Privacy Policy

Definitions

The following definitions apply throughout this Privacy Policy:

Scope & Application

This Privacy Policy applies to all Personal Data collected by atom4d in connection with the operation of the Platform. It covers data collected when you:

• Register an account or submit an account update form on the Platform;
• Make a deposit or withdrawal using supported Indonesian payment methods (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, and others);
• Place a wager on any sports market, live casino game, togel (Indonesia's traditional numbers lottery) draw, or other game offered on the Platform;
• Submit KYC verification documents;
• Contact our customer support team by email or live chat;
• Browse the Platform, whether logged in or as an unauthenticated visitor.

This Policy does not apply to third-party websites, payment processors, or game studio platforms that may be accessible via links from the Platform. atom4d encourages Members to review the privacy policies of any third-party services they interact with independently of the Platform.

Data We Collect

atom4d collects Personal Data from Members across several categories, as detailed in the table below. We collect only the data necessary for the stated purposes and do not engage in excessive or speculative data collection.

Legal Basis for Processing

atom4d processes Personal Data only where a lawful basis exists. The primary legal bases on which we rely are as follows:

• Contractual Necessity: Processing required to perform our obligations under the Member Agreement, including account management, payment processing, and game delivery;
• Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering (AML) obligations, KYC requirements, and regulatory reporting duties;
• Legitimate Interests: Processing necessary for atom4d's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights and interests as a Member;
• Consent: Processing based on your explicit consent, such as receiving promotional communications by email or SMS. You may withdraw consent at any time by updating your marketing preferences in your account settings or by contacting support.

How We Use Your Data

atom4d uses the Personal Data we collect for the following purposes:

5.1 Account Management

We use Identity Data, Contact Data, and KYC Documents to create and maintain your Member account, verify your identity, and ensure that your account profile remains accurate and up to date. This includes processing account registration, password resets, account-tier upgrades, and any changes to your registered payment methods.

5.2 Payment Processing

Financial Data is used exclusively to process deposit and withdrawal transactions via your selected Indonesian payment channels, including local bank transfers (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja). We share the minimum necessary Financial Data with our payment processing partners solely to complete authorised transactions.

5.3 Fraud Prevention & AML Compliance

atom4d uses Identity Data, Financial Data, Technical Data, and Betting & Gaming Data collectively to detect and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other conduct that violates our Terms & Conditions. Where suspicious activity is identified, we may freeze an account pending investigation and, where required by law, report the activity to relevant regulatory authorities.

5.4 Platform Improvement

Aggregated and anonymised Technical Data and Betting & Gaming Data are used to analyse Platform performance, identify technical issues, optimise the user experience across desktop and mobile devices, and inform product development decisions. Individual Members are not identifiable in the aggregated datasets used for this purpose.

5.5 Responsible Gaming Monitoring

atom4d uses Betting & Gaming Data — including session length, bet frequency, wager amounts, and deposit patterns — to monitor for indicators of problem gambling behaviour. Where such indicators are detected, we may proactively reach out to offer self-exclusion tools, deposit-limit adjustments, or referral to external support services, in line with our Responsible Gaming Policy.

5.6 Customer Support

Communications Data is used to respond to support enquiries, process complaints, and maintain records of interactions in the event of a future dispute. Support communications are retained for a minimum of two years from the date of the interaction.

5.7 Marketing Communications

Where you have opted in to receive marketing communications, we use your Contact Data and Marketing Preferences to send you information about relevant promotions, bonuses, and seasonal offers — including those tied to major Indonesian events such as Idul Fitri, Ramadhan, and Indonesian Independence Day (17 August). You may opt out of marketing communications at any time without affecting your ability to use the Platform.

Data Sharing & Disclosure

atom4d does not sell your Personal Data. We share data only in the following limited circumstances and strictly on a need-to-know basis:

6.1 Service Providers

We engage carefully selected third-party service providers who process data on our behalf, including payment processors, KYC verification platforms, cloud infrastructure providers, and customer support software vendors. All service providers are contractually bound to process data only in accordance with atom4d's instructions and applicable data protection standards.

6.2 Game Studio Partners

Certain Technical Data and session identifiers are shared with licensed game studio partners — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Pocket Games Soft, and Spribe — solely to facilitate seamless game delivery and resolve game-session disputes. These studios are prohibited from using Member data for any purpose beyond game delivery.

6.3 Regulatory & Legal Disclosure

atom4d may disclose Personal Data to regulatory authorities, law enforcement agencies, or courts where we are legally required to do so, including in connection with AML investigations, fraud inquiries, or court orders. We will notify affected Members of any such disclosure to the extent permitted by law.

6.4 Corporate Transactions

In the event of a merger, acquisition, or sale of substantially all of atom4d's assets, Personal Data may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections being maintained. Members will be notified of any such transfer in advance.

International Data Transfers

Given the international nature of atom4d's operations and the global footprint of our service providers, your Personal Data may be transferred to and processed in countries outside Indonesia. Where such transfers occur, atom4d ensures that adequate safeguards are in place to protect your data to a standard equivalent to that required under applicable Indonesian personal data protection law.

Safeguards employed for international transfers include:

• Standard contractual clauses with data processors located outside Indonesia;
• Transfer only to jurisdictions that maintain recognised adequacy standards for personal data protection;
• Technical and organisational measures, including encryption and access controls, applied equally regardless of the location of data processing.

Data Retention

atom4d retains Personal Data for the minimum period necessary to fulfil the purpose for which it was collected, subject to any longer retention periods required by applicable law. The following retention schedule applies:

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Anonymised data may be retained indefinitely for aggregated statistical analysis.

Your Privacy Rights

As a Member, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please contact atom4d's data team at the address specified in Clause 15. We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days.

9.1 Right of Access

You may request a copy of all Personal Data that atom4d holds about you, together with information about the purposes for which it is processed, the categories of data held, and the recipients with whom it has been shared.

9.2 Right to Rectification

If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request its correction. For account-profile data (name, email, address), you may also update certain fields directly within your account settings.

9.3 Right to Erasure

You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent and no other lawful basis applies, or where you object to processing and we have no overriding legitimate grounds. This right is subject to our legal retention obligations — data required to be retained under AML or financial record-keeping laws cannot be erased on request before the mandatory retention period expires.

9.4 Right to Restrict Processing

In certain circumstances, you may request that we restrict the processing of your Personal Data — for example, while a rectification request is being assessed, or where you contest the lawfulness of processing.

9.5 Right to Data Portability

Where processing is based on your consent or on contractual necessity, you have the right to receive a copy of the Personal Data you have provided to atom4d in a structured, commonly used, machine-readable format (e.g., CSV or JSON), and to transmit that data to another controller.

9.6 Right to Object

You have the right to object at any time to the processing of your Personal Data for direct marketing purposes. You also have the right to object to processing based on legitimate interests, on grounds relating to your particular situation. atom4d will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

9.7 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal. Withdrawal of consent to marketing communications will take effect within 48 hours of your request.

Cookies & Tracking Technologies

The atom4d Platform uses cookies and similar tracking technologies to operate core functions, maintain your login session, and gather anonymised usage analytics. The table below describes the categories of cookies we deploy:

atom4d does not deploy advertising or retargeting cookies that track your activity across third-party websites. Essential and security cookies are strictly necessary for Platform operation and cannot be disabled without impairing core functionality. Functional and analytics cookies may be declined by adjusting your browser settings or by contacting our support team to request a cookie opt-out.

10.1 Do Not Track

The atom4d Platform respects browser-level "Do Not Track" (DNT) signals. Where a DNT signal is detected, atom4d will limit data collection to essential operational cookies only and will not activate analytics tracking for that session.

Protection of Minors

The atom4d Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect Personal Data from individuals under the age of 21. If atom4d becomes aware that Personal Data has been submitted by a person under 21, that account will be immediately suspended, all associated data will be securely deleted without retention, and any deposits will be returned to the originating payment method.

Parents and guardians who believe that a minor has registered on the Platform are urged to contact us immediately at [email protected]. We take all reports of underage account registration extremely seriously and will act on verified reports within 24 hours of receipt.

Security Measures

atom4d implements a comprehensive set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Key security controls include:

• 256-bit SSL/TLS encryption applied to all data in transit between your device and our servers;
• AES-256 encryption for Personal Data and KYC documents stored at rest;
• Two-factor authentication (2FA) available to all Members and mandatory for internal staff access to production systems;
• Role-based access control (RBAC) ensuring that employees can access only the data necessary for their specific job functions;
• Regular penetration testing conducted by independent third-party security specialists;
• 24/7 intrusion detection and monitoring of all Platform infrastructure;
• Secure data centre facilities with physical access controls, surveillance, and environmental protection measures.

While atom4d takes every reasonable step to safeguard your Personal Data, no internet-based transmission or digital storage system can be guaranteed to be 100% secure. Members are encouraged to use strong, unique passwords and to enable 2FA on their accounts as an additional layer of personal protection.

Third-Party Services

The atom4d Platform integrates with a number of third-party services to deliver the full range of features available to Members. These include:

• Payment processors facilitating transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, Visa, and Mastercard — each governed by their own privacy policies;
• Game studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Pocket Games Soft, and Spribe — who receive session data necessary for game delivery;
• KYC verification platforms that process identity documents on atom4d's behalf under strict data processing agreements.

atom4d is not responsible for the privacy practices of third-party services. We strongly encourage Members to review the privacy policies of any third-party provider they interact with. atom4d will only engage third-party processors who can demonstrate adequate data protection standards and will enter into appropriate data processing agreements with each.

Policy Amendments

atom4d reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform functionality. Material changes to this Policy will be communicated to Members via the Platform's notification system and/or by email to the address registered on your account, with a minimum of seven days' advance notice before the amended Policy takes effect.

We recommend that all Members review this page periodically. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

If you object to any change in this Policy, you must cease using the Platform and contact our support team to arrange account closure and return of your verified Wallet Balance prior to the effective date of the change.

Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or wish to raise a privacy-related complaint, please contact atom4d's data team using the details below. All privacy enquiries are handled by a dedicated team and are treated with strict confidentiality.

15.1 Complaints to Regulatory Authorities

If you are not satisfied with atom4d's response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection authority in your jurisdiction. atom4d will cooperate fully with any regulatory investigation and will implement any remedial action required as a result.

Please note: the email address above is displayed as plain text and is not a clickable link. Copy the address manually into your email client to contact us.