Privacy Policy

1 Introduction

pam4d ("we", "us", "our") operates the online betting and gaming platform accessible at https://pam4d.one (the "Platform"). In the course of providing our sportsbook, live casino, slots, and togel (Indonesia's traditional numbers lottery) services to members across Indonesia, we necessarily collect and process personal data.

This Privacy Policy sets out, in clear and accessible terms, the categories of personal data we collect, the purposes for which we process it, the legal basis on which processing rests, the parties with whom we may share it, the protections we apply, and the rights available to you as a data subject. We have written this Policy in plain professional English to ensure it is genuinely understandable, not merely technically compliant.

This Policy applies to all personal data processed in connection with the Platform, whether collected through the website, our customer support channels, or any other interaction between you and pam4d. It applies to registered members, prospective members who browse the Platform without registering, and individuals who contact pam4d support without holding an account.

2 Definitions

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, either alone or in combination with other data.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, deletion, or anonymization.
• "Data Controller" means pam4d, as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third-party service provider that processes Personal Data on pam4d's behalf, strictly in accordance with pam4d's documented instructions and under a binding data-processing agreement.
• "Member" or "you" means any individual who holds a registered pam4d account or who accesses the Platform in any capacity.
• "KYC Data" means identity and address verification documents collected as part of pam4d's Know Your Customer programme, including copies of Indonesian National Identity Cards (KTP), Passports, and supporting proof-of-address documentation.
• "Cookies" means small text files placed on your device by the Platform to store session information, preferences, and analytics signals, as further described in Section 11.
• "Platform" has the same meaning as defined in the pam4d Terms & Conditions.

3 Data We Collect

The table below categorizes the Personal Data pam4d collects, with the context in which each category arises:

pam4d does not collect special-category data (such as racial or ethnic origin, religious beliefs, or health data) except where strictly necessary to process a responsible gaming intervention — and then only with your explicit consent or where processing is required to protect your vital interests.

4 How We Collect Data

4.1 Direct Collection

The majority of Personal Data pam4d holds is provided directly by you: through the account registration form, KYC document uploads, deposit and withdrawal requests, support interactions, and any voluntary preference settings you configure in your account.

4.2 Automated Technical Collection

When you visit or use the Platform, our servers and analytics tools automatically record Technical Data and Behavioral Data. This occurs through server log files, browser cookies, pixel tags, and session-recording tools. See Section 11 for full details of our cookie practices.

4.3 Third-Party Sources

In limited circumstances, pam4d may receive Personal Data about you from third parties, including:

• Identity verification providers engaged to cross-check KYC documents against authoritative data sources;
• Payment processors (including the bank and e-wallet partners listed in Section 3) who confirm transaction status and flag potential fraud signals;
• Fraud detection and anti-money-laundering screening services that provide risk scores based on publicly available or industry-shared watchlist data.

In each case, pam4d receives only the minimum data necessary and confirms that the third-party source is entitled to share that data with us.

5 Purposes of Processing

pam4d processes your Personal Data for the following specific, documented purposes:

1. Account Management: Creating, maintaining, authenticating, and closing your pam4d account; providing access to all Platform features.
2. Transaction Processing: Executing deposits and withdrawals via Indonesian banking and e-wallet channels; reconciling financial records; processing IDR-denominated transactions accurately.
3. Identity Verification (KYC): Verifying your identity and age (21+) in accordance with our responsible gaming commitment and anti-money-laundering obligations.
4. Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, bonus abuse, collusion, and other prohibited conduct as defined in the Terms & Conditions.
5. Responsible Gaming: Monitoring gaming patterns to identify indicators of problem gambling; applying member-requested limits; processing cooling-off and self-exclusion requests; fulfilling our duty of care to members in Indonesia.
6. Customer Support: Responding to your queries, complaints, and account requests; maintaining records of support interactions for quality assurance and dispute resolution.
7. Platform Improvement: Analyzing aggregated, anonymized Behavioral Data to improve the Platform's performance, user experience, game selection, and sportsbook market offerings.
8. Marketing Communications: Sending promotional offers, bonus notifications, and event-based communications (e.g., Ramadhan specials, BRI Liga 1 promotions) — exclusively to members who have provided explicit marketing consent.
9. Legal Compliance: Retaining and disclosing data where required by applicable law, court order, or regulatory authority directive.

6 Legal Basis for Processing

Each processing purpose listed in Section 5 rests on one of the following legal bases:

• Contractual Necessity: Processing required to perform the contract represented by the pam4d Terms & Conditions — including account management, transaction processing, and KYC verification.
• Legitimate Interests: Processing necessary for pam4d's legitimate interests in fraud prevention, platform security, responsible gaming oversight, and product improvement — provided those interests are not overridden by your privacy rights.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including anti-money-laundering obligations and data retention mandates.
• Consent: Processing for marketing communications and any non-essential cookies. Consent is freely given, specific, informed, and unambiguous, and may be withdrawn at any time without detriment to your account standing.

7 Data Sharing

7.1 Service Providers (Data Processors)

pam4d shares Personal Data with a defined set of third-party service providers who process data exclusively on our behalf and under binding data-processing agreements. These include:

• Payment processing partners and Indonesian banking and e-wallet integrators (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, LinkAja);
• KYC and identity verification providers;
• Fraud detection and AML screening services;
• Game content studio integrators (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) — limited to session tokens and game-result data;
• Customer support platform providers (live chat and ticketing infrastructure);
• Cloud hosting and content delivery network operators.

7.2 Legal Disclosures

pam4d may disclose Personal Data to law enforcement authorities, courts, or regulatory bodies where we are legally compelled to do so, or where disclosure is necessary to protect the rights, property, or safety of pam4d, its members, or the public. We will notify affected members of such disclosures wherever legally permitted to do so.

7.3 No Commercial Sale of Data

pam4d does not sell, rent, barter, or otherwise commercially exploit your Personal Data to any third party. Aggregated, fully anonymized analytics data that cannot be used to identify any individual may be used internally or shared with business partners, but this does not constitute disclosure of Personal Data.

8 International Data Transfers

As a platform serving members in Indonesia, the majority of pam4d's data processing takes place within the Asia-Pacific region. Some of our third-party service providers operate infrastructure in other jurisdictions. Where Personal Data is transferred outside of Indonesia, pam4d ensures that:

• The transfer is governed by a contractual arrangement incorporating internationally recognized data-protection standards;
• The recipient country or organization offers an adequate level of protection for Personal Data as assessed by pam4d's data-protection review process;
• Members are notified of any material change to the geographic scope of data transfers through an update to this Privacy Policy.

9 Data Retention

pam4d retains Personal Data in accordance with the following schedule:

At the end of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized, unless a specific legal obligation requires further retention.

10 Security Measures

pam4d employs a layered security architecture to protect your Personal Data against unauthorized access, disclosure, alteration, and destruction. Our current technical and organizational measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and pam4d servers;
• AES-256 encryption at rest for all stored Personal Data and financial records;
• Multi-factor authentication (MFA) for all pam4d administrative access;
• Role-based access controls (RBAC) ensuring that employees can access only the data necessary for their specific role;
• Intrusion detection and prevention systems (IDS/IPS) monitoring for anomalous network traffic;
• Regular penetration testing by independent third-party security firms;
• Staff data-protection training conducted at onboarding and on an annual basis;
• Incident response procedures enabling pam4d to detect, contain, and notify affected members of any confirmed data breach within seventy-two (72) hours of discovery.

11 Cookies & Tracking Technologies

11.1 What Are Cookies?

Cookies are small data files stored on your device by your browser when you visit the Platform. They allow the Platform to recognize your device across multiple pages within a session (session cookies) and across separate visits (persistent cookies). pam4d also uses pixel tags and local storage objects for equivalent purposes on certain Platform features.

11.2 Categories of Cookies We Use

• Essential Cookies: Required for the Platform to function. These include session authentication tokens, CSRF protection tokens, and load-balancing cookies. They cannot be disabled without rendering the Platform inoperable.
• Analytics Cookies: Used to collect aggregated, anonymized data on how members navigate the Platform — pages visited, time on page, bounce rate. This helps us improve the platform experience. Analytics cookies are set only with your consent.
• Functionality Cookies: Remember your preferences — such as preferred payment method, language, and responsible gaming reminder settings — to provide a more personalized experience.
• Marketing Cookies: Used only if you have consented to marketing communications. These allow pam4d to tailor promotional content — such as bonus offers relevant to Indonesian public holidays — to your demonstrated interests.

11.3 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies at any time. Please note that disabling certain functionality or analytics cookies may affect your Platform experience. Detailed instructions for managing cookies in popular browsers (Chrome, Firefox, Safari, Samsung Internet) are available through those browsers' support documentation.

12 Your Privacy Rights

As a pam4d member whose data is processed under this Privacy Policy, you hold the following rights. To exercise any of these rights, contact us using the details in Section 16:

• Right of Access: You may request a copy of all Personal Data pam4d holds about you, together with information about how it is used, stored, and shared.
• Right to Rectification: You may request that inaccurate or incomplete Personal Data be corrected. For account details you can update directly (such as contact information), we encourage you to do so through your account settings rather than by formal request.
• Right to Erasure: 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 overriding legal retention obligations — in particular, KYC and financial transaction records that must be retained under applicable law.
• Right to Restriction: You may request that pam4d restrict processing of your data while a rectification or erasure request is being assessed, or where you have objected to processing pending outcome determination.
• Right to Object: You may object to processing based on legitimate interests, including profiling for responsible gaming risk assessment. pam4d will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Data Portability: Where processing is based on your consent or contract performance and carried out by automated means, you may request a copy of your data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based solely on your consent (principally marketing communications and non-essential cookies), you may withdraw that consent at any time without penalty. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

pam4d will respond to all rights requests within thirty (30) calendar days of receipt of a verified request. Where a request is complex or we receive a high volume of requests, we may extend this period by a further thirty (30) days, with notice to you.

13 Minors

The pam4d Platform is strictly for individuals who are 21 years of age or older. We do not knowingly collect Personal Data from anyone under the age of 21. If pam4d becomes aware that a minor has provided Personal Data or registered an account, that account will be immediately closed, all associated data will be deleted, and any funds will be returned to the payment source used at deposit, subject to identity verification confirming the rightful owner.

If you are a parent or guardian and believe that a minor under your care has accessed the Platform and provided Personal Data, please contact us immediately at the details provided in Section 16.

14 Third-Party Links and Integrations

The Platform may reference or display content from game studio providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) within its interface. While pam4d integrates these studios' game content, the studios' own privacy practices apply to any direct interaction you have with their standalone client software or websites, should you access those separately outside of the pam4d Platform environment.

pam4d is not responsible for the privacy practices of any third-party website or service that is not operated by pam4d. We encourage you to read the privacy policies of any third-party services you choose to use.

15 Policy Amendments

pam4d may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or Platform functionality. Where an update materially affects your rights or how your data is used, we will provide at least fourteen (14) days' prior notice by prominently displaying the updated Policy on the Platform and, where practicable, sending a notification to your registered contact details.

The date at the top of this Policy ("Last updated") always reflects the most recent revision. Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not accept the updated Policy, you must cease using the Platform and contact support to close your account.

16 Contact Us

For all privacy-related enquiries, data-subject rights requests, or concerns regarding this Privacy Policy, please contact the pam4d Data Protection team through the following channel:

When submitting a data-subject rights request, please include your full registered name, your account username, and a description of the right you wish to exercise. We may ask you to verify your identity before processing the request, to ensure that Personal Data is not disclosed to an unauthorized party.