Privacy Policy — hut4d Platform

In this Privacy Policy, the following terms have the meanings set out below unless context requires otherwise:

2.1 Registration Data. When you create a hut4d account, we collect the following information: full legal name, date of birth, Indonesian residential address, active mobile phone number, and a valid email address. This data is required to establish your account and confirm your eligibility to use the Platform.

2.2 Identity Verification (KYC) Data. To comply with our anti-money-laundering obligations and to confirm that you are at least 21 years of age and a resident of Indonesia, we collect copies of government-issued identity documents. Accepted documents include your Indonesian National Identity Card (KTP), passport, or driver's licence (SIM). We may also request a selfie photograph for liveness verification and proof of ownership of your nominated payment method.

2.3 Financial Data. We collect details of your deposits and withdrawal requests, including the payment method used (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, or LinkAja), transaction reference numbers, and IDR amounts. We do not store full bank account numbers or e-wallet PINs on our servers; payment credentials are handled directly by our regulated payment processing partners.

2.4 Transactional and Gaming Data. We record all Wagers, game sessions, bet amounts, game outcomes, balance movements, and bonus credit activity associated with your Account. This data is used for account management, dispute resolution, and responsible gaming monitoring.

2.5 Technical and Device Data. When you access the Platform, we automatically collect certain technical information: IP address, browser type and version, operating system, device type and model, session timestamps, pages visited, clickstream data, and referral URL. This data is used for security monitoring, fraud prevention, and platform performance optimisation.

2.6 Communications Data. If you contact our support team via live chat or email, we retain a record of those communications, including the content of messages, timestamps, and any attachments you provide, for quality assurance and dispute-resolution purposes.

hut4d processes your Personal Data for the following purposes:

hut4d processes your Personal Data on the following legal grounds:

• Contractual necessity: The majority of our processing — account creation, payment processing, game delivery, KYC — is necessary to perform the contract between hut4d and you as a Member. Without this processing, we cannot operate your Account.
• Legal obligation: Certain processing activities are required by applicable anti-money-laundering regulations, financial record-keeping obligations, and lawful orders from regulatory or law enforcement authorities.
• Legitimate interests: We process technical and device data for fraud prevention and platform security on the basis of our legitimate interest in maintaining a safe and fair gaming environment for all Members.
• Consent: Where processing is not required for contractual or legal reasons — in particular, direct marketing communications — we rely on your freely given, informed, and specific consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5.1 Payment Processors. To process deposits and withdrawals in IDR, hut4d shares necessary transaction data with regulated payment processing partners covering bank transfer channels (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja). These partners process data only as required to complete each transaction and are bound by strict confidentiality agreements.

5.2 KYC Verification Partners. Identity documents and liveness-check data submitted for KYC purposes are processed by accredited third-party identity verification providers. These providers operate under data processing agreements that prohibit secondary use of your documents for any purpose other than identity verification on our behalf.

5.3 Game Studio Providers. Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive anonymised session data necessary to deliver game content and calculate outcomes. No directly identifying personal information is shared with game studios beyond what is technically required for game-round settlement.

5.4 Regulatory and Law Enforcement Authorities. hut4d will disclose Personal Data to competent regulatory or law enforcement authorities where required by law, court order, or formal regulatory request. We will, where legally permissible, inform you of such a disclosure.

5.5 No Sale of Data. hut4d does not sell, rent, or trade your Personal Data to third-party marketers, data brokers, or advertising networks under any circumstances.

6.1 What Are Cookies. Cookies are small text files placed on your device by the Platform when you visit. They allow the Platform to recognise your browser across sessions, maintain your login state, and store your preferences.

6.2 Types of Cookies We Use.

6.3 Managing Cookies. You may configure your browser to block or delete cookies at any time. Note that disabling strictly necessary cookies will prevent you from logging into your Account. Analytics and functional cookies can be disabled without affecting core Platform functionality.

7.1 Active Accounts. Personal Data associated with an active Member Account is retained for the duration of the account relationship. We regularly review account data to ensure that only information that remains necessary for our stated purposes is retained.

7.2 Closed Accounts. Following voluntary account closure or termination by hut4d, we are required by our anti-money-laundering obligations to retain certain account records — including KYC documents, transaction histories, and game logs — for a minimum of five years from the date of account closure.

7.3 Communications Records. Support chat transcripts and email correspondence are retained for a period of three years from the date of the interaction, after which they are securely deleted.

7.4 Marketing Data. If you withdraw consent to marketing communications, your email address and contact preferences are removed from our active marketing lists within 14 calendar days. A suppression record may be retained to ensure you are not inadvertently re-added to marketing lists.

7.5 Deletion Requests. Where you submit a valid erasure request under Clause 8, hut4d will delete all Personal Data that is not subject to a legal retention obligation within 30 calendar days of identity-verified receipt of your request.

As a Member of hut4d, you hold the following rights with respect to your Personal Data. To exercise any of these rights, contact our support team via live chat or at [email protected]. We will respond to all verified requests within 30 calendar days.

• Right of Access: You may request a copy of all Personal Data we hold about you, including a summary of the purposes for which it is processed and the categories of Third Parties to whom it has been disclosed.
• Right to Rectification: If any Personal Data we hold is inaccurate or incomplete, you have the right to request correction. You may update basic account information (address, phone number) directly through your Account profile at any time.
• Right to Erasure: Subject to legal retention obligations (see Clause 7.2), you may request deletion of your Personal Data. We will confirm which data can be deleted and which must be retained, together with the legal basis for retention.
• Right to Restriction: Where you contest the accuracy of data we hold, or where processing is unlawful but you prefer restriction over deletion, you may request that we restrict processing while the matter is resolved.
• Right to Data Portability: You may request a machine-readable export of the Personal Data you have provided to hut4d (registration data and transaction history) in CSV or JSON format.
• Right to Object: You may object to processing based on our legitimate interests, including profiling for responsible gaming monitoring, where you have compelling grounds relating to your particular situation. You may also object unconditionally to direct marketing processing at any time.
• Right to Withdraw Consent: Where processing is based on consent (primarily marketing), you may withdraw that consent at any time without penalty, by adjusting your Account notification settings or contacting our support team.

9.1 Technical Safeguards. hut4d implements industry-standard technical security measures to protect your Personal Data against unauthorised access, loss, destruction, or alteration. These measures include:

• Transport Layer Security (TLS 1.3): All data transmitted between your browser and our servers is encrypted using current TLS standards.
• Data Encryption at Rest: Sensitive Personal Data, including KYC document scans and payment method details, is encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data within hut4d's operational systems is strictly limited to authorised personnel on a need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Intrusion Detection: Our infrastructure is monitored 24/7 by automated intrusion detection systems that flag anomalous access patterns for immediate investigation.
• Regular Security Audits: hut4d engages independent security specialists to conduct penetration testing and vulnerability assessments on a regular schedule.

9.2 Your Responsibilities. You are responsible for keeping your hut4d Account credentials — username, password, and any two-factor authentication codes — confidential. Never share your login details with any third party. hut4d staff will never ask for your password through any communication channel.

9.3 Data Breach Notification. In the event of a data breach that poses a material risk to your rights and freedoms as a data subject, hut4d will notify affected Members without undue delay via their registered email address, and will take all reasonable steps to contain and remediate the breach.

hut4d operates a strict 21+ policy. The Platform is not directed at, and does not knowingly collect Personal Data from, individuals under the age of 21. Registration requires a declaration of age and is subject to KYC verification that confirms date of birth against government-issued identity documents.

If hut4d discovers that Personal Data has been collected from an individual who is under 21 years of age, we will immediately suspend the associated Account, void any open Wagers, and permanently delete all Personal Data associated with that Account without retaining it beyond any minimum statutory obligation.

If you are a parent or guardian and have reason to believe that a minor has gained access to a hut4d Account, please contact our support team immediately via live chat or at [email protected]. We treat all reports of this nature as urgent priority matters.

11.1 Cross-Border Processing. Some of hut4d's third-party service providers — including KYC verification partners and game studio providers — operate infrastructure located outside Indonesia. Where your Personal Data is transferred to and processed in a jurisdiction other than Indonesia, hut4d ensures that appropriate safeguards are in place to protect the data to a standard equivalent to that applicable in Indonesia.

11.2 Transfer Safeguards. Safeguards applied to international transfers include contractual data processing agreements incorporating standard data protection clauses, binding corporate rules where applicable, and transfer only to jurisdictions assessed as providing an adequate level of data protection.

11.3 No Transfers to Sanctioned Jurisdictions. hut4d does not transfer Personal Data to jurisdictions subject to international sanctions or to Third Parties operating in environments that do not provide adequate data protection guarantees.

12.1 Right to Update. hut4d reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. The effective date at the top of this page will be updated whenever material changes are made.

12.2 Notification of Changes. Where changes are material — for example, if we introduce a new category of data collection or a new purpose for processing — we will notify active Members via their registered email address or through a prominent in-platform notification, giving a minimum of 14 days' notice before the changes take effect.

12.3 Continued Use. Your continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not accept the revised terms, you should stop using the Platform and request Account closure in accordance with our Terms & Conditions.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the hut4d team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week — including all Indonesian public holidays — directly within your Member Account dashboard. Average response time: under 60 seconds.
• Email: [email protected] (plain text — not a clickable link). Email responses are typically issued within 4 business hours (WIB, UTC+7).
• Subject Line for Data Requests: Please use the subject line "Data Rights Request — [Your Registered Username]" so that our team can route your request to the appropriate handler without delay.
• Operating Timezone: Western Indonesia Time (WIB, UTC+7) — Jakarta. Members in WITA (UTC+8) and WIT (UTC+9) regions are equally served; all response-time commitments reference WIB as the standard.