Privacy Policy

1 Introduction

cland4 operates as an internationally oriented online gaming platform primarily serving players in Indonesia. We recognize that the personal information you share with us is entrusted to us in confidence, and we take that responsibility seriously. This Policy is designed to give you a clear, transparent understanding of our data practices so that you can make informed decisions about the personal information you provide.

cland4 processes personal data only to the extent necessary to deliver our gaming services, verify your identity, process financial transactions, comply with applicable anti-money laundering obligations, and communicate with you about your account and promotions. We do not monetize your personal data by selling it to third-party advertisers or data brokers.

This Policy applies to all Players resident in Indonesia, including those accessing the Platform from Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, Semarang, and other Indonesian cities. It covers data collected via the Platform website, any mobile-optimized interface, and all direct communications channels including live chat, email, and customer support messaging.

2 Definitions

The following terms, as used in this Privacy Policy, carry the meanings defined below.

3 Personal Data We Collect

We collect different categories of personal data depending on how you interact with cland4. The categories below outline what we collect and why each category is necessary.

3.1 Registration Data

• Full legal name — required for KYC verification and withd rawal processing.
• Date of birth — to confirm you are at least 21 years of age, as required by our eligibility policy.
• Email address — used for account communications, promotional notifications (where opted in), and password recovery.
• Mobile phone number — used for two-factor authentication and account security alerts.
• Residential address — collected during KYC to confirm Indonesian residency and comply with AML obligations.
• Username and password — password is stored as a one-way cryptographic hash; cland4 never stores or transmits your password in plain text.

3.2 Identity Verification (KYC) Data

• Government-issued photo ID — national identity card (KTP), passport, or driver's license, submitted as a scanned image or photograph.
• Proof of address — a recent utility bill, bank statement, or official document confirming your residential address in Indonesia.
• Selfie or liveness check — a photograph or short video taken during the KYC process to confirm that the submitter matches the identity document provided.
• Source-of-funds documentation — bank statements or payslips that may be requested for high-value deposit or withdrawal transactions in accordance with AML requirements.

3.3 Financial Transaction Data

• Bank account details — BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, and Bank Permata account numbers used for deposits and withdrawals; stored in encrypted form.
• E-wallet identifiers — registered phone numbers or account IDs associated with OVO, DANA, GoPay, ShopeePay, or LinkAja accounts used on the Platform.
• Transaction history — records of all deposits, withdrawals, bonus credits, and wagers, retained for a minimum of five years for AML compliance purposes.

3.4 Gaming and Behavioral Data

• Game session records including game type, stake amounts, outcomes, and session duration — used for personalization, responsible gaming monitoring, and dispute resolution.
• Sports betting history including markets wagered on (BRI Liga 1, EPL, La Liga, Champions League, Timnas Indonesia matches), odds accepted, and bet types including mix parlay accumulators and Asian handicap (voor bola) selections.
• Responsible gaming tool usage including self-exclusion requests, deposit limit settings, and session-time reminders.

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP — used for fraud detection, access-restriction enforcement, and regulatory compliance.
• Device type, operating system, browser type and version — collected automatically to optimize platform performance and troubleshoot technical issues.
• Session timestamps, page-view logs, and navigation paths — used for security monitoring and platform analytics.

3.6 Communications Data

• Records of live chat conversations, email correspondence, and support ticket submissions — retained for quality assurance, dispute resolution, and regulatory audit purposes.
• Responses to surveys or feedback forms submitted voluntarily by Players.

4 How We Collect Your Data

cland4 collects personal data through the following channels and mechanisms:

• Directly from you: When you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact customer support, or participate in a survey or promotion.
• Automatically: Via cookies, web beacons, log files, and similar tracking technologies embedded in the Platform, which record your device information, IP address, and browsing behavior as you navigate our pages.
• From third-party verification providers: Identity and fraud-screening data obtained from KYC service partners during the account verification process.
• From payment processors: Transaction confirmation data returned by banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) following a completed deposit or withdrawal.
• From publicly available sources: In limited circumstances, publicly accessible records may be consulted to verify identity or detect fraud, including politically exposed persons (PEP) screenings and sanctions list checks.

5 Purpose of Processing

cland4 processes your personal data only for the specific, legitimate purposes described below. We do not process your data in any manner incompatible with these stated purposes.

6 Legal Basis for Processing

cland4 relies on the following legal grounds to process your personal data, consistent with internationally recognized data protection principles:

• Contractual necessity: Processing is required to fulfill our obligations under the Terms & Conditions you accepted at registration — including account management, payments, and service delivery. Without this processing, we cannot provide the Platform's services.
• Legal obligation: Certain processing activities — particularly KYC verification, AML record-keeping, and sanctions screening — are mandatory under internationally recognized financial crime prevention standards that cland4 voluntarily adheres to as a responsible gaming operator.
• Legitimate interests: Processing for fraud detection, platform security, responsible gaming monitoring, and service improvement is justified by cland4's legitimate interest in operating a safe, fair, and sustainable gaming platform — provided these interests are not overridden by your privacy rights.
• Consent: Where we send promotional communications by email or SMS, we rely on your explicit opt-in consent. You may withdraw this consent at any time by updating your account notification preferences or contacting our support team.

7 Data Sharing & Disclosure

cland4 does not sell, rent, or trade your personal data to any third party for commercial gain. We share personal data only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose.

• Payment processors and banking partners: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja receive transaction data strictly as required to process your deposits and withdrawals. These entities operate under their own privacy policies and are subject to Indonesian banking regulations.
• KYC and identity verification providers: Specialist third-party verification partners process your identity documents and liveness-check data under strict data processing agreements with cland4. These providers are prohibited from using your data for any purpose other than verification services rendered on our behalf.
• Game content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive anonymized session data (e.g., game round identifiers) as part of normal RNG audit and game-delivery processes. These partners do not receive your identity or financial data.
• Cloud hosting and infrastructure providers: cland4 uses reputable cloud infrastructure services to host the Platform and store data securely. These providers operate as Data Processors under binding contractual terms and cannot use your data independently.
• Fraud prevention networks: In the event of suspected fraud, money laundering, or multi-accounting, cland4 may share relevant data with industry fraud-prevention databases or cooperating operators to protect the wider gaming community.
• Legal and regulatory authorities: cland4 will disclose personal data to law enforcement agencies, courts, or regulatory bodies when required to do so by a valid legal order, warrant, or statutory obligation. We will notify affected Players of such disclosures where legally permissible.
• Business transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity subject to the same privacy protections described in this Policy. We will notify you of any such transfer by email before it takes effect.

8 Cookies & Tracking Technologies

cland4 uses cookies and similar technologies to ensure the Platform functions correctly and to improve your experience. The table below summarizes the types of cookies we use.

You may control non-essential cookies through your browser settings. Disabling strictly necessary cookies will prevent you from logging into your account. Disabling analytics cookies will not affect your ability to use the Platform but will reduce our ability to identify and fix user-experience issues.

9 Data Retention

cland4 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Our standard retention periods are as follows:

• Active account data: Retained throughout the lifetime of your account plus a minimum of five (5) years following account closure, to satisfy AML record-keeping requirements.
• KYC documentation: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later. Documents may be retained longer if required by a live regulatory investigation or legal proceeding.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction. This applies to all deposits, withdrawals, bonus credits, and gaming wagers.
• Customer support communications: Retained for three (3) years from the date of the interaction. Communications involved in unresolved disputes are retained until final resolution plus one (1) additional year.
• Analytics and technical log data: Aggregated and anonymized after 13 months. Raw log files containing IP addresses are deleted after 90 days.
• Marketing consent records: Retained for the duration of your opt-in plus three (3) years following withdrawal of consent, as evidence of your prior authorization.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized using industry-standard data destruction methods. Anonymized, aggregated data that can no longer be linked to an identifiable individual may be retained indefinitely for statistical purposes.

10 Data Security

The security of your personal data is a top operational priority at cland4. We implement a multi-layered security architecture combining technical, organizational, and procedural controls to protect your data against unauthorized access, disclosure, alteration, and destruction.

• Encryption in transit: All data transmitted between your device and the cland4 Platform is encrypted using TLS 1.2 or higher. Our SSL certificate is maintained at all times and verified by independent certificate authorities.
• Encryption at rest: Sensitive data including bank account numbers, identity document images, and KYC records are stored using AES-256 encryption.
• Password security: User passwords are hashed using bcrypt with a per-user salt. Passwords are never stored in recoverable form. cland4 staff cannot retrieve your password — only a reset is possible.
• Two-factor authentication (2FA): Players are strongly encouraged to enable 2FA via SMS or authenticator app. 2FA is mandatory for all withdrawal requests above Rp 5,000,000.
• Access controls: Access to personal data within cland4's internal systems is restricted on a strict need-to-know basis. Staff with data access undergo background checks and mandatory data protection training annually.
• Penetration testing: The Platform undergoes independent security penetration testing at least once per year, with critical findings remediated within 30 days of identification.
• Incident response: In the event of a data breach that poses a risk to your rights, cland4 will notify affected Players within 72 hours of confirming the breach, and will document and report the incident in accordance with applicable data protection standards.

11 Your Data Rights

As a Player on cland4, you hold the following rights with respect to your personal data. To exercise any of these rights, please contact our Data Protection team at [email protected] with your full name, registered email address, and a clear description of your request.

cland4 will respond to all data rights requests within 30 calendar days of receipt. Where a request is complex or we receive a high volume of requests simultaneously, we may extend this period by an additional 30 days, with written notice to you explaining the delay. We will not charge a fee for handling data rights requests unless a request is manifestly unfounded or excessive.

12 Protection of Minors

cland4 strictly prohibits access to and use of the Platform by individuals under the age of 21. The Platform is intended exclusively for adults aged 21 and above. We implement the following measures to prevent the collection of data from minors:

• All account registrations require declaration of date of birth. Users declaring an age under 21 are blocked from completing registration.
• KYC verification requires submission of a government-issued photo ID confirming the Player's date of birth. Accounts where age cannot be verified are restricted pending document review.
• If cland4 becomes aware that personal data has been inadvertently collected from an individual under the age of 21, we will immediately suspend the associated account, delete all collected personal data, and return any deposited funds to their verified source.
• Parents or guardians who believe a minor has registered on cland4 are encouraged to contact us immediately at [email protected] with relevant details so that we can take swift remedial action.

13 Third-Party Links & Services

The cland4 Platform may contain references to or integrations with third-party services, such as payment gateways (BCA, OVO, DANA), game studios (Pragmatic Play, Evolution Gaming), and identity verification providers. cland4 is not responsible for the privacy practices of these third parties.

• When you interact with a third-party service through the Platform — for example, completing a bank transfer via your BCA online banking portal — you are subject to that third party's privacy policy and terms of use in addition to this Policy.
• cland4 conducts due diligence on all third-party Data Processors before engagement and requires them to operate under contractual data protection obligations consistent with this Policy.
• We recommend reviewing the privacy policies of your bank, e-wallet provider, and any other service you use in connection with your cland4 account to understand how they handle your personal data independently of cland4.

14 Changes to This Privacy Policy

cland4 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable regulations, or Platform features. We handle policy changes as follows:

• Material changes — defined as modifications that significantly affect how we collect, use, or share your personal data — will be communicated to you by email to the address on file at least seven (7) calendar days before the revised Policy takes effect. A prominent notice will also be displayed on the Platform homepage during this notice period.
• Minor changes — such as clarifications of existing language, updated contact details, or corrections of typographical errors — take effect immediately upon publication on this page without advance notice.
• The "Last Updated" date displayed at the top of this page reflects the date of the most recent revision. We encourage you to review this page periodically to stay informed of how cland4 protects your personal data.
• Your continued use of the Platform after the effective date of a revised Policy constitutes your acknowledgment and acceptance of the updated terms. If you do not agree to a revised Policy, you must discontinue use of the Platform and request account closure before the effective date.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or cland4's data protection practices, please contact our Data Protection team through the following channels. All contact details are provided as plain text — no clickable links or mailto protocols are used.

• Email (Data Protection Inquiries): [email protected] — responses within 24 hours for general inquiries; within 30 days for formal data rights requests
• Live Chat: Available 24/7 directly through the Platform — average response under 2 minutes for general queries
• WhatsApp: +62 812 3456 7890 — available 08:00–02:00 WIB daily
• Formal Written Requests: For data subject access requests, erasure requests, or formal complaints, please email [email protected] with the subject line "Data Rights Request" and include your full name, registered email address, account username, and a description of your request