Privacy Policy — ups4d

1 Definitions

In this Privacy Policy, the following terms carry the meanings set out below:

• "Platform" means the ups4d website at https://ups4d.cam and all associated interfaces and services.
• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, national identity number, contact details, financial account details, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• "Data Controller" means ups4d in its capacity as the entity that determines the purposes and means of Processing Personal Data.
• "Data Processor" means any third party engaged by ups4d to Process Personal Data on its behalf under a written data processing agreement.
• "Member" means any individual who has registered a verified account on the Platform.
• "Visitor" means any individual who accesses the Platform without having registered an account.
• "KYC" means Know Your Customer — the identity verification process applied to all Members prior to withdrawal processing or upon the Platform's reasonable request.
• "Cookie" means a small text file placed on a user's device by the Platform for session management, analytics, or preference storage purposes.

2 Data Controller

ups4d operates as the Data Controller in respect of all Personal Data collected through or in connection with the Platform. As Data Controller, ups4d determines the purposes for which your Personal Data is collected and the means by which it is processed.

For all privacy-related enquiries, data subject access requests, or complaints, the designated point of contact is our Data Protection team, reachable at the email address listed in Section 15 of this Policy.

3 Data We Collect

ups4d collects the following categories of Personal Data, depending on whether you are a Visitor or a registered Member:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identity document
• Date of birth (to verify you are 21 years of age or older)
• Indonesian National Identity Card number (NIK), passport number, or equivalent document number
• Nationality and country of residence
• Registered email address
• Indonesian mobile phone number
• Username and encrypted password

3.2 Financial & Transaction Data

• Bank account details for deposit and withdrawal purposes (BCA, BRI, BNI, Bank Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata)
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Transaction history including deposit amounts, withdrawal requests, wagering records, and bonus credits in Indonesian Rupiah (IDR)

3.3 KYC Verification Data

• Scanned or photographed copies of government-issued identity documents
• Proof of address documents (utility bills, bank statements dated within three months)
• Selfie photographs submitted during the verification process

3.4 Technical & Usage Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser type
• Session timestamps, pages visited, and features interacted with
• Cookie identifiers and similar tracking technologies (see Section 10)

3.5 Communications Data

• Records of live chat sessions, email correspondence, and support ticket history
• Feedback, complaints, and survey responses you voluntarily submit

4 How We Collect Data

We collect Personal Data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotional offer.
• Automatically — when you browse the Platform, through cookies, log files, and similar technologies that record technical and behavioral data about your session.
• From third parties — where permitted, from identity verification service providers engaged to assist with KYC, from payment processors to confirm transaction status, and from fraud-detection services that cross-reference data points to protect the integrity of the Platform.

5 Legal Basis for Processing

ups4d processes your Personal Data on the following legal bases:

6 How We Use Your Data

ups4d uses your Personal Data exclusively for the following purposes:

• Account Operation: Creating and managing your Member account, verifying your identity at registration and during KYC, and maintaining the security of your account throughout its lifetime.
• Transaction Processing: Facilitating deposits via Indonesian banks (BCA, BRI, BNI, Mandiri, and others) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), processing withdrawal requests, and maintaining accurate financial records.
• Regulatory Compliance: Meeting our anti-money-laundering (AML) obligations, responding to lawful requests from competent authorities, and retaining records as required by applicable law.
• Fraud Prevention & Platform Integrity: Detecting and investigating suspected fraudulent activity, multi-accounting, bonus abuse, and any other behavior that violates the Terms & Conditions.
• Customer Support: Responding to your support enquiries, resolving complaints, and maintaining records of interactions for quality and training purposes.
• Promotional Communications: Sending you information about bonuses, promotions, and platform updates where you have given consent to receive such communications. You may withdraw this consent at any time via your account settings.
• Responsible Gaming: Monitoring account activity patterns to identify signs of problem gambling and to support the effective delivery of responsible gaming tools such as deposit limits and self-exclusion.
• Platform Improvement: Analyzing aggregated, anonymized usage data to understand how Members interact with the Platform and to prioritize product improvements.

7 Data Sharing & Disclosure

ups4d does not sell your Personal Data. We share Personal Data only in the following limited circumstances:

• Payment Processors: We share financial and identity data with our authorized payment processing partners — including the operators of BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja integrations — strictly to facilitate your deposit and withdrawal transactions.
• KYC & Identity Verification Providers: We engage specialist third-party KYC service providers to assist with document verification. These providers are Data Processors acting under our instructions and are contractually prohibited from using your data for any other purpose.
• Fraud Prevention Services: We may share limited data with fraud-detection and risk-management service providers to protect the Platform and its Members.
• Legal Authorities: We will disclose Personal Data to law enforcement, regulatory bodies, or competent courts where required by law, pursuant to a valid legal order, or where we reasonably believe disclosure is necessary to prevent serious harm or illegal activity.
• Corporate Transactions: In the event of a merger, acquisition, or sale of substantially all of our assets, your Personal Data may be transferred to the acquiring entity, provided that entity agrees to honor this Privacy Policy.

8 Data Retention

We retain Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, Personal Data is either securely deleted using industry-standard data destruction methods or irreversibly anonymized so that it can no longer be associated with any identified individual.

9 Your Rights

Subject to applicable law and to verification of your identity, you hold the following rights in respect of your Personal Data held by ups4d:

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information on how it is processed.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update most profile data directly from your account settings.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and no other legal basis applies. Note that this right is subject to overriding legal retention obligations — for example, we cannot delete KYC or transaction records within a mandatory retention period.
• Right to Restrict Processing: You may request that we restrict processing of your Personal Data in certain circumstances, for example while the accuracy of data you have contested is being verified.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, you may request a structured, machine-readable copy of the Personal Data you provided to us.
• Right to Object: You may object to processing activities carried out on the basis of our legitimate interests, including direct marketing. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based solely on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, please contact our Data Protection team at support@ups4d.cam with the subject line "Data Subject Request." We will acknowledge your request within two (2) business days and respond in full within thirty (30) days. Where a request is complex or numerous, we may extend this period by an additional thirty (30) days, in which case we will notify you of the extension and the reason for it.

10 Cookies & Tracking Technologies

ups4d uses cookies and similar technologies to operate the Platform efficiently and to improve the user experience. We do not use third-party advertising cookies or retargeting pixels.

The following categories of cookies are used on the Platform:

• Strictly Necessary Cookies: Essential for the Platform to function — these include session authentication tokens, security cookies, and load-balancing identifiers. These cookies cannot be disabled without impairing core Platform functionality.
• Functional Cookies: Remember your preferences such as preferred language, display settings, and recently visited sections of the Platform. Disabling these cookies will not prevent access but may reduce convenience.
• Analytics Cookies: Collect anonymized, aggregated data about how Members interact with the Platform — for example, which pages are most visited, how long sessions last, and where users navigate from. This data is used solely for product improvement and is never shared with third-party advertising platforms.

You may manage your cookie preferences through your browser's built-in cookie controls. Instructions for the most common browsers are available through their respective help documentation. Please note that disabling strictly necessary cookies will prevent you from logging in to your Account.

11 Security Measures

ups4d implements a layered security architecture designed to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• AES-256 encryption for sensitive data at rest in our databases
• Multi-factor authentication (MFA) available to all Members for account login
• Role-based access controls ensuring that only authorized personnel can access Member Personal Data, and only to the extent necessary for their role
• Regular penetration testing and vulnerability assessments conducted by independent security specialists
• Continuous automated monitoring for anomalous access patterns and potential data breaches
• Staff training on data protection and information security practices, with mandatory annual refreshers

In the event of a Personal Data breach that poses a risk to your rights and freedoms, ups4d will notify affected Members without undue delay and will take immediate remedial action. We will document all breaches in our internal breach register regardless of whether notification is required.

12 International Data Transfers

As an internationally operating platform, ups4d may transfer your Personal Data to servers or Data Processors located in countries other than Indonesia. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy. Safeguards may include standard contractual clauses, adequacy assessments, or other legally recognized transfer mechanisms.

By registering a Member account and accepting our Terms & Conditions, you acknowledge and consent to the international transfer of your Personal Data in accordance with this Policy.

13 Minors

The Platform is strictly intended for adults aged 21 years and older. ups4d does not knowingly collect Personal Data from any individual under the age of 21. If we become aware that Personal Data belonging to a minor has been collected — for example, through a fraudulent registration — we will immediately close the account, forfeit any associated balance in accordance with our Terms & Conditions, and securely delete the minor's Personal Data.

If you are a parent or guardian and believe that a minor in your care has registered an account on the Platform, please contact our support team at support@ups4d.cam immediately so that we can take appropriate action.

14 Policy Amendments

ups4d reserves the right to update or replace this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. Material changes will be communicated to Members via email to their registered address and/or via a prominent notice on the Platform, with a minimum notice period of seven (7) days before the changes take effect.

The "Last updated" date at the top of this page indicates when the most recent revision was made. We recommend reviewing this Policy periodically. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

15 Contact & Complaints

For all privacy-related enquiries, data subject access requests, or complaints, please contact the ups4d Data Protection team through the following channels:

• Email: support@ups4d.cam — use the subject line "Privacy Enquiry" or "Data Subject Request" as appropriate. We aim to acknowledge all enquiries within two (2) business days.
• Live Chat: Available 24 hours a day, 7 days a week through the Platform. Our support agents can assist with general privacy questions and escalate formal data subject requests to the Data Protection team.
• Support Hours: 24/7, Western Indonesia Time (WIB, UTC+7). For Members located in Central Indonesia (WITA, UTC+8) or Eastern Indonesia (WIT, UTC+9), we are equally available around the clock.

If you believe that ups4d has not handled your Personal Data in accordance with this Policy, you have the right to raise a formal complaint. We will investigate all complaints diligently and respond in writing within thirty (30) days. Where a complaint cannot be resolved to your satisfaction through our internal process, you may escalate the matter to the relevant data protection authority in your jurisdiction.