Privacy Policy

1. Information We Collect

1.1 Personal Information You Provide

When you register for a clen4d account, we collect personal information necessary to verify your identity, process transactions, and provide our services. This includes:

• Identity Information: Full legal name, date of birth, gender, and Indonesian national identification number (KTP number) for age verification and KYC compliance.
• Contact Information: Email address, phone number, and residential address in Indonesia.
• Financial Information: Bank account details for deposits and withdrawals (including bank name, account number, and account holder name), e-wallet account identifiers (OVO, DANA, GoPay), and transaction history.
• Account Credentials: Username, password (stored in encrypted form), and security questions/answers for account recovery.
• Verification Documents: Copies of your KTP (Indonesian ID card), selfie photographs for identity verification, and any additional documentation requested for enhanced due diligence.

1.2 Information Collected Automatically

When you access and use the clen4d platform, we automatically collect certain technical and usage information:

• Device Information: IP address, device type, operating system, browser type and version, device identifiers, and screen resolution.
• Usage Data: Pages visited, games played, bet history, deposit and withdrawal transactions, login times, session duration, and navigation patterns on our platform.
• Location Data: General geographic location based on IP address to verify compliance with territorial restrictions and detect potentially fraudulent access.
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to recognize your device, remember your preferences, analyze platform performance, and prevent fraud. See Section 8 for detailed cookie information.

1.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment processors and financial institutions to verify transaction details and prevent fraud
• Identity verification services to confirm your identity and age
• Game providers (Pragmatic Play, Evolution Gaming, etc.) regarding your game activity and outcomes
• Marketing partners (where you have consented to such data sharing)
• Public databases and credit reference agencies for fraud prevention purposes

2. How We Use Your Information

clen4d uses your personal information for the following purposes, all of which are necessary for operating our gaming platform and fulfilling our legal obligations:

2.1 Service Provision

• Creating and managing your account on the clen4d platform
• Processing deposits, withdrawals, and bet transactions
• Providing customer support via live chat, email, and WhatsApp
• Administering bonuses, promotions, and loyalty rewards
• Facilitating gameplay across sports betting, casino games, slots, and togel products
• Resolving disputes, investigating complaints, and enforcing our Terms & Conditions

2.2 Legal and Compliance Obligations

• Verifying your identity and age (21+ requirement) in compliance with Indonesian law
• Conducting KYC (Know Your Customer) checks to prevent identity theft and fraud
• Monitoring transactions for money laundering, fraud, and other illegal activities
• Complying with legal obligations, court orders, and regulatory requirements
• Maintaining records for audit and reporting purposes as required by law
• Implementing responsible gaming measures including self-exclusion and deposit limits

2.3 Platform Security and Fraud Prevention

• Detecting and preventing fraudulent activity, bonus abuse, and account security breaches
• Monitoring for multiple accounts and collusive behavior
• Protecting against cyber attacks, hacking attempts, and unauthorized access
• Conducting security assessments and vulnerability testing
• Investigating suspicious betting patterns and unusual account activity

2.4 Communication and Marketing

• Sending transactional emails (account registration, deposit confirmations, withdrawal notifications)
• Providing customer service communications and responding to your inquiries
• Sending promotional offers, bonus notifications, and platform updates (with your consent)
• Conducting customer satisfaction surveys and collecting feedback
• Informing you of changes to our Terms & Conditions, Privacy Policy, or services

2.5 Platform Improvement and Analytics

• Analyzing usage patterns to improve platform performance and user experience
• Identifying popular games and features to optimize our content offerings
• Conducting A/B testing to enhance website design and functionality
• Generating anonymized statistics and reports for business intelligence
• Training our customer support team to provide better service

3. Legal Basis for Processing

Under applicable data protection laws, clen4d processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contract with you (providing gaming services as outlined in our Terms & Conditions).
• Legal Obligation: Processing is required to comply with Indonesian law, including age verification, KYC requirements, anti-money laundering regulations, and tax reporting.
• Legitimate Interest: Processing is necessary for our legitimate business interests including fraud prevention, platform security, service improvement, and debt collection, provided these interests do not override your fundamental rights.
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you can withdraw at any time without affecting the lawfulness of processing based on consent before withdrawal.

4. Data Sharing and Disclosure

clen4d does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for the purposes described:

4.1 Service Providers

We share information with trusted third-party service providers who assist in operating our platform:

• Payment Processors: To process deposits and withdrawals via BCA, BRI, BNI, Mandiri, and e-wallet providers
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and other software suppliers to deliver game content
• Identity Verification Services: For KYC compliance and age verification
• Cloud Hosting Providers: For secure data storage and platform infrastructure
• Customer Support Software: For live chat, email management, and ticketing systems
• Analytics Providers: For platform performance monitoring and user behavior analysis

All service providers are contractually bound to protect your data and use it only for the specific purposes we authorize.

4.2 Legal and Regulatory Authorities

We may disclose your information to law enforcement, regulatory bodies, courts, or government agencies when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, court orders, or regulatory requests
• Detect, prevent, or address fraud, security breaches, or illegal activities
• Enforce our Terms & Conditions and protect our legal rights
• Protect the safety and security of our users and the public

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on our platform before your information becomes subject to a different privacy policy.

4.4 With Your Consent

We may share your information with other third parties when you have provided explicit consent for such sharing, for example when participating in third-party promotions or contests.

5. Data Security Measures

clen4d implements comprehensive security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

• Encryption: All data transmission between your device and our servers is protected using 256-bit SSL (Secure Socket Layer) encryption - the same standard used by major Indonesian banks.
• Secure Storage: Personal information is stored on secure servers located in protected data centers with restricted physical access, environmental controls, and 24/7 monitoring.
• Password Protection: All passwords are hashed using industry-standard cryptographic algorithms and are never stored in plain text.
• Access Controls: We implement strict internal access controls, ensuring that only authorized personnel with legitimate business needs can access personal data.
• Regular Security Audits: Our systems undergo regular security assessments, vulnerability testing, and penetration testing by independent security experts.
• Fraud Monitoring: We employ automated fraud detection systems that monitor transactions and account activity for suspicious patterns.
• Employee Training: All employees with access to personal data receive regular training on data protection and security best practices.

While we implement robust security measures, no internet transmission or electronic storage system is completely secure. We cannot guarantee absolute security, but we commit to promptly notifying you and relevant authorities in the event of a data breach that poses a risk to your rights and freedoms.

6. Data Retention

clen4d retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with our legal obligations:

• Active Accounts: Personal information for active accounts is retained for the duration of your relationship with clen4d and for a reasonable period thereafter to address customer service inquiries, disputes, or legal claims.
• Closed Accounts: After account closure, we retain certain information for up to 7 years to comply with Indonesian financial record-keeping requirements, tax obligations, and to prevent fraud.
• Transaction Records: Financial transaction records are retained for 7 years in accordance with Indonesian anti-money laundering regulations.
• Self-Excluded Users: For users who have requested self-exclusion, we retain minimal information necessary to enforce the exclusion and prevent account re-registration during the exclusion period.
• Marketing Data: If you withdraw consent for marketing communications, we will suppress your data from marketing lists while retaining a record of your opt-out preference to honor your request.

After the retention period expires, personal information is securely deleted or anonymized so that it can no longer identify you.

7. Your Privacy Rights

Under Indonesian data protection law and international privacy standards, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request a copy of the personal information we hold about you. This includes information about how we use your data, who we share it with, and how long we retain it. To request access, contact our Data Protection Officer at [email protected]. We will respond within 30 days and provide the information in a commonly used electronic format.

7.2 Right to Rectification

If any of your personal information is inaccurate or incomplete, you have the right to request correction. You can update most information directly through your account settings, or contact customer support for assistance. We will update your records within 7 business days of verification.

7.3 Right to Erasure

You may request deletion of your personal information in certain circumstances, such as when the information is no longer necessary for the purposes for which it was collected, or you withdraw consent. However, we may retain certain information where required by law or necessary to enforce our Terms & Conditions, resolve disputes, or prevent fraud. Account closure requests can be submitted to our support team.

7.4 Right to Restrict Processing

You have the right to request that we limit how we use your personal information in certain situations, such as while we verify the accuracy of the information or assess your objection to processing.

7.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another service provider where technically feasible.

7.6 Right to Object

You have the right to object to processing of your personal information where we rely on legitimate interests as our legal basis. This includes the right to opt out of marketing communications at any time by clicking the unsubscribe link in emails or contacting customer support.

7.7 Right to Withdraw Consent

Where we process your information based on consent (such as for marketing), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

7.8 How to Exercise Your Rights

To exercise any of these rights, please contact us at [email protected] or through our customer support channels. We may request verification of your identity before processing your request to ensure data security. There is no fee for exercising your rights unless your request is manifestly unfounded or excessive.

8. Cookies and Tracking Technologies

clen4d uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how you use our services.

8.1 Types of Cookies We Use

• Essential Cookies: Required for platform functionality including account login, session management, and security features. These cannot be disabled.
• Performance Cookies: Collect anonymous data about how users interact with our platform, helping us identify and fix technical issues.
• Functional Cookies: Remember your preferences such as language settings, game favorites, and display options.
• Marketing Cookies: Track your browsing activity to deliver personalized advertisements and measure campaign effectiveness (requires your consent).

8.2 Managing Cookies

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect platform functionality. Most browsers allow you to refuse all cookies or indicate when a cookie is being sent. However, some features of clen4d may not function properly without cookies enabled.

9. Third-Party Links and Services

The clen4d platform may contain links to third-party websites, applications, or services including game providers, payment processors, and social media platforms. This Privacy Policy applies only to information collected by clen4d. We are not responsible for the privacy practices of third-party sites and encourage you to read their privacy policies before providing any personal information.

10. Children's Privacy

clen4d services are strictly for adults aged 21 and above. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected information from someone under 21, we will immediately delete that information and close the associated account. If you believe a minor has accessed our platform, please contact us immediately at [email protected].

11. International Data Transfers

While clen4d primarily serves Indonesian users, your personal information may be transferred to and processed in countries outside Indonesia where our service providers and data centers are located. When we transfer data internationally, we ensure appropriate safeguards are in place through contractual agreements that require recipients to protect your information to standards equivalent to Indonesian data protection law. By using our services, you consent to such international transfers.

12. Changes to This Privacy Policy

clen4d reserves the right to update this Privacy Policy to reflect changes in our data practices, legal requirements, or platform features. When we make material changes, we will notify you by email to your registered email address and/or through a prominent notice on our platform at least 30 days before the changes take effect. The "Last Updated" date at the top of this page indicates when the policy was most recently revised. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of clen4d services after changes take effect constitutes your acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through our website
• WhatsApp Support: Contact details provided to registered users

We will respond to privacy-related inquiries within 30 days. For urgent security concerns, please use our live chat for immediate assistance. If you are not satisfied with our response to a privacy complaint, you have the right to lodge a complaint with the relevant Indonesian data protection authority.