top4d Privacy Policy

1 Definitions

The following defined terms are used throughout this Policy:

• "Personal Data" — any information that identifies or could reasonably be used to identify a living individual, either directly (e.g., full name, national ID number) or indirectly (e.g., IP address combined with account activity).
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transfer, or deletion.
• "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, the Data Controller is top4d.
• "Data Processor" — a third party that processes Personal Data on behalf of top4d under a written data processing agreement (e.g., a KYC verification provider or payment processor).
• "Sensitive Personal Data" — a subset of Personal Data that warrants heightened protection, including but not limited to national identity numbers, financial account details, and biometric data.
• "Cookie" — a small text file stored on your device by the top4d Platform for the purposes described in the Cookies section of this Policy.

2 Data Controller

top4d is the Data Controller responsible for the Personal Data of all registered Platform users. top4d determines what data is collected, the purposes for which it is collected, and the technical and organizational measures applied to protect it.

All data-related inquiries, rights requests, and complaints may be directed to top4d via the contact details set out in Section 14 of this Policy. top4d will acknowledge all data-related requests within 3 business days and will endeavor to resolve them within 30 calendar days.

3 Data We Collect

top4d collects Personal Data through several channels during your use of the Platform. The categories of data collected, and the context in which each is obtained, are set out in the table below:

top4d does not collect data from third-party social media platforms or data brokers. All Personal Data collected by top4d is provided directly by you through your interaction with the Platform.

4 Purpose & Legal Basis for Processing

top4d processes your Personal Data only where it has a defined purpose and a lawful basis for doing so. The primary purposes and their corresponding legal bases are as follows:

• Account creation and authentication: Processing is necessary to perform the contract between you and top4d — specifically, to create and maintain your account and to verify your identity before permitting access to the Platform's services.
• Transaction processing (deposits and withdrawals): Processing is necessary to execute payment transactions via your nominated Indonesian bank or e-wallet and to maintain accurate financial records for your account.
• Identity verification (KYC): Processing is required by top4d's internal compliance policies and by the terms of its operating licenses to verify that users meet the minimum age (21+) and residency requirements.
• Fraud detection and platform security: Processing is carried out in top4d's legitimate interest to protect the integrity of the Platform, detect and prevent fraudulent or abusive activity, and safeguard the interests of all registered users.
• Responsible gaming monitoring: Processing is carried out in top4d's legitimate interest — and to meet the obligations it has assumed as a responsible gaming operator — to identify patterns of play that may indicate problem gambling and to enforce self-exclusion and deposit limit elections.
• Customer support: Processing is necessary to respond to your inquiries, resolve complaints, and provide the level of service contemplated by the top4d Terms and Conditions.
• Platform improvement and analytics: Processing is carried out in top4d's legitimate interest to understand how the Platform is used and to improve its performance, usability, and game offering for the benefit of all users.
• Direct marketing communications: Where you have opted in to receive promotional communications from top4d, we process your contact data on the basis of your consent. You may withdraw this consent at any time by contacting support or using the unsubscribe mechanism in any marketing email.

5 Data Sharing

top4d shares your Personal Data only with the categories of third parties described below, and only to the extent strictly necessary for each stated purpose:

• Payment processors and banking partners: Financial Data (bank account details, transaction amounts) is shared with Indonesian banking partners — including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, and Bank Permata — and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) for the sole purpose of processing your deposit and withdrawal transactions.
• KYC and identity verification providers: Identity Data and Sensitive Personal Data submitted during account verification may be shared with regulated KYC service providers who verify its authenticity against official records. These providers are bound by data processing agreements and are prohibited from using your data for any purpose other than verification.
• Licensed game suppliers: Technical Data (session tokens, account identifiers) is shared with top4d's licensed game providers — including Evolution Gaming, Pragmatic Play, PG Soft, NetEnt, Microgaming, and Spribe — to the extent necessary to deliver their games within the top4d lobby and to log game results accurately in your account.
• Platform infrastructure providers: Technical Data may be processed by cloud hosting and content delivery network (CDN) providers who provide the server infrastructure on which the top4d Platform operates. These providers are bound by appropriate data processing agreements.
• Legal and regulatory authorities: top4d may disclose Personal Data to Indonesian law enforcement, regulatory bodies, or financial intelligence units where required to do so by applicable law, court order, or a direction from a competent regulatory authority.

6 International Data Transfers

Some of top4d's service providers — particularly game suppliers (Evolution Gaming, Pragmatic Play, PG Soft, NetEnt, Microgaming) and certain infrastructure providers — operate servers located outside of Indonesia. Where your Personal Data is transferred to and processed in a country outside Indonesia, top4d ensures that appropriate safeguards are in place, including:

• Contractual data processing agreements incorporating standard data protection clauses;
• Transfer only to jurisdictions that maintain an adequate level of data protection under internationally recognized standards; and
• Restriction of transferred data to the minimum necessary for the relevant provider to deliver the contracted service.

You may request information about the specific safeguards applied to any international transfer of your Personal Data by contacting top4d support at the address provided in Section 14.

7 Data Retention

top4d retains your Personal Data only for as long as is necessary for the purposes described in this Policy, or for the minimum period required by applicable law or top4d's operating license obligations. The general retention framework applied by top4d is as follows:

Following the expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized. Anonymized data — which can no longer be linked to any identifiable individual — may be retained indefinitely for aggregate analytics purposes.

8 Cookies & Tracking Technologies

top4d uses cookies and similar technologies on its Platform for the purposes described below. Cookies are small text files stored on your browser or device that allow the Platform to recognize your session and preferences.

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They maintain your login session, preserve your account balance display, and enable secure navigation between sections of the Platform. These cookies cannot be disabled without breaking core Platform functionality.
• Performance and Analytics Cookies: top4d uses first-party analytics cookies to understand how players navigate the Platform — which pages are visited most frequently, where errors occur, and how game lobbies are used. This data is aggregated and anonymized and is used solely to improve Platform performance. No third-party advertising analytics cookies are deployed.
• Preference Cookies: These cookies remember your language settings, display preferences, and last-accessed sections of the Platform to deliver a more personalized experience on return visits.

You can manage cookie preferences through your browser's built-in settings at any time. Disabling strictly necessary cookies will impair the functionality of your top4d account. Disabling performance or preference cookies will not affect your ability to place bets or access your account.

9 Security Measures

top4d implements a multi-layered set of technical and organizational security measures to protect your Personal Data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the top4d Platform;
• AES-256 encryption for Personal Data stored in top4d's databases;
• Two-factor authentication (2FA) available for all registered accounts;
• Real-time anomaly detection systems that flag unusual login locations, device changes, and suspicious account activity for immediate review;
• Role-based access controls that limit internal access to Personal Data strictly to personnel whose job function requires it;
• Regular penetration testing and vulnerability assessments conducted by qualified third-party security specialists; and
• Staff training on data handling and privacy best practices for all personnel with access to player data.

While top4d maintains robust security measures, no internet-based platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to the rights and freedoms of affected Players, top4d will notify affected individuals without undue delay and will take all reasonable steps to contain and remediate the breach.

10 Protection of Minors

If you believe that top4d has inadvertently collected Personal Data from an individual under 21, please contact us immediately at [email protected]. top4d will investigate and, where confirmed, delete the relevant data promptly.

11 Your Privacy Rights

As a registered top4d user, you hold the following rights in relation to your Personal Data. These rights are subject to applicable legal limitations and verification of your identity before top4d acts on any request:

To exercise any of the rights described above, please submit a written request to top4d support via the contact details in Section 14. top4d will verify your identity before processing any rights request and will respond within 30 calendar days. Where a request is particularly complex or numerous, top4d may extend this period by a further 30 days and will notify you accordingly.

12 Complaints

If you believe that top4d has processed your Personal Data in a manner inconsistent with this Policy or in breach of applicable data protection law, you have the right to file a complaint. top4d strongly encourages you to contact us directly in the first instance so that we have the opportunity to resolve your concern promptly.

Complaints may be submitted in writing to top4d at the contact details provided in Section 14. top4d will acknowledge receipt within 3 business days and will provide a substantive response within 30 calendar days. For complex matters, top4d will provide an interim update within 15 calendar days explaining the investigation timeline.

If you remain dissatisfied following top4d's internal complaint resolution process, you retain the right to escalate your complaint to the relevant supervisory authority in the jurisdiction applicable to your circumstances.

13 Policy Amendments

top4d reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, top4d's data processing practices, or the services offered on the Platform. The revised Policy will be published on this page with an updated "Last Reviewed" date.

Where an amendment is material — meaning it changes how your Personal Data is collected, used, or shared in a way that is less protective of your privacy — top4d will notify registered Players by email or through an in-platform notification at least 14 days before the amendment takes effect.

Your continued use of the top4d Platform following the effective date of any Policy amendment constitutes your acceptance of the revised terms. If you do not agree with an amendment, you may request voluntary Account closure before the amendment takes effect without penalty.

14 Contact

All data-related requests, privacy complaints, and questions about this Policy should be directed to top4d using the following contact details:

When submitting a data access, correction, or deletion request, please provide your full registered name, the email address associated with your top4d Account, and a brief description of your request. top4d will require identity verification before actioning any request that involves disclosure or deletion of Personal Data.