pug4d Privacy Policy

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

• "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, residential address, email address, phone number, IP address, device identifiers, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Platform" means the pug4d website at pug4d.onl and all associated interfaces, mobile-optimised views, and services.
• "Account" means a registered player account on the pug4d Platform.
• "KYC" means Know Your Customer identity verification procedures applied to player accounts.
• "Cookies" means small data files placed on your device by the Platform to support functionality, analytics, and session management.
• "Third-Party Processor" means any external service provider that processes Personal Data on behalf of pug4d under a data-processing agreement.

pug4d acts as the data controller in respect of the Personal Data it collects from users of the Platform. As data controller, pug4d is responsible for determining the purposes and means of Processing your Personal Data in accordance with this Policy.

All enquiries, requests, and complaints relating to this Policy should be directed to the pug4d Data Privacy contact as set out in Clause 15 of this Policy.

pug4d collects the following categories of Personal Data in the course of providing its services:

pug4d collects Personal Data through the following channels:

4.1 Direct Collection

Data you provide directly to pug4d when: registering an Account; completing KYC verification; making a deposit or withdrawal; contacting the support team; participating in promotions; or completing responsible gaming self-assessments.

4.2 Automated Collection

Data collected automatically when you access the Platform, including Technical Data captured via server logs, Cookies, web beacons, and pixel tags. This data is collected regardless of whether you are logged into an Account.

4.3 Third-Party Sources

In certain circumstances, pug4d may receive Personal Data from third parties in order to verify your identity, screen for financial crime, or comply with legal obligations. Such third parties include: identity verification service providers; payment processors (including Indonesian bank virtual account networks and e-wallet platforms such as OVO, DANA, GoPay, ShopeePay, and LinkAja); fraud-detection and AML-screening providers; and publicly available government and regulatory databases.

pug4d processes your Personal Data on the following legal grounds:

• Contractual necessity: Processing required to fulfil our obligations to you as an Account holder — including account management, transaction processing, game provision, and customer support.
• Legal obligation: Processing required to comply with applicable anti-money-laundering (AML) regulations, KYC requirements, financial crime prevention obligations, and any other legal duties to which pug4d is subject.
• Legitimate interests: Processing necessary for pug4d's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, product improvement, and analytics — provided those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed consent — primarily for the sending of promotional and marketing communications. Consent can be withdrawn at any time without affecting the lawfulness of Processing carried out before withdrawal.

pug4d uses the Personal Data it collects for the following purposes:

• Creating and managing your pug4d Account, including password reset and account recovery.
• Verifying your identity and age (21+) through KYC procedures before processing withdrawal requests.
• Processing deposits and withdrawals via your nominated Indonesian bank account (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata), e-wallet (OVO, DANA, GoPay, ShopeePay, LinkAja), or crypto wallet (USDT, BTC, ETH).
• Delivering the pug4d gaming services, including sportsbook markets, live casino, slot games, crash games, and togel (Indonesia's traditional numbers lottery) draws.
• Detecting and preventing fraud, money laundering, account compromise, and other prohibited activities.
• Administering bonuses, promotions, and loyalty programmes in accordance with applicable offer terms.
• Providing customer support and resolving disputes relating to bets, transactions, or account operation.
• Sending you transactional notifications — including deposit confirmations, withdrawal status updates, and security alerts — that are essential to account operation.
• Sending promotional and marketing communications where you have opted in to receive them.
• Monitoring Platform usage for responsible gaming purposes, including identifying patterns that may indicate problem gambling and triggering appropriate interventions.
• Improving Platform functionality, user experience, and game offering through aggregated, anonymised analytics.
• Complying with applicable legal and regulatory obligations.

7.1 Third-Party Processors

pug4d shares Personal Data with carefully selected Third-Party Processors who provide services essential to Platform operation. These include:

• Payment processors: Indonesian bank networks, e-wallet platforms, and cryptocurrency exchange/custodial services required to process your deposits and withdrawals.
• Identity verification providers: KYC and AML screening services used to verify your identity and screen for financial crime risk.
• Game content providers: Licensed game studios and platform providers (such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Pocket Games Soft, and Spribe) whose platforms are embedded within pug4d. These providers may process limited technical data such as player session tokens to deliver game functionality.
• Infrastructure providers: Cloud hosting, content delivery network (CDN), and data-storage providers who host Platform data under strict data-processing agreements with pug4d.
• Customer support platforms: Live-chat and helpdesk software providers used to deliver pug4d's 24/7 support service.

All Third-Party Processors are contractually required to process Personal Data only in accordance with pug4d's instructions and to maintain appropriate security measures.

7.2 Legal Disclosures

pug4d may disclose Personal Data to competent authorities, regulators, or law enforcement bodies where required to do so by applicable law, court order, or regulatory direction — including in connection with AML investigations, fraud prevention, or the protection of pug4d's legal rights.

7.3 No Commercial Sale of Data

pug4d does not sell, rent, license, or otherwise commercially transfer your Personal Data to any third party for that third party's own marketing, advertising, or commercial purposes.

The pug4d Platform uses Cookies and similar tracking technologies to support its operation. The following categories of Cookies are used:

• Strictly Necessary Cookies: Essential for core Platform functionality — including maintaining your login session, remembering your game preferences, and enabling the deposit and withdrawal flow. These Cookies cannot be disabled without impairing Platform functionality.
• Performance & Analytics Cookies: Used to measure Platform usage patterns, page load performance, and user flow. Data is aggregated and anonymised. These Cookies help pug4d identify pages that need improvement and understand how players navigate the Platform.
• Functional Cookies: Used to remember your personalisation choices, such as language preference, responsible gaming settings, and display configurations.
• Security Cookies: Used to support fraud detection and to ensure that the player interacting with an Account session is the legitimate Account holder.

pug4d retains Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following indicative retention periods apply:

• Account and identity data: Retained for the duration of the Account relationship and for a minimum of 5 years following Account closure, in accordance with AML record-keeping requirements.
• Transaction data (deposits, withdrawals, bet history): Retained for a minimum of 5 years following the date of the transaction, in accordance with financial record-keeping obligations.
• KYC documentation: Retained for the duration of the Account relationship and for a minimum of 5 years following Account closure.
• Customer support communications: Retained for 2 years following the close of the relevant support interaction, unless retention is required for an active dispute.
• Technical and log data: Retained for up to 12 months, unless extended retention is required for fraud investigation or legal proceedings.
• Marketing consent records: Retained for the duration of the marketing relationship and for 2 years following withdrawal of consent.

Following the expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with pug4d's data-destruction procedures.

pug4d implements a layered set of technical and organisational security measures to protect Personal Data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport security: All data transmitted between your device and pug4d servers is encrypted using TLS 1.2 or higher (HTTPS). Unencrypted HTTP connections are not accepted.
• Data-at-rest encryption: Sensitive data stored on pug4d servers — including KYC documents and financial account details — is encrypted using AES-256 encryption.
• Access controls: Access to Personal Data is restricted on a need-to-know basis. Staff with access to Personal Data are subject to confidentiality obligations and receive data-security training.
• Fraud and intrusion detection: Real-time monitoring systems detect and alert on anomalous login patterns, unusual transaction activity, and potential account compromise.
• Two-factor authentication: Account holders are encouraged to enable two-factor authentication (2FA) for an additional layer of login security. pug4d may require 2FA for high-value withdrawals.
• Regular security review: pug4d's security architecture is subject to periodic review and, where applicable, third-party penetration testing.

Subject to applicable law, you have the following rights in relation to your Personal Data held by pug4d:

• Right of Access: You may request a copy of the Personal Data pug4d holds about you, together with information about how that data is processed.
• Right of Rectification: You may request correction of inaccurate or incomplete Personal Data. Where possible, you can update your Account details directly through your profile settings.
• 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, where you withdraw consent, or where Processing is unlawful. This right is subject to legal retention requirements — pug4d may retain data it is legally obligated to keep.
• Right to Restriction: You may request that pug4d restrict the Processing of your Personal Data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: Where Processing is based on consent or contractual necessity and is carried out by automated means, you may request a copy of your data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to Processing based on pug4d's legitimate interests, including profiling for responsible gaming purposes. You may also object to direct marketing at any time, and pug4d will cease marketing Processing immediately upon receiving that objection.
• 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 withdrawal.

To exercise any of these rights, contact pug4d via live chat or email as specified in Clause 15. pug4d will respond to verified requests within 30 calendar days. Identity verification may be required before requests are processed.

The pug4d Platform is strictly for persons aged 21 and over. pug4d does not knowingly collect or process Personal Data of persons under the age of 21. If pug4d becomes aware that an Account has been registered by a person under 21, the Account will be closed immediately, all funds will be returned to the payment source, and any winnings generated will be forfeited.

If you are a parent or guardian and believe that a minor in your care has registered an Account on pug4d, please contact us immediately via the details in Clause 15. We will investigate and take action promptly.

The pug4d Platform may contain embedded content from or links to third-party websites and services — for example, game content delivered via licensed studio platforms. pug4d is not responsible for the privacy practices of those third parties, and this Policy does not apply to data collected by third-party websites or services that you access through or in connection with the Platform. We recommend that you review the privacy policies of any third-party services you interact with.

pug4d may update this Privacy Policy from time to time to reflect changes in Platform operations, applicable law, or best-practice data-protection standards. Where changes are material, pug4d will provide advance notice by posting the updated Policy on the Platform and, where practicable, notifying registered Account holders by email at least 14 days before the amended Policy takes effect.

The "Effective Date" at the top of this Policy indicates when the current version came into force. Your continued use of the Platform after a revised Policy takes effect constitutes your acceptance of the updated Policy. If you do not accept material changes to this Policy, you must close your Account before the amendments take effect.

For questions, requests, or complaints relating to this Privacy Policy or pug4d's processing of your Personal Data, please contact us through the following channels:

• Live Chat: Available 24/7 within the pug4d Platform after login. Please select the "Privacy / Data Request" topic category when initiating the chat. Average first response time is under two minutes.
• Email: [email protected] (plain text — not a clickable link). Please include "Privacy Request" in the subject line. Responses are provided within 24 hours for general enquiries and within 30 calendar days for formal data subject requests.

When submitting a data subject request, please provide your Account username, a clear description of your request, and any relevant transaction references or dates. Identity verification will be required before requests affecting Account data are processed.