Privacy Policy

1 Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• Personal Data: Any information relating to an identified or identifiable natural person — including name, date of birth, email address, phone number, payment details, device identifiers, and IP address.
• Processing: Any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transmission, erasure, or destruction.
• Controller: The entity that determines the purposes and means of processing Personal Data. For data collected via the ttm4d Platform, ttm4d is the Controller.
• Processor: A third party that processes Personal Data on behalf of the Controller — for example, a payment gateway provider or KYC verification service.
• Consent: A freely given, specific, informed, and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.
• Data Subject: The natural person to whom Personal Data relates — in most cases, a registered Member or site visitor.
• KYC: Know Your Customer — the identity verification process required by ttm4d prior to processing withdrawals above defined thresholds.

2 Personal Data We Collect

ttm4d collects Personal Data across several categories depending on how you interact with the Platform. The table below summarizes the primary categories of data we collect and typical examples within each category:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data for identification purposes, or health data, except where health-related information is voluntarily provided in the context of a responsible gaming self-exclusion or support request, in which case it is processed solely for the purpose of providing the requested support.

3 How Personal Data Is Collected

ttm4d collects Personal Data through the following mechanisms:

• Direct Submission: Information you provide when registering an Account, completing the KYC process, making a deposit or withdrawal request, contacting support, or adjusting your Account settings.
• Automated Technical Collection: Technical Data collected automatically by our servers and analytics infrastructure when you visit or interact with the Platform, including IP address logging, session tracking, and device fingerprinting for fraud prevention purposes.
• Payment Processors: Transaction confirmation data and payment method details provided by third-party payment gateways (bank transfer processors, e-wallet providers, and cryptocurrency exchange services) when you initiate a deposit or withdrawal.
• KYC Verification Providers: Identity verification outcomes and data quality assessments provided by accredited third-party KYC service providers where automated document verification is used.
• Cookies and Tracking Technologies: Data collected via cookies and similar tracking mechanisms as described in Clause 9 of this Policy.

4 Purposes of Processing

ttm4d processes your Personal Data for the following specific purposes. We do not use your data for any purpose that is incompatible with those listed here without first obtaining your consent or being required to do so by applicable law:

• Account Administration: Creating and maintaining your Account, authenticating your identity on login, and managing your Account settings and preferences.
• Service Delivery: Processing deposits and withdrawals, settling bets and game outcomes, crediting bonuses, and providing access to all Platform products — including sportsbook, live casino, slots, keno, and togel (Indonesia's traditional numbers lottery).
• KYC and Regulatory Compliance: Verifying your identity and age (21+ requirement), complying with anti-money laundering (AML) obligations, and responding to lawful requests from competent authorities.
• Fraud Prevention and Security: Detecting and preventing unauthorized access, multi-accounting, bonus abuse, money laundering, and other fraudulent or prohibited conduct on the Platform.
• Responsible Gaming: Monitoring account activity for signs of problem gambling, applying deposit limits and self-exclusion measures requested by Members, and fulfilling obligations under our Resp onsible Gaming policy.
• Customer Support: Responding to enquiries, resolving disputes, processing complaints, and maintaining records of support interactions for quality and training purposes.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to Members who have opted in to receive such communications. You may withdraw this consent at any time via your Account settings or by contacting support.
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve Platform performance, user experience, game selection, and payment processing efficiency.
• Legal Compliance: Meeting our obligations under applicable international law, including data protection regulations, financial crime prevention requirements, and licensing conditions.

5 Legal Basis for Processing

ttm4d processes your Personal Data on one or more of the following legal bases depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and ttm4d — including Account creation, payment processing, bet settlement, and KYC verification — is necessary for the execution and performance of our Terms & Conditions.
• Legal Obligation: Processing required to comply with applicable law — including AML reporting obligations, record-keeping requirements, and responses to lawful authority requests.
• Legitimate Interests: Processing carried out to further ttm4d's legitimate business interests, including fraud detection, platform security, responsible gaming monitoring, and product improvement — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for marketing communications and the use of non-essential cookies, where your explicit consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

ttm4d does not sell, rent, or trade your Personal Data to unrelated third parties for their own marketing purposes. We may share your Personal Data with the following categories of recipients, strictly as necessary for the purposes described in this Policy:

• Payment Service Providers: Bank transfer processors, e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja), and cryptocurrency exchange services require certain financial and identity data to process your deposit and withdrawal requests. These providers act as data processors under contract with ttm4d and are prohibited from using your data for their own independent purposes.
• KYC and Identity Verification Providers: Accredited identity verification services that process your submitted KYC documents to confirm your identity and age. Document data is shared only to the extent necessary to complete the verification.
• Game Content Providers: Third-party game studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive session-level technical data (e.g., session token, game round ID) necessary to deliver their game content. These providers do not receive your full identity or financial data.
• IT Infrastructure and Security Providers: Cloud hosting, content delivery, and cybersecurity service providers that support the operation and protection of the Platform. All such providers are bound by data processing agreements requiring them to maintain appropriate security standards.
• Fraud Prevention Services: Specialist fraud detection and AML screening providers that analyze transaction patterns and identity data to identify and prevent financial crime.
• Legal and Regulatory Authorities: Where required by applicable law, court order, or lawful request from a competent government authority, ttm4d may disclose Personal Data to law enforcement agencies, regulatory bodies, or other public authorities. We will notify you of such disclosure where permitted to do so by law.
• Professional Advisors: Legal counsel, auditors, and accountants, strictly on a need-to-know basis and subject to professional confidentiality obligations.

7 Data Retention

ttm4d retains Personal Data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following minimum retention standards:

• Active Account Data: Identity, contact, and financial data is retained for the full duration of your Account membership and for a minimum of five (5) years following Account closure, to satisfy AML record-keeping obligations.
• Transaction Records: Deposit, withdrawal, and betting transaction logs are retained for a minimum of five (5) years following the date of each transaction, in compliance with applicable financial record-keeping requirements.
• KYC Documentation: Identity and address verification documents are retained for a minimum of five (5) years following Account closure or the completion of the relevant KYC review, whichever is later.
• Support Communications: Live chat transcripts and email correspondence are retained for three (3) years from the date of the relevant interaction, unless the matter relates to an ongoing dispute or regulatory enquiry.
• Technical and Analytics Data: Log files and session data are retained for a maximum of thirteen (13) months in identifiable form, after which they are anonymized or deleted.
• Marketing Consent Records: Records of your marketing opt-in or opt-out choices are retained for the duration of your Account membership and for one (1) year following Account closure.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized. Anonymized data (from which you cannot be identified) may be retained indefinitely for statistical and research purposes.

8 Data Security

ttm4d applies a layered approach to data security, combining technical, organizational, and procedural controls to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. Key security measures include:

• Encryption in Transit: All data transmitted between your browser and the ttm4d Platform is protected by 256-bit Transport Layer Security (TLS / SSL) encryption. Our SSL certificate is maintained continuously and renewed before expiry.
• Encryption at Rest: Sensitive Personal Data — including financial details and KYC documentation — is encrypted at rest in our database infrastructure using AES-256 encryption.
• Access Controls: Access to systems holding Personal Data is restricted on a strict need-to-know basis, enforced through role-based access control (RBAC), strong password policies, and multi-factor authentication for all administrative accounts.
• Penetration Testing: The Platform undergoes regular security assessments including penetration testing and vulnerability scanning carried out by independent security specialists.
• Incident Response: ttm4d maintains a formal data breach incident response plan. In the event of a confirmed data breach that poses a risk to your rights and freedoms, we will notify affected Members without undue delay and in accordance with applicable regulatory requirements.
• Staff Training: All ttm4d personnel with access to Personal Data are trained in data protection obligations and are contractually bound by confidentiality obligations.

9 Cookies & Tracking Technologies

ttm4d uses cookies and similar tracking technologies to operate the Platform, ensure security, and where you have consented, to analyze usage and deliver relevant content. The categories of cookies we use are as follows:

You may manage your cookie preferences at any time via your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform, including logging in and processing transactions. Disabling analytics and marketing cookies will not affect your core Platform experience.

10 Your Data Rights

Subject to applicable law, you hold the following rights in relation to your Personal Data processed by ttm4d. To exercise any of these rights, contact us at the details provided in Clause 14:

• Right of Access: You may request a copy of the Personal Data ttm4d holds about you, together with information about how it is processed. We will respond within 30 days of receiving a verifiable request.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data. For basic Account details (email, phone number), corrections can be made directly in your Account settings. For identity data, corrections require 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. Note that certain data must be retained for the minimum periods set out in Clause 7 to comply with legal obligations, and erasure requests cannot override these retention requirements.
• Right to Restrict Processing: You may request that we limit the processing of your Personal Data in certain circumstances — for example, while the accuracy of data you have disputed is being verified.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, and is carried out by automated means, you may request a machine-readable copy of the Personal Data you have provided to us.
• Right to Object: You may object to processing based on legitimate interests or carried out for direct marketing purposes. Where you object to direct marketing, we will cease that processing immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

11 Minors

The ttm4d Platform is strictly for adults aged 21 and over. We do not knowingly collect or process Personal Data from individuals under the age of 21. If you are under 21, you must not register an Account or use any ttm4d Services.

If ttm4d becomes aware that Personal Data has been collected from an individual under the age of 21, that Account will be immediately suspended, all associated data will be deleted, and any deposited funds will be returned to the original payment method after identity confirmation. Parents or guardians who believe that a minor has registered an Account should contact us immediately at [email protected].

12 International Data Transfers

ttm4d operates a platform that serves Members primarily located in Indonesia. Our core infrastructure and some of our third-party service providers (including game studios, payment processors, and KYC providers) may process Personal Data in countries other than Indonesia.

Where Personal Data is transferred to a country that does not provide a level of data protection equivalent to internationally recognized standards, ttm4d ensures that appropriate safeguards are in place — including contractual clauses requiring the recipient to apply data protection standards equivalent to those described in this Policy.

By registering an Account and using the ttm4d Platform, you acknowledge that your Personal Data may be transferred to and processed in countries outside Indonesia as described in this clause, subject to the safeguards outlined above.

13 Policy Amendments

ttm4d may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or Platform services. When material changes are made, we will notify registered Members via email or via a prominent notice on the Platform at least seven (7) days before the revised Policy takes effect.

The version of this Policy currently in force is identified by the "Last Updated" date at the top of this page. We encourage you to review this Policy periodically. Your continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Policy.

Previous versions of this Privacy Policy are available on request by contacting [email protected].

14 Contact Us

If you have any questions about this Privacy Policy, wish to exercise a data right, or want to raise a concern about how your Personal Data has been handled, please contact the ttm4d data team through any of the following channels:

• Live Chat: Available 24/7 via the Platform. For data rights requests, please indicate "Data Rights Request" at the start of your message to ensure routing to the appropriate team.
• Email: [email protected] — include "Privacy Policy Enquiry" in the subject line. We aim to respond to all privacy-related emails within five (5) business days.
• WhatsApp: Available during WIB business hours for general enquiries. Complex data rights requests are best handled via email to ensure a full written record.

When submitting a data rights request, please include your registered Account username and a brief description of your request to help us locate your record and respond efficiently. Identity verification will be required before any data is disclosed or deleted.