Privacy Policy — brt4d

Definitions

For the purposes of this Privacy Policy, the following definitions apply:

Personal Data We Collect

brt4d collects personal data across three broad categories depending on the nature of your interaction with the Platform:

2.1 Account & Registration Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (used to verify the 21+ age requirement)
• Residential address in Indonesia (city, province, postal code)
• Email address (for account communications)
• Username and hashed password
• Mobile phone number (for two-factor authentication and WhatsApp support)

2.2 Identity Verification (KYC) Data

• National Identity Card (KTP) number and image
• Passport image (if provided as an alternative to KTP)
• Selfie photograph taken at the time of KYC verification
• Proof-of-address documents (bank statements, utility bills)
• Payment account details: bank account number and account holder name for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, or Bank Permata; or e-wallet account details for OVO, DANA, GoPay, ShopeePay, or LinkAja

2.3 Transaction & Activity Data

• Deposit and withdrawal history (amounts in IDR, timestamps, payment method used)
• Betting history (markets wagered on, stake amounts, outcomes)
• Game session data (games played, session duration, balance changes)
• Bonus redemption history and wagering progress

2.4 Technical & Device Data

• IP address and approximate geolocation (city level, derived from IP)
• Device type, operating system, and browser version
• Session timestamps and page interaction data
• Cookie identifiers (see Section 9)

2.5 Communications Data

• Content of Live Chat conversations with brt4d's support team
• Email correspondence you send to [email protected]
• WhatsApp message content sent to our support number
• Survey responses and feedback you voluntarily submit

How We Collect Your Data

brt4d collects personal data through the following mechanisms:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotion.
• Automatically: Through cookies, web beacons, server logs, and similar tracking technologies when you browse the brt4d Platform. See Section 9 for full details.
• From third-party payment processors: When you transact via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, or LinkAja, we receive transaction confirmation data (reference number, amount, account holder name) from the respective payment provider.
• From identity verification services: We may use third-party electronic KYC providers to cross-reference the identity documents you submit against authoritative data sources.
• From fraud prevention and risk management partners: We receive risk scores and flagging alerts from specialised third-party services to protect the Platform from fraudulent activity.

Legal Basis for Processing

brt4d processes personal data only where a valid legal basis exists. The primary legal bases we rely on are:

How We Use Your Personal Data

brt4d uses the personal data we collect strictly for the purposes listed below. We do not use your data in any manner that is incompatible with these stated purposes without first notifying you and, where required, obtaining your consent.

• Account Management: Creating, maintaining, and securing your brt4d account; processing login requests; applying Loyalty tier benefits.
• KYC & Compliance: Verifying your age (21+) and identity as required by our operational obligations; conducting ongoing AML and source-of-funds checks proportionate to your activity level.
• Payment Processing: Executing deposits and withdrawals via your nominated BCA/BRI/BNI/Mandiri bank account or e-wallet; detecting and preventing fraudulent transactions.
• Customer Support: Responding to Live Chat, email, and WhatsApp enquiries; maintaining a record of your support history to deliver consistent service.
• Responsible Gaming: Monitoring play patterns for signs of problem gambling behaviour; applying self-imposed limits you have activated; triggering reality-check notifications during extended sessions.
• Marketing (Consent-Based): Sending you personalised bonus offers, reload promotions, and news about brt4d where you have opted in to marketing communications. You can unsubscribe at any time.
• Platform Improvement: Analysing aggregated, anonymised usage data to identify and fix technical issues, optimise page performance, and develop new features that serve our Indonesian player base better.

Data Sharing & Disclosure

brt4d does not sell, rent, or trade your personal data. We may share data with the following categories of recipients, strictly on a need-to-know basis and under appropriate contractual safeguards:

• Payment Processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja receive the minimum data required to process your transaction.
• Identity Verification Providers: Third-party KYC platforms receive your document images and personal details solely for the purpose of identity verification; they are prohibited from retaining or using your data for any other purpose.
• Fraud Prevention & Risk Partners: Specialised firms that help us detect account takeovers, payment fraud, and bonus abuse receive anonymised or pseudonymised event data.
• IT Infrastructure Providers: Cloud hosting, database, and content delivery network providers who process data on our infrastructure under strict data processing agreements.
• Legal & Regulatory Authorities: Where required by a valid court order, subpoena, or applicable law, we may disclose data to law enforcement or regulatory bodies. We will notify you of any such disclosure where legally permitted to do so.

International Data Transfers

brt4d's servers and some of our third-party data processors may be located outside Indonesia. When personal data is transferred internationally, brt4d ensures that appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) incorporated into agreements with all third-party processors located in non-equivalent jurisdictions.
• Transfers to processors in jurisdictions that maintain an adequate level of data protection equivalent to that provided in Indonesia's data protection framework (Government Regulation No. 71 of 2019 on Electronic Systems and Transactions).
• Binding corporate rules where data is transferred within a corporate group that brt4d has a relationship with.

Data Retention

brt4d retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.

Cookies & Tracking Technologies

brt4d uses cookies and similar technologies to operate the Platform, remember your preferences, and understand how players engage with our content. The cookies we use fall into three categories:

You can manage your cookie preferences through your browser settings. Note that disabling functional or analytics cookies will not affect your ability to place bets or make transactions, but may limit certain convenience features.

Security Measures

brt4d implements a multi-layered security framework to protect personal data against unauthorised access, accidental loss, destruction, or alteration. Our measures include:

• Encryption in Transit: All data exchanged between your browser and brt4d's servers is encrypted via TLS 1.3 / 256-bit SSL.
• Encryption at Rest: Sensitive data fields, including KTP numbers, bank account details, and payment credentials, are stored in encrypted form using AES-256 encryption.
• Access Controls: Internal access to personal data is governed by role-based access control (RBAC). Only staff with a legitimate operational need can access player data, and all access is logged and audited.
• Two-Factor Authentication (2FA): Player accounts support 2FA to prevent unauthorised login even if credentials are compromised.
• Regular Security Audits: brt4d conducts periodic penetration testing and vulnerability assessments of its infrastructure.
• Data Breach Response: In the event of a confirmed data breach that is likely to result in a risk to your rights and freedoms, brt4d will notify affected players without undue delay and will take immediate steps to contain and remediate the incident.

Minors & Age Gating

brt4d does not knowingly collect personal data from individuals under the age of 21. The Platform is strictly intended for adults aged 21 and above. We employ the following age-gating measures:

• A mandatory date-of-birth declaration during account registration.
• Electronic age verification during the KYC process, cross-referencing your stated date of birth against your submitted ID document.
• Immediate account suspension where we have reasonable grounds to believe a registered player may be under 21, pending resolution of the age dispute.

Third-Party Links & Services

The brt4d Platform does not contain links to external third-party websites. However, if you access the Platform through a third-party referral link or if you use a third-party browser extension, please note that those third parties operate independently and brt4d has no control over their data practices. We recommend reviewing the privacy policies of any third-party service you use in connection with the Platform.

Our payment providers — BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja — are independent data controllers with respect to the personal data you provide to them directly within their own apps or portals. Their respective privacy policies govern the use of that data.

Amendments to This Policy

brt4d reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, operational requirements, or applicable law. When we make a material change — defined as a change that affects your rights or the way we process your personal data in a substantive manner — we will:

• Post the updated Policy on this page with a revised effective date.
• Send a notification to your registered email address at least seven (7) days before the changes take effect, where practicable.
• Display an in-platform notification upon your next login.

Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. If you disagree with any changes, please contact us to request account closure before the amendment takes effect.

Contact & Complaints

For all privacy-related enquiries, data subject rights requests, or complaints, please contact the brt4d Data Protection team using the details below. All contact information is provided as plain text — please copy and use in your own messaging application:

• Email (Privacy Enquiries): [email protected] — subject line: "Privacy Request"
• Live Chat: Available 24/7 through the brt4d Platform
• WhatsApp: +62 811-0001-4000 (08:00 – 24:00 WIB)
• Response Time: All privacy requests acknowledged within 5 business days; fully resolved within 30 calendar days

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority in Indonesia — the Ministry of Communication and Information Technology (Kementerian Komunikasi dan Informatika / Kominfo) — which oversees personal data protection matters under Government Regulation No. 71 of 2019.