Privacy Policy — tema4d

1 Introduction & Scope

tema4d ("we", "us", "our") is committed to protecting the privacy and personal data of all individuals who use our platform at tema4d.cam. This Privacy Policy sets out, in plain and accessible terms, the nature of the personal data we collect from users registered in Indonesia, the purposes for which that data is processed, the conditions under which it may be disclosed to third parties, and the rights available to you as a data subject.

This policy applies to all personal data collected through:

• The tema4d website and any mobile-optimized version thereof;
• Account registration, login, and ongoing account management processes;
• KYC (Know Your Customer) identity verification procedures;
• Deposit, withdrawal, and transaction processing via local Indonesian payment channels;
• Customer support interactions conducted via email, live chat, or any other communication channel;
• Promotional and marketing activities to which you have consented.

This policy does not apply to third-party websites, payment processors, or game providers that may be accessible through or integrated with the tema4d platform. We encourage you to review the privacy policies of those third parties independently.

2 Definitions

For clarity and consistency throughout this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — that is, any data that can be used, directly or indirectly, to identify you.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means tema4d, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of tema4d under a contractual arrangement, such as KYC verification partners or payment gateway operators.
• "User" / "Player" means any individual who has registered, or is in the process of registering, an account on the tema4d platform.
• "Cookies" means small text files placed on your device by the tema4d website to facilitate session management, security, and anonymized usage analytics.
• "KYC" means the Know Your Customer identity and age verification process mandated for all Players before withdrawal rights are activated on the platform.

3 Data We Collect

tema4d collects personal data in proportion to what is operationally necessary. The categories of data we may collect are set out in the table below:

We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, health information, or biometric data, except where identity document scans submitted for KYC purposes incidentally contain such information. In such cases, that data is used solely for verification and is not processed for any other purpose.

4 How We Collect Your Data

tema4d collects personal data through the following channels:

1. Direct Submission: Data you provide when completing the registration form, submitting KYC documents, making a deposit or withdrawal request, or contacting our support team.
2. Automated Technical Collection: Data collected automatically when you visit and interact with the Platform, including IP addresses, device finger prints, browser metadata, and behavioral session data collected via cookies and server logs.
3. Payment Processors: Transaction confirmation data received from Indonesian payment providers including BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, and LinkAja when you initiate a deposit or withdrawal.
4. KYC Verification Partners: Identity verification outcomes and risk scores returned by our certified KYC processing partners following document review. These partners operate under strict data processing agreements with tema4d.
5. Game Providers: Anonymized game session data — such as round outcomes and RTP statistics — transmitted by integrated game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. These providers do not transmit personally identifiable information to tema4d.

5 Legal Basis for Processing

tema4d processes your personal data only where a valid legal basis exists. The applicable legal bases are as follows:

• Contractual Necessity: Processing required to create and manage your account, execute deposits and withdrawals in IDR, settle wagers, and provide customer support. Without this processing, we cannot deliver the services you have contracted for.
• Legal Obligation: Processing required to comply with our licensing conditions, anti-money laundering (AML) obligations, and KYC regulatory requirements. This includes retaining financial transaction records for the periods mandated by applicable regulations.
• Legitimate Interests: Processing carried out to detect and prevent fraud, maintain platform security, improve the quality of our services, and conduct anonymized analytics. We apply a balancing test to ensure our legitimate interests do not override your privacy rights.
• Consent: Processing of your data for optional marketing communications — including promotional emails, bonus notifications, and seasonal campaign messages — is carried out only on the basis of your explicit, informed, and freely given consent. You may withdraw this consent at any time.

6 How We Use Your Data

The personal data collected by tema4d is used for the following specific and legitimate purposes:

1. Account Creation and Management: Establishing your Player account, authenticating your identity at login, and maintaining the ongoing integrity of your account record.
2. Age and Identity Verification: Confirming that you are at least 21 years of age and a resident of Indonesia, as required by our eligibility standards and licensing obligations. Players who cannot be verified will not receive withdrawal access.
3. Transaction Processing: Facilitating deposits and withdrawals in IDR via your selected local bank (BCA, BRI, BNI, Mandiri, or others) or e-wallet (OVO, DANA, GoPay, ShopeePay, LinkAja), and maintaining an accurate transaction ledger within your account.
4. Fraud and Security Monitoring: Analyzing login patterns, device fingerprints, IP addresses, and behavioral signals to detect unauthorized access attempts, duplicate account creation, money laundering activity, and other forms of abuse.
5. Responsible Gaming Compliance: Monitoring your wagering patterns to identify potential problem gambling indicators and applying any deposit limits, session restrictions, or self-exclusion measures you have requested through the Platform's Responsible Gaming tools.
6. Customer Support: Using your contact and account data to respond to support inquiries, resolve disputes, and maintain records of all communications for quality assurance purposes.
7. Platform Improvement: Using anonymized and aggregated usage data to understand how Players interact with the Platform, identify technical issues, and prioritize feature development.
8. Marketing and Promotions (Consent Only): Sending you promotional communications about new games, seasonal offers — such as Idul Fitri and Ramadhan campaigns — and exclusive bonuses, but only where you have explicitly opted in to receive such communications.

7 Sharing & Disclosure of Your Data

tema4d does not sell, rent, or trade your personal data. We may share your data with carefully selected third parties only in the following circumstances:

1. KYC and Compliance Partners: Identity verification providers engaged to authenticate your documents and confirm your eligibility. These partners act as Data Processors under binding data processing agreements and may not use your data for any purpose beyond the verification task.
2. Payment Service Providers: Indonesian banks and e-wallet operators (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, and others) that receive the minimum necessary financial data to execute your requested transactions.
3. Technology and Infrastructure Providers: Cloud hosting, server infrastructure, and cybersecurity vendors that process data on our behalf under strict contractual confidentiality obligations.
4. Game Studios: Game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive session tokens and anonymized Player identifiers for the purpose of delivering their games. They do not receive your full identity or financial data.
5. Legal and Regulatory Authorities: Where required by a valid court order, regulatory directive, law enforcement request, or other legally binding obligation, tema4d may disclose your personal data to the relevant authority. We will notify you of such disclosure where legally permitted to do so.
6. Corporate Transactions: In the event of a merger, acquisition, or sale of substantially all assets of tema4d, your data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained. We will notify affected users of any such transfer.

8 Cookies & Tracking Technologies

tema4d uses cookies and similar local storage technologies to support platform functionality, maintain session security, and gather anonymized usage analytics. The following categories of cookies are deployed on the Platform:

tema4d does not deploy third-party advertising cookies, retargeting pixels, or cross-site tracking scripts. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair your ability to log in and use the Platform.

9 Data Retention

tema4d retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention principles apply:

1. Active Accounts: Personal data associated with an active Player account is retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
2. Financial Transaction Records: Transaction logs, deposit and withdrawal records, and associated payment data are retained for a minimum of five (5) years from the date of each transaction, regardless of account status.
3. KYC Documents: Identity documents submitted for verification are retained for the period required by our licensing conditions, typically five (5) years following the conclusion of the business relationship.
4. Support Communications: Customer support transcripts and correspondence are retained for up to three (3) years from the date of the interaction to support dispute resolution and quality assurance.
5. Marketing Consent Records: Records of your marketing opt-in consent, including the timestamp and method of consent, are retained for the duration of the marketing relationship and for three (3) years following opt-out, to demonstrate compliance.
6. Anonymized Analytics Data: Aggregated, anonymized usage data from which no individual can be identified may be retained indefinitely for platform improvement purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymized using industry-standard data destruction methods.

10 Data Security

tema4d implements a multi-layered technical and organizational security framework to protect your personal data against unauthorized access, accidental loss, alteration, and unlawful disclosure. Our security measures include, but are not limited to:

• 256-Bit SSL/TLS Encryption: All data in transit between your device and our servers is encrypted using TLS 1.2 or higher, preventing interception by third parties.
• Encrypted Data Storage: Personal data and financial records stored within our systems are encrypted at rest using AES-256 encryption standards.
• Access Controls: Internal access to personal data is granted on a strict need-to-know basis. All staff with access to personal data are bound by confidentiality obligations and receive regular data protection training.
• Intrusion Detection and Prevention: tema4d operates continuous network monitoring, intrusion detection systems (IDS), and automated threat response protocols to identify and neutralize security incidents in real time.
• PCI-Compliant Payment Handling: All financial transaction data is processed through PCI DSS-compliant payment gateways. tema4d does not store full bank account credentials or card numbers on its own infrastructure.
• Regular Security Audits: Our platform undergoes periodic independent security audits and penetration testing to identify and address vulnerabilities before they can be exploited.

11 Your Data Subject Rights

As a data subject, you are entitled to exercise the following rights with respect to the personal data tema4d holds about you. To submit a request, contact us at the details provided in Section 16. We will respond within 30 calendar days of receiving a valid request.

1. Right of Access: You may request a copy of all personal data tema4d holds about you, together with information about how it is being processed and the purposes for which it is used.
2. Right to Rectification: If you believe that personal data held about you is inaccurate or incomplete, you may request that it be corrected or updated. Account profile data can also be updated directly through your account settings panel.
3. Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to overriding legal retention obligations (see Section 9).
4. Right to Restrict Processing: You may request that we limit the processing of your data to storage only — for example, while a dispute about its accuracy is resolved — without requesting full erasure.
5. Right to Data Portability: Where processing is based on your consent or on a contract, you have the right to receive a structured, machine-readable copy of your personal data for transfer to another service provider.
6. Right to Object: You have the right to object to processing based on our legitimate interests, including profiling. You also have an absolute right to object to the use of your data for direct marketing at any time.
7. Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

12 Children & Minors

The tema4d platform is strictly intended for adults aged 21 and over. We do not knowingly collect personal data from any person under the age of 21. All account registrations are subject to age verification, and Players who cannot confirm their age during the KYC process will not be granted full account access or withdrawal rights.

If you have reason to believe that a minor has accessed the Platform or submitted personal data without authorization, please contact our support team immediately at the details provided in Section 16. Upon confirmation, we will promptly delete the relevant data and close the associated account.

13 Marketing Communications

tema4d sends promotional communications — including bonus offers, new game announcements, and seasonal campaigns aligned with the Indonesian cultural calendar (such as Ramadhan, Idul Fitri, and Independence Day promotions) — only to Players who have explicitly opted in to receive them during account registration or through their account settings.

1. Opt-In Consent: Marketing consent is collected separately from the general Terms & Conditions acceptance. Declining marketing communications does not affect your ability to use the Platform.
2. Unsubscribe: You may withdraw your marketing consent and opt out of all promotional communications at any time by updating your notification preferences in your account settings, or by sending an opt-out request to our support team. Unsubscribe requests will be processed within 10 business days.
3. Transactional Communications: Certain non-promotional communications — such as deposit confirmations, withdrawal notifications, security alerts, and KYC status updates — are sent regardless of your marketing preferences, as they are necessary for the delivery of services you have requested.

14 Third-Party Links

The tema4d platform may from time to time contain references to or integrations with third-party services — including game studio portals, payment gateway interfaces, and responsible gaming support organizations. This Privacy Policy applies only to data processed by tema4d directly. When you interact with a third-party service, that service's own privacy policy governs the collection and use of any data you provide to it. tema4d accepts no responsibility for the privacy practices of third-party operators.

We recommend reviewing the privacy policies of any third-party service you access through or in connection with the tema4d platform before submitting personal information to that service.

15 Amendments to This Privacy Policy

tema4d reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform functionality. When material changes are made, we will notify registered Players by email and/or by displaying a prominent notice on the Platform at least 7 days prior to the changes taking effect, except where an immediate update is required by law or to address a security threat.

The version date shown at the top of this document indicates when the policy was last revised. We encourage you to review this page periodically to stay informed of how your data is protected. Your continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated policy.

If you object to any change to this Privacy Policy, you should cease using the Platform and may contact us to request account closure and erasure of your data, subject to the retention obligations described in Section 9.

16 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the manner in which tema4d processes your personal data, please reach out to our dedicated support team using the contact details below:

When submitting a data subject rights request, please include your registered account username and a clear description of the right you wish to exercise. This will help us locate your records and process your request as efficiently as possible.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction.