Privacy Policy — Your Data, Our Responsibility

1 Definitions

In this Privacy Policy, the following terms carry the meanings assigned to them below:

• "Personal Data" means any information relating to an identified or identifiable natural person — including but not limited to full name, date of birth, residential address, email address, phone number, Indonesian national identity number (NIK on KTP), financial account details, and device identifiers.
• "Processing" means any operation performed on Personal Data, whether or not by automated means — including collection, recording, storage, structuring, retrieval, use, disclosure, erasure, or destruction.
• "Controller" means kiyo4d, the entity that determines the purposes and means of Processing your Personal Data.
• "Processor" means any third party engaged by kiyo4d to Process Personal Data on its behalf, under binding contractual obligations.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the Processing of your Personal Data for a stated purpose.
• "You" / "Player" means any individual who visits the kiyo4d Platform, creates an account, or otherwise interacts with kiyo4d's services.
• "Platform" means the kiyo4d website at https://kiyo4d.club, including all associated pages, services, and mobile-optimized interfaces.

2 Personal Data We Collect

kiyo4d collects Personal Data in three primary ways: data you actively provide, data collected automatically through your use of the Platform, and data obtained from trusted third-party verification partners. The categories of data collected are outlined in the table below.

3 Legal Basis for Processing

kiyo4d processes your Personal Data on one or more of the following lawful grounds:

• Contractual Necessity: Processing is required to perform the contract between you and kiyo4d — namely, to create and maintain your account, process deposits and withdrawals in Indonesian Rupiah (IDR / Rp), and deliver the gaming services you have requested.
• Legal Obligation: kiyo4d is required by its international operating licence and applicable AML regulations to collect and retain certain categories of personal and financial data for a prescribed minimum period.
• Legitimate Interests: kiyo4d processes Technical Data and Usage Data to protect the security and integrity of the Platform, prevent fraud, detect duplicate accounts, and improve the player experience — provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where kiyo4d sends you direct marketing communications or uses non-essential cookies for analytics and personalization, it does so on the basis of your freely given consent. You may withdraw consent at any time by contacting [email protected] or using the opt-out mechanism provided in any marketing email.

4 How We Use Your Personal Data

kiyo4d uses the Personal Data it collects for the following specific purposes:

• Account Management: Creating, verifying, and maintaining your kiyo4d player account; processing password resets and two-factor authentication (2FA).
• Transaction Processing: Facilitating deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja without hidden conversion fees.
• Identity and Age Verification: Confirming that you are at least 21 years of age and a genuine individual using a valid Indonesian government-issued identity document.
• Fraud and Security Monitoring: Detecting and preventing unauthorized account access, duplicate registrations, bonus abuse, money laundering, and other prohibited activities.
• Responsible Gaming Compliance: Monitoring gameplay patterns to identify signs of problem gambling behavior and trigger appropriate responsible gaming interventions, including deposit limit enforcement and self-exclusion processing.
• Customer Support: Resolving disputes, responding to account queries, and maintaining records of support interactions for quality assurance and regulatory compliance purposes.
• Regulatory Reporting: Fulfilling mandatory reporting obligations under kiyo4d's international operating licence, including suspicious transaction reports where legally required.
• Marketing Communications: Sending you promotional offers, bonus notifications, and seasonal campaign updates (such as Idul Fitri, Ramadhan, and Chinese New Year / Imlek promotions) where you have opted in. You may unsubscribe at any time.
• Platform Analytics and Improvement: Analyzing aggregated usage data to optimize game load times, improve the sports betting interface, and enhance the overall player experience across devices commonly used in Jakarta, Surabaya, Bandung, Bali, and other Indonesian cities.

kiyo4d will not use your Personal Data for any purpose that is incompatible with those stated above without first obtaining your consent or establishing a new lawful basis.

5 Cookies and Tracking Technologies

kiyo4d uses cookies and similar tracking technologies (including local storage, session tokens, and device fingerprinting) to operate the Platform securely and effectively. The categories of cookies deployed are as follows:

You may manage or revoke cookie consent at any time by contacting kiyo4d support at [email protected]. Please note that disabling Strictly Necessary cookies will impair Platform functionality and may prevent you from logging in or completing transactions.

6 Data Sharing and Disclosure

kiyo4d does not sell your Personal Data. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: Indonesian bank partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction data necessary to process your deposits and withdrawals. These entities process data under their own privacy policies and applicable Indonesian financial regulations.
• KYC and Identity Verification Providers: Licensed third-party identity verification services receive the documents you submit during KYC. These providers are contractually bound to use your data solely for identity verification purposes and are prohibited from retaining or commercializing it beyond that scope.
• Game Studio Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive the minimum technical data necessary to deliver their games within the kiyo4d Platform environment (e.g., a pseudonymized player token). They do not receive your full identity or financial data.
• Fraud Detection and AML Screening Services: kiyo4d engages specialized fraud analytics and AML screening providers to cross-reference player data against watchlists, sanctions databases, and known fraud patterns. These providers operate under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: kiyo4d will disclose Personal Data to competent authorities where required by a valid legal order, court judgment, regulatory directive, or mandatory reporting obligation under international AML standards. kiyo4d will, where legally permissible, notify you of such disclosure.
• Corporate Successors: In the event of a merger, acquisition, or restructuring affecting kiyo4d, your Personal Data may be transferred to the successor entity, which will be required to honor the commitments set out in this Privacy Policy.

7 Data Retention

kiyo4d retains your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following retention periods apply:

• Account Data (Identity, Contact, Financial): Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with international AML record-keeping standards.
• KYC Documentation: Retained for a minimum of five (5) years from the date of submission, as required under anti-money laundering regulations applicable to kiyo4d's operating licence jurisdiction.
• Transaction Records: Retained for a minimum of seven (7) years to support audit, regulatory, and dispute resolution requirements.
• Communications Data (Live Chat, email, WhatsApp): Retained for three (3) years for quality assurance and dispute resolution purposes.
• Technical and Usage Data: Retained in identifiable form for up to twelve (12) months, after which it is anonymized and may be retained indefinitely for aggregate analytics.
• Marketing Consent Records: Retained for the duration of the consent and for two (2) years after consent is withdrawn, as evidence of compliance.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized. Where deletion is not technically possible for a specific data category (e.g., data embedded in backup archives), kiyo4d will isolate and protect it from further Processing until deletion is feasible.

8 Your Data Rights

As a kiyo4d player, you hold the following rights in relation to your Personal Data. To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request — [Your Username]". kiyo4d will respond within 30 calendar days.

• Right of Access: You may request a copy of all Personal Data kiyo4d holds about you, including the categories of data, the purposes for which it is processed, and the recipients with whom it has been shared.
• Right to Rectification: If any Personal Data kiyo4d holds about you is inaccurate or incomplete, you may request that it be corrected or supplemented. This includes updating your registered mobile number, residential address, or email address.
• Right to Erasure ("Right to be Forgotten"): You may request 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 mandatory retention obligations (see Clause 7) and overriding legitimate interests.
• Right to Restriction of Processing: You may request that kiyo4d suspends Processing of your data in specific circumstances — for example, while the accuracy of data is being disputed or while an objection to Processing is being assessed.
• Right to Data Portability: Where Processing is based on consent or contractual necessity, and is carried out by automated means, you may request a copy of your Personal Data in a structured, commonly used, machine-readable format (e.g., JSON or CSV).
• Right to Object: You have the right to object to Processing carried out on the basis of legitimate interests, including profiling for responsible gaming monitoring. kiyo4d will cease such Processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where Processing is based solely on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of Processing carried out prior to withdrawal.

9 Minors and Age Restriction

The kiyo4d Platform is strictly for adults aged 21 and above. kiyo4d does not knowingly collect Personal Data from any individual under the age of 21. Age verification is conducted during the KYC process for all registered players.

If kiyo4d discovers that Personal Data has been collected from a person under 21 years of age — whether through an inaccurate date of birth provided during registration or any other means — the associated account will be immediately suspended, all funds will be returned to the depositing payment source after verification, and the data will be securely deleted as promptly as technically feasible.

If you believe that kiyo4d may have inadvertently collected data from a minor, please contact [email protected] immediately. Adults only (21+).

10 Data Security Measures

kiyo4d implements a layered security architecture to protect your Personal Data against unauthorized access, accidental loss, destruction, or alteration. Key security measures include:

• Encryption in Transit: All data transmitted between your browser or mobile device and kiyo4d's servers is encrypted using TLS 1.2 or higher, enforced site-wide including on all login, deposit, withdrawal, and account management pages.
• Encryption at Rest: Sensitive data fields (including identity documents, financial account details, and KYC records) are encrypted at rest using AES-256 encryption on kiyo4d's server infrastructure.
• Access Controls: Logical access to systems containing Personal Data is restricted to authorized kiyo4d personnel on a role-based, need-to-know basis. Access is logged and reviewed on a regular audit cycle.
• Two-Factor Authentication (2FA): kiyo4d strongly recommends — and for high-value accounts may require — two-factor authentication to protect your player account from unauthorized access.
• Intrusion Detection: kiyo4d's infrastructure is monitored 24/7 (WIB / UTC+7) by automated intrusion detection and prevention systems, supplemented by periodic penetration testing by independent security specialists.
• Employee Training: All kiyo4d staff with access to Personal Data receive mandatory data protection training on an annual basis. Breaches of data handling protocols by employees are subject to disciplinary action.

Notwithstanding these measures, no method of electronic transmission or storage is 100% secure. kiyo4d cannot guarantee absolute security of your data but commits to responding swiftly and transparently to any confirmed security incident in accordance with Clause 11.

11 Data Breach Notification

In the event of a confirmed Personal Data breach that poses a material risk to the rights and freedoms of affected players, kiyo4d will:

1. Notify affected players via their registered email address within 72 hours of confirming the breach, describing the nature of the incident, the categories of data affected, and the approximate number of records involved.
2. Provide clear guidance on the steps players should take to protect themselves — including advice on changing passwords, monitoring bank accounts (BCA, BRI, BNI, Mandiri), and reviewing e-wallet activity (OVO, DANA, GoPay).
3. Report the breach to the relevant supervisory authority under kiyo4d's operating licence jurisdiction within the timeframe mandated by applicable law.
4. Publish a summary of the incident and the remediation measures taken on the kiyo4d Platform within a reasonable period, where doing so does not compromise the ongoing security investigation.

For lower-severity incidents that do not materially affect player rights, kiyo4d will document the breach internally and take corrective action, but may not issue individual player notifications at its discretion.

12 Third-Party Services and Links

The kiyo4d Platform integrates game content from third-party studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. While kiyo4d takes care to work only with reputable, licensed providers, each studio operates under its own privacy practices and end-user agreements. kiyo4d is not responsible for the data practices of third-party game studios beyond the scope of the data processing agreements it holds with them.

The kiyo4d Platform does not embed links to external commercial websites. Any third-party service you access independently of kiyo4d — including your Indonesian bank's internet banking portal (BCA, BRI, BNI, Mandiri), your e-wallet app (OVO, DANA, GoPay, ShopeePay, LinkAja), or any responsible gaming support organization — is subject to that service's own privacy policy, and kiyo4d accepts no responsibility for such external data practices.

13 Changes to This Privacy Policy

kiyo4d reserves the right to update this Privacy Policy at any time. When material changes are made, kiyo4d will:

• Publish the revised Policy on this page with an updated Effective Date and Version number at the top of the document.
• Send a notification to all registered players via their registered email address at least 7 calendar days before the changes take effect, except where immediate amendment is required by applicable law or a regulatory directive.
• Display a prominent in-Platform banner on first login after the update, prompting you to review the revised Policy.

Your continued use of the kiyo4d Platform after the stated effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not accept the amended Policy, you must cease using the Platform and request Account closure in accordance with the Terms & Conditions, Clause 11.

We encourage you to review this page periodically. The Version number and Effective Date at the top of this document will always reflect the most current revision.

14 Contact and Data Rights Requests

For any questions, concerns, or formal requests related to this Privacy Policy or kiyo4d's data practices, please contact our Data Protection team through the following channels:

• Live Chat: Available 24/7 on the Platform — fastest response for general privacy queries.
• Email: [email protected] — use subject line "Privacy Request — [Your Username]" for formal data rights submissions.
• WhatsApp: +62 811 0000 4444
• Response Times: General queries — within 24 hours (WIB). Formal data rights requests — within 30 calendar days of identity verification.

All formal legal notices regarding data protection matters must be submitted in writing to [email protected]. kiyo4d will acknowledge receipt within 3 business days (WIB).