Privacy Policy — pand4

The data controller responsible for the personal information processed under this Privacy Policy is pand4, the operator of the online gaming platform accessible at pand4.net.

All data protection enquiries, rights requests, and complaints should be directed to our dedicated data protection contact:

• Email: [email protected] (subject line: "Data Protection Request")
• Live Chat: Available 24/7 on pand4.net — fastest response channel for urgent privacy matters
• WhatsApp: +62 800 PAND4 (08:00–24:00 WIB)

pand4 is committed to responding to all data protection enquiries within 30 calendar days of receipt. Where a request is complex or involves a large volume of data, we will notify you within the initial 30-day period and provide an estimated completion date.

pand4 collects the following categories of personal data, depending on how you interact with the platform:

pand4 collects personal data through the following means:

• Direct Submission: Data you provide voluntarily when registering an account, completing KYC verification, making a deposit or withdrawal, contacting our support team, or responding to a promotion.
• Automated Technologies: Data collected automatically when you visit or use our platform, including via cookies, web beacons, server logs, and similar tracking technologies. See Section 8 (Cookies & Tracking) for full details.
• Third-Party Sources: Data received from identity verification and fraud-prevention service providers to cross-check information you have provided; data from payment processors such as BCA, BRI, BNI, Mandiri, OVO, DANA, and GoPay to confirm transaction status; and publicly available information where relevant to fraud or responsible gaming obligations.
• Game Providers: Aggregated gameplay and wagering data transmitted to pand4 by licensed game studios including Evolution Gaming, Pragmatic Play, Pocket Games Soft (PG Soft), Spribe, NetEnt, and Microgaming for account management, bonus calculation, and compliance purposes.

pand4 processes your personal data only where a lawful basis exists for doing so. The table below sets out our primary processing purposes and the corresponding legal basis:

pand4 does not sell, rent, or trade your personal data to third-party advertisers, data brokers, or unaffiliated marketing companies. We share personal data only in the following circumstances and strictly to the extent necessary:

• Licensed Game Providers: Gameplay and account data is shared with game studios (e.g., Evolution Gaming, Pragmatic Play, PG Soft, Spribe) to enable game functionality, calculate returns, and credit winnings. These providers operate under strict data processing agreements with pand4.
• Payment Processors: Financial data is shared with Indonesian payment partners — BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja — solely to process your deposit and withdrawal transactions. These partners are independently regulated financial institutions.
• Identity Verification & KYC Providers: Identity document data is shared with licensed third-party KYC and anti-money-laundering (AML) service providers who assist pand4 in verifying player identities and screening for sanctions or politically exposed persons (PEP) status.
• Fraud Prevention Networks: Technical data (such as IP address and device fingerprint) may be shared with fraud detection platforms to identify and prevent multi-accounting, bonus abuse, and financial crime.
• Regulatory & Law Enforcement Authorities: pand4 will disclose personal data where required by valid legal process — such as a court order, regulatory demand, or law enforcement request — from a competent authority. pand4 will notify the affected player of such a disclosure where legally permitted to do so.
• Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of all or part of pand4's business, personal data held by pand4 may be transferred to the acquiring entity. Players will be notified in advance of any such transfer and of any resulting changes to this Privacy Policy.

pand4 retains your personal data for only as long as necessary to fulfil the purposes for which it was collected, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. The following indicative retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with pand4's internal data disposal procedures. Anonymised data may be retained indefinitely for statistical and analytical purposes as it no longer constitutes personal data.

pand4 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and pand4's servers is encrypted using industry-standard TLS 1.2 or higher. Look for the padlock icon in your browser's address bar when accessing pand4.net.
• Encryption at Rest: Sensitive data fields stored in pand4's databases — including financial data and identity document references — are encrypted at rest using AES-256 encryption.
• Two-Factor Authentication (2FA): pand4 strongly encourages all players to enable 2FA on their accounts via Indonesian SMS OTP. 2FA is mandatory for all administrative and compliance personnel with access to player data.
• Role-Based Access Controls: Access to personal data within pand4's internal systems is restricted on a strict need-to-know basis. Staff access privileges are reviewed quarterly.
• Penetration Testing: pand4's platform and infrastructure are subject to regular independent security audits and penetration tests conducted by certified third-party security firms.
• Incident Response: pand4 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to affected players, pand4 will notify impacted individuals without undue delay and in accordance with applicable regulatory requirements.

pand4.net uses cookies and similar tracking technologies to deliver a functional, personalised, and secure user experience. A cookie is a small text file placed on your device by our web server when you visit the site. The following categories of cookies are used:

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair or prevent your ability to use pand4.net. Most modern browsers — including those commonly used on Indonesian Android and iOS devices — provide granular cookie management controls in their privacy or security settings.

pand4 respects and upholds the data rights of every registered player. The following rights are available to you and may be exercised by contacting us at [email protected] with the subject line "Data Rights Request":

pand4 will respond to all valid data rights requests within 30 calendar days. In exceptional cases involving complex requests, we may extend this period by a further 60 days and will notify you accordingly. pand4 does not charge a fee for processing data rights requests unless a request is manifestly unfounded or excessive in nature.

pand4 operates a strict adults-only policy. Our Services are available exclusively to individuals who are at least 21 years of age. We do not knowingly collect, process, or retain personal data from any individual under 21 years of age.

If you are a parent or guardian and believe that a minor has registered an account on pand4 using false age information, please contact us immediately at [email protected] with the subject line "Underage Account Report". We will investigate and act on all such reports as a matter of priority.

pand4 operates as an international gaming platform. As a result, certain personal data may be transferred to, stored on, or processed by systems and service providers located in jurisdictions outside Indonesia — including data centres in Singapore, the European Union, and the Isle of Man, depending on the infrastructure and licensing arrangements in place at the time of processing.

Where personal data is transferred internationally, pand4 ensures that appropriate safeguards are in place to provide a level of protection equivalent to that applicable in the originating jurisdiction. These safeguards include:

• Contractual data processing agreements that incorporate internationally recognised standard contractual clauses (SCCs) or equivalent binding data protection obligations.
• Transfer to jurisdictions that have been assessed as providing an adequate level of data protection by the applicable supervisory authority.
• Technical measures including end-to-end encryption and access controls that apply regardless of where data is physically stored.

You may request further information about the specific safeguards applicable to any particular international data transfer by contacting us at [email protected].

pand4 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or the structure of our platform. When we make material changes to this Policy, we will:

• Update the "Last Reviewed" date at the top of this page.
• Notify all registered players via the email address associated with their pand4 account at least 14 calendar days before the revised Policy takes effect, where the changes materially affect player rights or our data processing obligations.
• In cases where changes are required immediately by law or regulatory direction, we will implement the changes without advance notice and notify players as soon as reasonably practicable thereafter.

Your continued use of pand4.net following the publication of a revised Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree to the revised Policy, you should discontinue use of the platform and may request account closure in accordance with the account termination provisions in our Terms & Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how pand4 protects your personal data.

For any questions, concerns, or requests relating to this Privacy Policy or to pand4's handling of your personal data, please reach out through any of the following channels:

• Live Chat: Available 24/7 on pand4.net — recommended for time-sensitive privacy queries. Indonesian-speaking agents are available at all hours.
• Email: [email protected] — use subject line "Privacy Policy Enquiry" or "Data Rights Request" for faster routing to our data protection team.
• WhatsApp: +62 800 PAND4 (available 08:00–24:00 WIB). For players in Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, Semarang, and across Indonesia.

All privacy-related correspondence is handled in English. Indonesian-speaking support agents are available via live chat for players who prefer to communicate in Bahasa Indonesia, though formal legal and data protection correspondence must be submitted in English to ensure accurate processing.

pand4 takes every privacy enquiry seriously and is committed to providing clear, prompt, and transparent responses to all data protection matters.