted on servers located in geographically distributed data centers with industry-standard physical and logical security controls. Regardless of where your data is processed, the protections described in this Privacy Policy apply in full.

7. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The following general retention periods apply:

• Account and registration data: Retained for the duration of your account and for a minimum of five years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Identity verification documents: Retained for a minimum of five years from the date of verification, or longer if required by applicable law or ongoing investigation.
• Financial transaction records: Retained for a minimum of five years from the date of each transaction.
• Customer support communications: Retained for a minimum of two years from the date of last contact.
• Marketing consent records: Retained until consent is withdrawn, plus an additional 12 months as evidence of lawful processing.
• Website usage and analytics data: Retained in aggregated, anonymized form indefinitely; personally identifiable usage data is deleted or anonymized within 24 months of collection.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized so that it can no longer be attributed to any individual. Backup copies are purged within 90 days of the primary deletion.

8. Your Rights as a Data Subject

As a player on clan4d, and in particular as a resident of Indonesia, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us at [email protected] — we will respond to verifiable requests within 30 days.

• Right of Access: You have the right to request a copy of the personal data we hold about you, along 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 it be corrected or completed. You may also update most registration details directly through your account settings.
• Right to Erasure: In certain circumstances, you have the right to request that we delete your personal data. This right is subject to legal retention obligations — for example, we cannot erase financial transaction records that we are required by law to retain for five years.
• Right to Restriction of Processing: You may request that we restrict the processing of your personal data in certain circumstances, such as while the accuracy of the data is under dispute.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on our legitimate interests, including direct marketing. Where you object to direct marketing, we will cease that processing immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

9. Cookies and Tracking Technologies

9.1 What Cookies We Use

clan4d uses cookies and similar tracking technologies — including web beacons, pixel tags, and local storage objects — to operate and improve our platform. We categorize our cookies as follows:

• Strictly Necessary Cookies: Essential for the website to function. They enable core features such as session authentication, security enforcement, and load balancing. These cookies cannot be disabled without impairing platform functionality.
• Functional Cookies: Enable enhanced functionality and personalization, such as remembering your preferred language, currency display, and game lobby layout preferences.
• Analytics Cookies: Help us understand how players interact with our platform by collecting aggregated information about page visits, session durations, and navigation paths. This data informs ongoing platform improvements.
• Security Cookies: Used to detect fraudulent activity, prevent unauthorized access, and enforce device fingerprinting for account protection purposes.

9.2 Managing Your Cookie Preferences

Strictly necessary and security cookies are always active, as they are integral to platform operation. You can manage your preferences for functional and analytics cookies through your browser settings. Most modern browsers allow you to refuse all cookies, delete existing cookies, or receive a warning before a cookie is stored. Please note that disabling certain cookies may affect the functionality and personalization features of our platform. Detailed guidance on managing cookies in popular browsers is available from the browser provider's help documentation.

10. Security Measures

We take the security of your personal data seriously and implement a comprehensive set of technical and organizational measures to protect it against unauthorized access, accidental loss, destruction, or disclosure. Our security framework includes:

• TLS 1.3 encryption for all data transmitted between your device and our servers
• AES-256 encryption for sensitive data stored in our databases
• Multi-factor authentication options for player accounts and mandatory MFA for all internal staff access to player data
• Regular third-party penetration testing and vulnerability assessments conducted by accredited security firms
• Role-based access controls ensuring that employees can only access personal data necessary for their specific job functions
• Continuous security monitoring, intrusion detection systems, and automated alerting for anomalous activity
• Formal incident response procedures with defined escalation paths and regulatory notification timelines
• Regular staff training on data protection, social engineering awareness, and secure data handling practices

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify you without undue delay and provide information about the nature of the breach, the data affected, the likely consequences, and the measures we are taking to address it.

11. Children's Privacy

clan4d's services are strictly intended for adults aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been submitted by or on behalf of a minor, we will immediately suspend the associated account, delete the data, and take any further action required to prevent the minor from accessing our services. If you believe a minor has created an account with us, please contact our support team immediately so that we can investigate and act promptly.

12. Marketing Communications

We will send you promotional emails, SMS notifications, or in-platform messages about bonuses, new games, and special events only if you have explicitly opted in to receive such communications during registration or through your account notification preferences. Each marketing communication includes a clear and functional unsubscribe mechanism. You may also manage your marketing preferences at any time through the notification settings in your account dashboard.

Opting out of marketing communications does not affect our ability to send you service-related messages, such as deposit confirmations, withdrawal notifications, security alerts, or updates to this Privacy Policy, which are sent regardless of marketing preferences as they are necessary for the operation of your account.

13. Links to Third-Party Content

Our platform may reference third-party payment providers, game studios, and sports data suppliers by name or logo. We are not responsible for the privacy practices of any third-party service. We encourage you to review the privacy policy of any external service you interact with independently of clan4d. This Privacy Policy applies solely to data processed by clan4d directly or by processors acting on our behalf under a data processing agreement.

14. Amendments to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our data practices, applicable law, or platform functionality. When material changes are made, we will notify registered players via email to their registered address and display a prominent notice on the website for at least 30 days following the update. The "Last Updated" date at the top of this page will always reflect the most recent revision. Continued use of our services after the effective date of any revision constitutes acceptance of the updated policy.

15. Contact and Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or our data processing practices, or if you wish to exercise any of your data subject rights, please contact our dedicated data protection contact using the details below. All communications must be in writing, and we will acknowledge receipt within 5 business days and provide a substantive response within 30 calendar days.

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Subject Request"
• Response Language: English or Indonesian
• Response Time: Within 30 calendar days of receipt

If you are not satisfied with our response to your complaint, you have the right to escalate the matter to the relevant data protection authority in Indonesia or the jurisdiction from which you are accessing our services.