This Privacy Policy ("Policy") describes how ungu4d ("we", "us", "our") collects, uses, stores, and protects personal information submitted by users ("you", "Player", "User") of the ungu4d platform accessible at https://ungu4d.cam. By accessing or using our services, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree with this Policy, please do not use the Platform.
1 Introduction
ungu4d is committed to protecting the privacy and security of your personal information. We understand that entrusting us with your data is a significant act of confidence, and we take that responsibility seriously. This Privacy Policy sets out in clear terms what information we collect, why we collect it, how we use it, who we share it with, and what rights you have regarding your personal data.
This Policy applies to all personal data processed by ungu4d in connection with the Platform, including data collected through our website, mobile applications, customer support channels, and any other digital service we operate. It applies regardless of how you access the Platform — whether via desktop browser, mobile browser, or native application.
We comply with internationally recognized data protection principles and, where applicable, the General Data Protection Regulation (GDPR) framework. Indonesian residents benefit from data protection practices that meet or exceed GDPR standards, even though Indonesia is not within the GDPR's territorial scope.
2 Data Controller
For the purposes of applicable data protection laws, ungu4d is the data controller of your personal information. This means we determine how and why your personal data is processed. All questions, requests, or complaints regarding your personal data should be directed to our Data Protection Officer via the contact details provided in Section 14 of this Policy.
3 Information We Collect
3.1 Information You Provide Directly
When you register an account on the ungu4d platform, we collect the following personal information:
- Identity Information: Full legal name, date of birth, gender, nationality, and a government-issued identity document number (Indonesian National Identity Card / KTP number).
- Contact Information: Email address, mobile phone number, and residential address (including city, province, and postal code).
- Account Credentials: Username and password (passwords are stored in encrypted form and are not accessible to ungu4d staff).
- Payment Information: Bank account details (bank name, account number, account holder name) or e-wallet identifiers (OVO, DANA, GoPay, ShopeePay account names and numbers) used for deposits and withdrawals.
- Verification Documents: Copies of identity documents, proof of address documents (utility bills, bank statements), and selfie photographs submitted as part of the Know Your Customer (KYC) verification process.
- Communication Records: Any information you provide when contacting customer support, including live chat transcripts, email correspondence, and attached files.
3.2 Information Collected Automatically
When you use the Platform, we automatically collect certain technical and behavioral information:
- Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (advertising ID, device ID).
- Connection Information: IP address, approximate geographic location (city-level based on IP), internet service provider, time zone (WIB, WITA, or WIT).
- Usage Data: Pages visited, features accessed, time spent on pages, click patterns, game sessions (games played, bet amounts, win/loss outcomes), search queries within the Platform, and referral source (how you arrived at our site).
- Cookies and Similar Technologies: We use cookies, web beacons, pixel tags, and local storage to track user preferences, authentication state, and behavioral analytics. See Section 10 for detailed information about cookies.
3.3 Information from Third Parties
We may receive information about you from third-party sources, including:
- Payment processors and banks (transaction confirmation, fraud alerts).
- Identity verification services (document authentication results, fraud risk scores).
- Sports data providers (for validating bet settlement outcomes in live sports betting and mix parlay markets).
- Marketing affiliates (if you accessed ungu4d through an affiliate link, we receive information about the referring source).
We do not collect sensitive categories of personal data such as religious beliefs, political opinions, trade union membership, or health data, except where required by law for age verification (date of birth) and identity confirmation (KTP).
4 How We Use Your Data
ungu4d processes your personal information for the following purposes:
4.1 Account Management and Service Delivery
- To create and maintain your user account.
- To authenticate your identity when you log in.
- To process deposits, withdrawals, and bonus credits.
- To enable you to place bets on sports events (including football matches in BRI Liga 1, EPL, La Liga, Champions League, and on Indonesian togel numbers games), play live casino games powered by Evolution Gaming, and access slot games from providers including Pragmatic Play.
- To apply account limits (deposit limits, loss limits, session timers) that you have set via our responsible gaming tools.
4.2 Compliance and Verification
- To verify that you are at least 21 years of age and a resident of Indonesia, as required by our Terms & Conditions.
- To conduct Know Your Customer (KYC) and anti-money laundering (AML) checks as required by applicable financial regulations.
- To detect and prevent fraud, collusion, bonus abuse, multi-accounting, and other prohibited conduct.
- To comply with legal obligations, including responding to lawful requests from government authorities and regulatory bodies.
4.3 Customer Support
- To respond to your inquiries, complaints, and support requests via email, live chat, or other communication channels.
- To troubleshoot technical issues and improve the quality of our support services.
- To provide you with updates regarding the status of your account, transactions, or verification.
4.4 Marketing and Promotions
- To send you promotional offers, bonus announcements, and newsletters about new games, features, and special events (e.g., Indonesian Independence Day promotions, Idul Fitri cashback offers, Chinese New Year bonuses).
- To personalize your experience by recommending games or betting markets based on your past activity and preferences.
- To conduct market research and analyze user engagement to improve our product offerings.
You may opt out of marketing communications at any time by clicking the "unsubscribe" link in any promotional email or by contacting customer support. Opting out of marketing does not affect transactional emails (account notifications, withdrawal confirmations, KYC updates), which we are required to send regardless of your marketing preferences.
4.5 Analytics and Platform Improvement
- To analyze usage patterns and identify opportunities to improve platform performance, especially on mobile devices commonly used across Indonesia.
- To conduct A/B testing on new features, user interface designs, and promotional campaigns.
- To monitor site security, detect unusual patterns that may indicate technical issues or security breaches, and protect the integrity of our systems.
5 Legal Basis for Processing
Under internationally recognized data protection frameworks, ungu4d relies on the following legal bases for processing your personal data:
- Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you accepted when registering your account — including identity verification, payment processing, and service delivery.
- Legal Obligation: Processing is required to comply with applicable laws and regulations, including anti-money laundering statutes, age verification requirements, tax reporting obligations, and responses to lawful government requests.
- Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, customer support, platform security, analytics, and product improvement, provided these interests do not override your fundamental rights and freedoms.
- Consent: Where processing is based on consent (e.g., marketing communications, non-essential cookies), you have the right to withdraw that consent at any time.
6 Data Sharing & Disclosure
ungu4d does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We share your data only in the following limited circumstances:
6.1 Service Providers
We engage trusted third-party service providers to perform functions on our behalf, including:
- Payment processors (to facilitate deposits via BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay).
- Identity verification services (to authenticate KTP documents and conduct fraud checks).
- Cloud hosting providers (to store data and run Platform infrastructure).
- Customer support platforms (to manage live chat and email ticketing systems).
- Game providers (Evolution Gaming, Pragmatic Play, and others — these providers process game session data but do not receive your identity or financial information).
- Sports data feeds (for real-time odds and match results for football leagues, badminton tournaments, and other sports markets).
All service providers are contractually bound to process your data only on our instructions and to implement appropriate security measures.
6.2 Legal Requirements
We may disclose your personal information if required by law or in response to valid legal requests from government authorities, law enforcement agencies, or regulatory bodies. This includes compliance with court orders, subpoenas, and regulatory investigations into money laundering, fraud, or match-fixing allegations.
6.3 Business Transfers
In the event that ungu4d is acquired by, merged with, or sells substantially all of its assets to another entity, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified via email and/or a prominent notice on the Platform of any such change in ownership and any choices you may have regarding your data.
6.4 Aggregated Data
We may share aggregated, anonymized data (data that cannot reasonably be used to identify you) with third parties for research, analytics, or business intelligence purposes. For example, we may publish statistics about deposit trends by Indonesian province, popular game categories, or average session length — none of which would identify individual users.
7 Data Retention
ungu4d retains your personal data for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.
- Active Accounts: While your account is active, we retain all account data, transaction history, and gaming records to provide ongoing service and support.
- Closed Accounts: If you close your account voluntarily, we retain your data for a minimum of seven (7) years from the date of closure to comply with financial regulations, resolve disputes, and maintain an audit trail for regulatory inquiries.
- Fraud and Compliance Records: Data related to fraud investigations, AML checks, or other compliance matters may be retained indefinitely or for the period required by law, whichever is longer.
- Marketing Data: If you opt out of marketing communications, we retain a record of your opt-out preference indefinitely to ensure we do not contact you again.
After the retention period expires, we securely delete or anonymize your data so that it can no longer be associated with you.
8 Security Measures
ungu4d employs industry-standard technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:
- Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption. Passwords are hashed using bcrypt and are never stored in plain text.
- Access Controls: Access to personal data is restricted to authorized personnel only, based on role-based access controls and the principle of least privilege. All staff members with data access are bound by confidentiality agreements.
- Infrastructure Security: Our platform is hosted on secure cloud infrastructure with firewalls, intrusion detection systems, and regular vulnerability scanning.
- Monitoring and Logging: We maintain audit logs of all access to personal data and monitor for suspicious activity.
- Regular Audits: We conduct periodic security audits and penetration testing by independent third parties to identify and remediate vulnerabilities.
Despite our best efforts, no method of electronic transmission or storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.
9 Your Privacy Rights
Under applicable data protection laws, you have the following rights regarding your personal information:
9.1 Right of Access
You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format (typically PDF or CSV). Your first access request in any 12-month period is provided free of charge; subsequent requests may incur a reasonable administrative fee.
9.2 Right to Rectification
If any personal information we hold about you is inaccurate, incomplete, or out of date, you have the right to have it corrected. You can update certain information (email address, phone number) directly through your account settings. For changes to identity information (legal name, date of birth), please contact customer support with documentary evidence.
9.3 Right to Erasure
You have the right to request deletion of your personal data in certain circumstances, including where: (a) the data is no longer necessary for the purposes for which it was collected; (b) you withdraw consent on which processing was based; (c) you object to processing and there are no overriding legitimate grounds for continued processing; or (d) the data was unlawfully processed. Note that we may be required to retain certain data to comply with legal obligations (e.g., financial records for seven years) even after an erasure request.
9.4 Right to Restriction of Processing
In certain situations, you can ask us to restrict how we use your data — for example, while we verify the accuracy of data you have contested, or while we assess whether your legitimate interests override ours following an objection to processing.
9.5 Right to Data Portability
You have the right to receive your personal data in a portable format and to transmit that data to another service provider, where technically feasible. This right applies to data you provided to us based on consent or contract, and that we process by automated means.
9.6 Right to Object
You have the right to object at any time to processing of your personal data that is based on legitimate interests. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.
9.7 Right to Withdraw Consent
Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
9.8 How to Exercise Your Rights
To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Privacy Rights Request". Please include your full name, registered email address, and a description of the right you wish to exercise. We will respond to your request within 30 calendar days. If we require additional time, we will inform you of the reason for the delay and the expected response date.
You also have the right to lodge a complaint with a data protection supervisory authority if you believe your rights have been violated. However, we encourage you to contact us first so we can address your concern directly.
10 Cookies & Tracking Technologies
10.1 What Are Cookies?
Cookies are small text files stored on your device when you visit a website. They allow the site to recognize your device and remember information about your visit, such as your login state, language preference, and browsing history.
10.2 Types of Cookies We Use
- Essential Cookies: Required for the Platform to function. These include authentication cookies (to keep you logged in), security cookies (to detect fraudulent login attempts), and load-balancing cookies (to ensure the site performs optimally). You cannot opt out of essential cookies.
- Functional Cookies: Remember your preferences, such as language selection, currency display (Rupiah), and whether you prefer to see scanline patterns on hero sections.
- Performance/Analytics Cookies: Collect information about how you use the Platform — which pages you visit, how long you stay, and which links you click. This helps us understand user behavior and improve the Platform. We use first-party analytics and do not share this data with external analytics providers.
- Marketing Cookies: Track your browsing activity to deliver personalized promotions and measure the effectiveness of our advertising campaigns (e.g., whether you registered after seeing a specific bonus offer).
10.3 Managing Cookies
Most browsers allow you to control cookies through their settings. You can block or delete cookies at any time. Note that blocking essential cookies will prevent you from using the Platform, and blocking functional or performance cookies may degrade your experience. For instructions on managing cookies in your browser, consult your browser's help documentation.
11 International Data Transfers
ungu4d primarily serves Indonesian residents, and we store data on servers located in secure, internationally recognized data centers. Some of our service providers may process data outside Indonesia. Where personal data is transferred internationally, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by data protection authorities, to protect your information in accordance with this Policy.
12 Children's Privacy
The ungu4d platform is strictly intended for adults aged 21 years or older. We do not knowingly collect personal information from individuals under 21. If we become aware that we have inadvertently collected data from an underage user, we will take immediate steps to delete that information and close the associated account. If you believe we have collected information from an underage individual, please contact us at [email protected] immediately.
13 Changes to This Privacy Policy
ungu4d reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated to you via email to your registered address and/or a prominent notice on the Platform at least 14 calendar days before the revised Policy takes effect. The "Last Updated" date at the top of this page will reflect the date of the most recent changes.
Your continued use of the Platform after the effective date of a revised Privacy Policy constitutes acceptance of the updated terms. If you do not agree to the changes, you must cease using the Platform and request closure of your account.
14 Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact our Data Protection Officer:
- Email: [email protected] (plain text — not a clickable link)
- Subject Line for Privacy Inquiries: "Privacy Policy Question" or "Privacy Rights Request"
- Response Time: We aim to respond to all privacy-related inquiries within one (1) business day for initial acknowledgment, and within 30 calendar days for substantive responses.
For general customer support inquiries (not related to privacy), please use our 24/7 live chat service accessible through the Platform interface, staffed by Indonesian-speaking agents.