Privacy Policy

1. Definitions

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

• "Personal Data" means any information that identifies or can reasonably identify a living individual, including name, national identity number, email address, device identifiers, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, alteration, or deletion.
• "Data Controller" refers to lote4d, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" refers to third parties engaged by lote4d to process data on our behalf, such as payment gateway operators and fraud-detection service providers.
• "You", "Your", "Player", "User" refers to any individual who registers an account or interacts with the lote4d platform.
• "Platform" refers to the lote4d website at https://lote4d.cam and any associated mobile interfaces.

2. Scope and Applicability

This Privacy Policy applies to all Personal Data collected by lote4d from individuals who access or use the Platform, whether as registered members, prospective registrants, or anonymous visitors. It covers data collected through the website, customer support channels, KYC verification processes, and any promotional communications sent by lote4d.

By creating an account on lote4d or continuing to use the Platform after this Policy has been updated, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your Personal Data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform and may contact us to request account closure.

3. Data We Collect

3.1 Identity and Contact Data

When you register an account with lote4d, we collect the following personal information:

• Full legal name as it appears on your government-issued identification.
• Date of birth (to verify that you are at least 21 years of age).
• Indonesian National Identity Card number (NIK) or passport number.
• Residential address, including city (e.g., Jakarta, Surabaya, Medan, Bandung, Bali) and postal code.
• Active email address.
• Mobile phone number registered with your Indonesian SIM card.

3.2 Financial and Transaction Data

To process deposits and withdrawals, lote4d collects the following financial information:

• Bank account details, including account holder name, bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata), account number, and branch code.
• E-wallet account identifiers for OVO, DANA, GoPay, and ShopeePay.
• Card details (card type, last four digits, expiry date) for Visa and Mastercard payments — full card numbers are never stored on lote4d servers.
• Complete transaction history, including deposit amounts, withdrawal amounts, bet amounts, game session data, and timestamps, all recorded in Indonesian Rupiah (IDR).

3.3 Identity Verification (KYC) Data

As part of our Know Your Customer process, we collect and retain:

• Scanned or photographed copies of government-issued photo identification (KTP, passport, or driver's license).
• Proof of residential address documents (utility bill, bank statement, or official correspondence dated within three months).
• Selfie photographs taken with your identification document for biometric verification purposes.

3.4 Technical and Usage Data

When you access the Platform, we automatically collect certain technical data, including:

• IP address and approximate geolocation data.
• Browser type, version, and operating system.
• Device type, screen resolution, and unique device identifiers.
• Pages visited, session duration, click-path data, and referring URLs.
• Login timestamps and session activity logs.

3.5 Communications Data

We retain records of all communications between you and lote4d, including live chat transcripts, support ticket exchanges, email correspondence, and any feedback or complaints submitted through official channels.

4. How We Collect Your Data

lote4d collects your Personal Data through the following methods:

• Direct submission: Information you provide during account registration, KYC verification, payment setup, or when contacting customer support.
• Automated technologies: Cookies, web beacons, server logs, and analytics tools that capture technical and usage data as you interact with the Platform.
• Third-party sources: Identity verification services, fraud-detection databases, and payment processors who share data with us to confirm your identity and the legitimacy of financial transactions.

5. How We Use Your Data

lote4d uses your Personal Data for the following purposes:

• Account management: Creating, maintaining, and securing your player account, including password reset processes and two-factor authentication.
• Service delivery: Processing deposits and withdrawals, settling bets, providing access to games (sports betting, live casino, slots, togel — Indonesia's traditional numbers lottery), and delivering customer support.
• Identity verification and compliance: Conducting KYC checks, verifying minimum age (21+), preventing fraud, detecting money laundering, and fulfilling anti-money-laundering (AML) obligations.
• Platform security: Monitoring for unauthorized access attempts, detecting suspicious betting patterns, and protecting the integrity of our games and markets.
• Personalization: Tailoring promotional offers, game recommendations, and platform content to your preferences and betting history.
• Communications: Sending transactional notifications (deposit confirmations, withdrawal approvals), service updates, and — with your consent — promotional communications about bonuses, events, and new features.
• Legal compliance: Retaining records as required by applicable international gaming regulations and responding to lawful requests from competent authorities.
• Analytics and improvement: Analyzing aggregate usage data to improve platform performance, user experience, and product offerings.

6. Legal Basis for Processing

lote4d processes your Personal Data on the following legal grounds:

• Contractual necessity: Processing required to fulfill our obligations under the user agreement you entered into upon registration — including account operation, payment processing, and service delivery.
• Legal obligation: Processing required to comply with AML regulations, age verification laws, and data retention requirements under applicable international standards.
• Legitimate interests: Processing for fraud prevention, platform security, and analytical purposes that do not override your fundamental privacy rights.
• Consent: Processing for direct marketing and non-essential cookies, where you have provided explicit, freely given, and withdrawable consent.

7. Data Sharing and Disclosure

7.1 Third-Party Service Providers

lote4d shares Personal Data with carefully vetted third-party processors who assist in delivering our services. These include payment gateway providers (for processing transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay), identity verification service providers, cloud infrastructure operators, cybersecurity firms, and customer support platform vendors. All processors are contractually bound to process data only on our documented instructions and to maintain security standards equivalent to those we apply internally.

7.2 Legal and Regulatory Disclosures

lote4d may disclose your Personal Data to law enforcement agencies, regulatory bodies, or courts if required to do so by applicable law or a valid legal order. We will, where permitted, notify you of such disclosure requests before complying. We will not disclose more data than is strictly required by the legal order or regulatory requirement.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of lote4d's assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified via email or a prominent notice on the Platform prior to such a transfer, and the acquiring entity will be bound by this Privacy Policy or an equivalent standard.

7.4 No Sale of Personal Data

lote4d does not sell, rent, or lease your Personal Data to third parties for their independent marketing or advertising purposes. Your data is used exclusively to deliver and improve our services to you.

8. Cookies and Tracking Technologies

The lote4d Platform uses cookies and similar tracking technologies to enhance your experience and collect analytical data. The types of cookies we use include:

• Strictly necessary cookies: Required for the Platform to function, including session management, authentication, and security tokens. These cannot be disabled.
• Performance and analytics cookies: Used to measure how players interact with the Platform, identify popular pages, and diagnose technical issues. Data collected is aggregated and anonymized.
• Functionality cookies: Used to remember your preferences, such as language settings and preferred payment methods, to provide a more personalized experience.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. You may opt out of marketing cookies at any time through your account settings or browser controls.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality and performance of the lote4d Platform.

9. Data Retention

lote4d retains your Personal Data for as long as your account remains active and for a defined period thereafter, as required by our legal and regulatory obligations. Specifically:

• Account and transaction data: Retained for a minimum of five (5) years after account closure, to comply with AML and financial record-keeping requirements.
• KYC verification documents: Retained for a minimum of five (5) years after the completion of the business relationship, or longer if required by applicable law.
• Customer support communications: Retained for three (3) years following the resolution of the relevant inquiry or dispute.
• Technical and usage logs: Retained for twelve (12) months and then anonymized or deleted.

Following the expiration of applicable retention periods, Personal Data is securely deleted or anonymized so that it can no longer be attributed to an identifiable individual.

10. Data Security

lote4d employs a comprehensive suite of technical and organizational security measures to protect your Personal Data against unauthorized access, loss, alteration, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• AES-256 encryption for Personal Data stored in our databases.
• Multi-layer firewall architecture and intrusion detection systems.
• Mandatory two-factor authentication for all administrative access to data systems.
• Regular penetration testing and vulnerability assessments conducted by independent third-party security specialists.
• Role-based access controls ensuring that employees can only access the data necessary to perform their specific job functions.
• Formal data breach response procedures, including notification protocols.

While we take every reasonable precaution to protect your data, no system can guarantee absolute security. In the event of a data breach that poses a significant risk to your rights, we will notify you and relevant authorities in accordance with applicable standards.

11. Your Rights as a Data Subject

As a registered player and data subject, you hold the following rights with respect to your Personal Data held by lote4d. To exercise any of these rights, contact our Data Protection team at the email address listed in Section 14:

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data. Note that changes to KYC-verified data require submission of updated supporting documentation.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal obligation to retain certain data as outlined in Section 9.
• Right to Restriction of Processing: You may request that we limit processing of your Personal Data in specific circumstances, such as while a rectification request is under review.
• Right to Data Portability: You may request a structured, machine-readable export of Personal Data you have provided to us, to facilitate transfer to another service provider.
• Right to Object: You may object to processing based on 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 on your consent (e.g., marketing emails), you may withdraw consent at any time without affecting the lawfulness of prior processing.

We will respond to all data rights requests within 30 days of receipt. In complex cases, we may extend this period by a further 60 days, with notification to you of the extension and the reason for it.

12. Children's Privacy

The lote4d Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. If you are a parent or guardian and believe that a minor has registered an account on lote4d or submitted Personal Data to us, please contact us immediately at the address in Section 14. Upon verification of the report, we will delete all data associated with the underage account and permanently close it.

13. Changes to This Privacy Policy

lote4d reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. Material changes — those that significantly affect how we collect, use, or share your Personal Data — will be communicated to you via email to your registered address and through a pro minent notice on the Platform at least 14 days before the changes take effect. Minor updates (such as corrections of typographical errors or clarifications that do not alter the substance of the Policy) may be made without prior notice, though the "Effective Date" at the top of this document will always reflect the date of the most recent revision.

14. Contact Information

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact our Data Protection team through the following channel:

• Email: [email protected]
• Live Chat: Available 24/7 directly through the lote4d Platform

We are committed to addressing all privacy-related inquiries promptly and transparently. If you are not satisfied with our response, you have the right to escalate your complaint to a relevant data protection supervisory authority.

By continuing to use the lote4d Platform after the effective date of this Privacy Policy, you acknowledge that you have read, understood, and agreed to the collection and processing of your Personal Data as described in this document. This Privacy Policy is to be read in conjunction with our Terms & Conditions and Responsible Gaming policy, which together constitute the full legal framework governing your use of lote4d.