Privacy Policy

Djarum4D ("the Company", "we", "us", "our") operates the online gambling platform accessible at https://djarum4d.cam (the "Platform"). This Privacy Policy describes how the Company collects, processes, stores, discloses, and protects personal data provided by or collected about individuals who register for, access, or use the Platform ("you", "your", "Player").

We are committed to handling your personal data responsibly, transparently, and in a manner consistent with internationally recognised data protection principles. The Company understands that trust in our data handling practices is fundamental to the relationship we maintain with players across Malaysia — from Kuala Lumpur and Petaling Jaya to Penang, Johor Bahru, and Shah Alam.

By registering an account on Djarum4D, accessing the Platform, or otherwise interacting with our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any aspect of this Policy, you should refrain from using the Platform.

The following defined terms are used throughout this Privacy Policy:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information, and online identifiers.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, transmission, or deletion.
• "Data Controller" — Djarum4D, which determines the purposes and means by which personal data is processed.
• "Data Processor" — a third party that processes personal data on behalf of the Company under a contractual agreement and according to our instructions.
• "KYC Data" — identity and document verification data collected for Know Your Customer compliance purposes, including government-issued identification documents, proof of address, and selfie verification images.
• "Sensitive Data" — personal data that warrants heightened protection, including but not limited to financial account details, identification document numbers, and information relating to responsible gambling self-exclusion status.
• "Cookies" — small text files stored on your device by your browser when you access the Platform, used to maintain session state, enable functionality, and collect analytics data.

The following table summarises the categories of personal data we collect, with examples and the primary purpose for collecting each category:

We collect personal data through the following primary channels:

4.1 Direct Collection

Data you provide directly when registering an account, completing KYC verification, submitting a deposit or withdrawal request, contacting our support team, or participating in promotions and surveys.

4.2 Automated Technical Collection

Data collected automatically when you access the Platform, including IP address, device fingerprint, browser metadata, session activity logs, and cookie-derived identifiers. This collection occurs whether or not you are logged in to your account.

4.3 Third-Party Sources

In certain circumstances, we may receive personal data about you from third-party sources, including:

• Payment service providers (such as Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, DuitNow, and FPX processors) — transaction confirmation and fraud flag data.
• Identity verification service providers engaged to assist with KYC processing — document validation results and identity match scores.
• Fraud prevention and AML screening services — adverse media checks and sanctions list screening results.
• Our licensing authority — regulatory instructions relating to specific player accounts or transactions.

Djarum4D processes personal data for the following specific, legitimate purposes:

• Account Creation and Management: Establishing and maintaining your player account, including authentication, preference settings, account history, and communications.
• Identity Verification and KYC Compliance: Confirming your identity and age (21+), verifying the legitimacy of payment methods, and complying with anti-money laundering obligations under our licensing framework.
• Payment Processing: Facilitating deposits and withdrawals through Malaysian payment methods, reconciling transactions, and resolving payment disputes.
• Gaming Operations: Delivering gameplay, recording wager and outcome history, administering VIP tier advancement, and settling promotional bonus requirements.
• Fraud Prevention and Security: Detecting and investigating suspicious activity, enforcing our one-account policy, identifying multi-accounting, and protecting the integrity of the Platform.
• Responsible Gambling: Monitoring player activity for indicators of problem gambling, enforcing self-imposed deposit or loss limits, processing cooling-off and self-exclusion requests, and maintaining self-exclusion records.
• Customer Support: Responding to enquiries, resolving disputes, investigating complaints, and maintaining records of support interactions.
• Legal and Regulatory Compliance: Meeting obligations under our international gaming licence, responding to lawful requests from competent authorities, and maintaining records required by law.
• Platform Improvement: Analysing aggregated usage data to improve product features, identify technical issues, and optimise the player experience — including mobile performance for players accessing via Maxis, Celcom, Digi, or Unifi connections.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time.

The Company processes personal data on the following legal bases, applied as appropriate to each specific processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you entered into upon registration — including account management, payment processing, and gameplay delivery.
• Legal Obligation: Processing required to comply with applicable laws, regulatory requirements under our gaming licence, anti-money laundering statutes, and lawful orders from competent authorities.
• Legitimate Interests: Processing in pursuit of the Company's legitimate business interests, including fraud prevention, platform security, and responsible gambling monitoring, provided such interests are not overridden by your fundamental privacy rights.
• Consent: Where we rely on your consent as the legal basis for processing — for example, for marketing communications or the use of non-essential cookies — you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

Djarum4D does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following limited circumstances:

7.1 Service Providers (Data Processors)

We engage carefully selected third-party service providers to assist in delivering the Platform. These providers process personal data strictly on our instructions and are bound by data processing agreements that prohibit unauthorised use of your data. Categories of such providers include:

• Payment processing and e-wallet gateway providers (including those supporting Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and Hong Leong integrations)
• Identity and document verification (KYC) service providers
• Fraud detection and AML screening service providers
• Cloud infrastructure and data hosting providers
• Customer support platform providers
• Email and notification delivery service providers
• Analytics platform providers (using anonymised or pseudonymised data where possible)

7.2 Legal and Regulatory Disclosure

We may disclose personal data where required to do so by applicable law, court order, regulatory direction, or lawful request from a competent authority. We will, where legally permissible, notify affected players of such disclosures.

7.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of the Company or its assets, player personal data may be transferred to the relevant successor entity, subject to that entity maintaining equivalent privacy protections and notifying players accordingly.

As an internationally licensed online gaming operator, certain of the Company's data processing activities — including cloud infrastructure, KYC verification services, and fraud screening — may involve the transfer of personal data to servers or processors located outside Malaysia.

Where such transfers occur, the Company takes reasonable steps to ensure that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses in agreements with third-party processors and, where applicable, reliance on recognised international data transfer frameworks.

Players who are concerned about the international transfer of their personal data may contact our support team for further information about the specific safeguards applicable to their data.

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

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be associated with an identified individual.

Djarum4D uses cookies and similar tracking technologies to operate the Platform effectively, maintain login sessions, detect fraud, and improve the player experience. The following categories of cookies are used:

10.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function. They include session authentication tokens, security tokens, and load-balancing cookies. These cannot be disabled without impairing core Platform functionality. No consent is required for strictly necessary cookies.

10.2 Functional Cookies

These cookies remember your preferences such as currency display, language settings (where applicable), and UI customisations. They enhance your experience but are not strictly essential to Platform operation.

10.3 Analytics Cookies

We use privacy-respecting analytics tools to understand how players interact with the Platform — which pages are most visited, how long sessions last, and where technical errors occur. Analytics data is aggregated and does not personally identify individual players where possible.

10.4 Managing Cookies

You can control and delete cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform, including the ability to maintain a logged-in session. Guidance on cookie management is available through your browser's help documentation.

Subject to applicable law and our regulatory obligations (which may in certain circumstances limit or delay the exercise of these rights), you have the following rights in relation to your personal data held by Djarum4D:

• Right of Access: You may request a copy of the personal data we hold about you, together with information about how it is being processed. We will respond to verified access requests within 30 days.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held in your account. For certain data fields (such as your registered name), correction may require supporting documentation.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data. Please note that erasure requests may be limited where we are required to retain data under applicable legal, regulatory, or contractual obligations — such as AML record-keeping requirements.
• Right to Restrict Processing: You may request that we restrict the active processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where processing is unlawful.
• Right to Data Portability: Where processing is based on your consent or performed by automated means, you may request a copy of your data in a structured, machine-readable format for transfer to another controller.
• Right to Object: You may object to processing based on our legitimate interests, including for the purpose of direct marketing communications. Where you object to marketing, we will cease processing your data for that purpose immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of the above rights, please contact our support team via the 24/7 live chat or by emailing us at the address provided in Section 16 of this Policy. We will acknowledge your request within 72 hours and provide a substantive response within 30 calendar days, or notify you if an extension is required.

The Djarum4D Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21.

Age verification is a mandatory step in our KYC process. Any account found to be registered by an individual under the age of 21 will be immediately suspended, all funds held in the account will be returned to the deposit source (net of any winnings derived from that account), and all associated personal data will be deleted.

If you believe a person under the age of 21 has registered an account on the Platform, please contact our support team immediately so we can investigate and take appropriate action.

Djarum4D implements technical and organisational security measures appropriate to the sensitivity of the personal data we hold and the risks associated with its processing. These measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your device and the Platform is protected by TLS 1.2 or higher (256-bit SSL). This applies to all login sessions, payment flows, form submissions, and API communications.
• Encryption at Rest: Sensitive personal data stored in our databases — including KYC documents, identity data, and financial records — is encrypted at rest using industry-standard encryption.
• Access Controls: Access to personal data is restricted on a need-to-know basis. Staff with access to player data are subject to background checks, confidentiality agreements, and role-based access control policies.
• Password Security: Player passwords are hashed using a strong cryptographic hashing algorithm. Plaintext passwords are never stored.
• Two-Factor Authentication: 2FA is available for all player accounts as an additional layer of login security.
• Security Monitoring: Our systems are subject to continuous automated security monitoring, anomaly detection, and periodic penetration testing by qualified security professionals.
• Incident Response: In the event of a data breach that poses a risk to your rights, we will notify affected players and, where required, relevant regulatory authorities within the timeframes prescribed by applicable law.

While we implement robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and should notify us immediately if you suspect unauthorised access to your account.

The Platform may contain references to or integrations with third-party services — including payment gateways for Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong, DuitNow, and FPX — through which transactions are processed. When you interact with third-party payment interfaces, your data is subject to that third party's privacy policy in addition to ours.

Djarum4D is not responsible for the privacy practices, data handling, or security of third-party websites, applications, or services. We recommend reviewing the privacy policies of any third-party service you use in connection with the Platform. Our Privacy Policy applies solely to the Djarum4D Platform and services operated directly by the Company.

Djarum4D reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, regulatory requirements, or Platform features. When material changes are made, we will:

• Update the "Effective Date" at the top of this document;
• Where reasonably practicable, notify registered players via email or on-Platform notification prior to the changes taking effect; and
• Publish the revised Privacy Policy at https://djarum4d.cam/privacy-policy.

Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to remain informed about our data handling practices.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the manner in which Djarum4D processes your personal data, please contact us through any of the following channels:

• 24/7 Live Chat: Available directly on the Djarum4D Platform. Our support team can acknowledge data privacy enquiries and escalate them to the appropriate internal team. Average response time is under 3 minutes.
• Email: [email protected] — for privacy-specific requests, please include "Privacy Request" in your subject line, along with your registered account username and a clear description of your request or concern.

We aim to acknowledge all privacy-related communications within 48 hours and provide a substantive response within 30 calendar days. Where a request is complex or numerous, we may extend this period by a further 30 days, notifying you of the extension and the reason for it.

If you are not satisfied with our response, you may be entitled to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. Malaysian players may consult the Department of Personal Data Protection (JPDP) for guidance on their rights under the Personal Data Protection Act 2010.