kode4 Privacy Policy

1. Introduction and Scope

This Privacy Policy (the "Policy") describes how kode4 ("we", "us", "our", or the "Company") collects, uses, stores, protects, and discloses personal information from users ("you", "your", or "User") of the kode4 website located at https://kode4.cam and all related services (collectively, the "Platform" or "Service").

At kode4, we are deeply committed to protecting your privacy and safeguarding your personal data. We recognize that when you entrust us with your personal information — including your name, contact details, identification documents, financial data, and gaming activity — you expect that information to be handled with the utmost care, transparency, and respect for applicable data protection laws.

This Policy applies to all personal data collected through the kode4 Platform, including data provided during account registration, identity verification (KYC), deposits and withdrawals, customer support interactions, promotional communications, and gameplay. By creating an account or using any part of the Service, you acknowledge that you have read, understood, and consent to the data practices described in this Policy.

2. Information We Collect

kode4 collects several categories of personal information necessary to provide the Service, comply with legal obligations, prevent fraud, and improve user experience. The types of data we collect include:

2.1 Account Registration Data

When you create a kode4 account, we collect the following information:

• Personal Identifiers: Full legal name (as it appears on your Indonesian National Identity Card / KTP), date of birth, gender, and nationality.
• Contact Information: Email address, mobile phone number with Indonesian country code (+62), and residential address including city, province, and postal code.
• Account Credentials: Unique username and encrypted password (stored using industry-standard cryptographic hashing).
• Device Information: Device type, operating system, browser type and version, IP address, and device identifiers for security and fraud prevention.

2.2 Identity Verification (KYC) Data

To comply with international Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations, we are required to verify the identity of all account holders before processing withdrawals. This includes:

• Government-Issued Identification: Clear photograph or scan of your Indonesian National Identity Card (KTP) showing your photo, full name, NIK (National Identification Number), date of birth, address, and signature.
• Biometric Verification: Selfie photograph of you holding your KTP next to your face for identity confirmation and liveness detection.
• Proof of Address (Optional): Recent utility bill, bank statement, or government-issued document dated within the last 3 months, if requested for additional verification.
• Source of Funds Documentation: For large transactions exceeding Rp 50,000,000, we may request documentation verifying the source of deposited funds (employment letter, business registration, bank statements) to comply with AML regulations.

All KYC documents are encrypted, stored securely on our servers, and accessed only by authorized personnel for verification purposes.

2.3 Financial and Transaction Data

To process deposits, withdrawals, and maintain accurate account balances, we collect:

• Payment Information: Indonesian bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata account numbers and names) and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja registered phone numbers or account IDs).
• Transaction History: Complete records of all deposits, withdrawals, bonuses credited, bets placed, winnings paid out, and account balance adjustments, including timestamps in WIB (Waktu Indonesia Barat / Western Indonesia Time).
• Payment Method Metadata: Transaction reference numbers, payment confirmation receipts, and processing timestamps from third-party payment processors.

kode4 does not store full credit card numbers or CVV codes. All card transactions (if offered) are processed through PCI DSS-compliant third-party payment gateways that maintain their own security standards.

2.4 Gaming Activity and Behavioral Data

To personalize your experience, detect fraud, and fulfill responsible gaming obligations, we track:

• Betting and Gaming History: All bets placed (sports betting, casino games, slots, live dealer, togel, sabung ayam), stakes, odds, outcomes, winnings/losses, game sessions, and playtime duration.
• Login Activity: Login times, IP addresses, geographic locations, device information, and session durations to detect unauthorized account access and fraudulent activity.
• Responsible Gaming Data: Deposit limits, loss limits, session time limits, self-exclusion requests, and reality check preferences to help you maintain control over your gambling activity.
• Promotional Engagement: Bonuses claimed, wagering progress, promotional email opens and clicks, and responses to marketing campaigns.

2.5 Customer Support Communications

When you contact our customer support team via live chat, WhatsApp, or email, we collect:

• Full content of your support inquiries, complaints, feedback, and our responses.
• Attachments you provide (screenshots, documents) to assist with issue resolution.
• Support ticket metadata including timestamps, resolution status, and assigned support agent.

These records help us improve service quality and resolve disputes.

3. How We Use Your Personal Data

kode4 uses the personal information we collect for the following lawful purposes:

3.1 Service Provision and Account Management

• Creating and maintaining your user account with secure authentication.
• Processing deposits and withdrawals to and from your Indonesian bank accounts and e-wallets.
• Enabling you to place bets, play games, and participate in sports betting markets including football (bandar bola), live casino, slots, and traditional Indonesian games.
• Calculating winnings, settling bets, and updating your account balance in real-time.
• Administering bonuses, promotions, cashback rewards, and VIP loyalty program benefits.

3.2 Legal Compliance and Fraud Prevention

• Verifying your identity, age (21+ requirement), and residency in Indonesia to comply with gambling regulations and prevent underage gambling.
• Conducting AML (Anti-Money Laundering) and CTF (Counter-Terrorism Financing) checks to detect and prevent financial crimes.
• Monitoring betting patterns, account activity, and IP addresses to detect fraud, collusion, multi-accounting, bonus abuse, and other prohibited activities.
• Fulfilling legal obligations to report suspicious activity to relevant authorities when required by law.
• Maintaining records as required by our gaming licenses and international regulatory standards.

3.3 Customer Support and Communication

• Responding to your inquiries, complaints, and support requests via live chat, WhatsApp, email, and other communication channels.
• Sending you important account notifications including deposit confirmations, withdrawal processing updates, KYC verification status, and security alerts.
• Providing 24/7 Indonesian-speaking customer support tailored to Indonesian players' banking, gaming, and cultural preferences.

3.4 Marketing and Promotional Communications (With Your Consent)

• Sending you personalized promotional offers, bonus announcements, tournament invitations, and special event notifications (Indonesian Independence Day on August 17, Idul Fitri, Chinese New Year / Imlek, Ramadan promotions) via email, SMS, or push notifications.
• Tailoring marketing content based on your gaming preferences, betting history, and VIP tier status.
• Conducting surveys and requesting feedback to improve our services.

You may opt out of marketing communications at any time by clicking "unsubscribe" links in emails or adjusting your account preferences. Opting out does not affect essential service communications (transaction confirmations, security alerts, legal notices).

3.5 Platform Improvement and Analytics

• Analyzing user behavior, game popularity, betting trends, and platform performance to enhance user experience and optimize game offerings.
• Conducting A/B testing to improve website design, navigation, and feature functionality.
• Troubleshooting technical issues, identifying bugs, and improving system stability and security.
• Developing new features, games, and services tailored to Indonesian player preferences (BRI Liga 1 betting, EPL coverage, badminton odds, Mobile Legends esports betting).

3.6 Responsible Gaming and Player Protection

• Implementing and enforcing responsible gaming tools including deposit limits, loss limits, session timers, and self-exclusion programs.
• Monitoring player behavior for signs of problem gambling and proactively intervening with support resources when necessary.
• Enforcing strict 21+ age verification to prevent underage access to gambling services.

4. Data Sharing and Disclosure

kode4 does not sell your personal information to third parties for marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality agreements and only to the extent necessary:

4.1 Service Providers and Business Partners

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals.
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, and other licensed game studios to deliver casino games, live dealer tables, slots, and sports betting data feeds.
• Identity Verification Services: Third-party KYC/AML verification providers to authenticate identity documents and perform fraud checks.
• Cloud Hosting and IT Infrastructure: Secure data centers and cloud service providers that host our servers and databases under strict data protection agreements.
• Customer Support Tools: Live chat platforms, WhatsApp Business API, and email systems used to communicate with you.

All service providers are contractually obligated to protect your data, use it only for the specified purposes, and comply with applicable data protection laws.

4.2 Legal and Regulatory Authorities

We may disclose your personal information to government authorities, law enforcement, regulators, or courts when:

• Required by law, court order, subpoena, or legal process.
• Necessary to comply with gaming license obligations or regulatory reporting requirements.
• Needed to detect, prevent, or prosecute fraud, money laundering, or other criminal activity.
• Necessary to protect the rights, property, or safety of kode4, our users, or the public.

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email and prominent notice on the Platform before your data is transferred and becomes subject to a different privacy policy.

4.4 With Your Explicit Consent

We may share your data with other third parties if you provide explicit consent for specific purposes not covered by this Policy.

5. Data Security Measures

kode4 implements industry-leading technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Technical Security Controls

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using SSL 256-bit encryption — the same standard used by Indonesian banks for online banking.
• Data Encryption at Rest: Sensitive personal information and financial data stored on our servers are encrypted using AES-256 encryption algorithms.
• Secure Password Storage: User passwords are hashed using bcrypt or Argon2 cryptographic hashing algorithms with unique salts. kode4 cannot retrieve your original password — we can only allow you to reset it.
• Two-Factor Authentication (2FA): We strongly encourage enabling 2FA on your account for an additional layer of login security using time-based one-time passwords (TOTP).
• Firewalls and Intrusion Detection: Our servers are protected by enterprise-grade firewalls, intrusion detection systems (IDS), and distributed denial-of-service (DDoS) mitigation to prevent cyberattacks.
• Regular Security Audits: We conduct regular penetration testing, vulnerability assessments, and third-party security audits to identify and remediate potential security weaknesses.

5.2 Administrative Security Measures

• Access Controls: Personal data is accessible only to authorized kode4 employees and contractors who require access to perform their job functions (customer support, KYC verification, fraud investigation). All personnel sign confidentiality agreements.
• Employee Training: All staff members receive regular training on data protection, privacy regulations, and security best practices.
• Incident Response Plan: We maintain a comprehensive data breach response plan to quickly detect, contain, and remediate security incidents while notifying affected users as required by law.

5.3 Your Security Responsibilities

While we implement robust security measures, you also play a critical role in protecting your account:

• Use a strong, unique password that is not shared with other websites or services.
• Enable two-factor authentication (2FA) for enhanced login protection.
• Never share your username, password, or 2FA codes with anyone, including individuals claiming to be kode4 staff (we will never ask for your password).
• Log out of your account when using shared or public devices.
• Keep your registered email address and phone number secure and up to date.
• Report any suspicious account activity or unauthorized access to our support team immediately.

6. Cookies and Tracking Technologies

kode4 uses cookies and similar tracking technologies to enhance your experience on our Platform, remember your preferences, and analyze usage patterns. A cookie is a small text file stored on your device by your web browser.

6.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for basic Platform functionality including login authentication, session management, and secure access to your account. These cannot be disabled.	Session / 30 days
Functional Cookies	Remember your preferences such as language selection (English for Indonesian market), preferred odds format, timezone (WIB), and VIP settings.	1 year
Analytics Cookies	Collect aggregated, anonymized data about how users interact with the Platform (page views, navigation paths, popular games) to improve user experience.	2 years
Marketing Cookies	Track your responses to promotional campaigns and personalize marketing content based on your interests. You can opt out via cookie settings.	1 year

6.2 Managing Cookie Preferences

You can control and delete cookies through your web browser settings. Most browsers allow you to:

• View which cookies are stored and delete them individually or all at once.
• Block third-party cookies while allowing first-party cookies from kode4.
• Receive notifications before cookies are stored, allowing you to accept or reject them.
• Enable "Do Not Track" mode (though not all websites honor this setting).

Please note that disabling essential cookies will prevent you from logging into your account and using core features of the Service. Disabling analytics and marketing cookies will not affect Platform functionality.

7. Your Privacy Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request a copy of all personal data we hold about you. We will provide this information in a structured, commonly used, machine-readable format (typically PDF or CSV) within 30 days of your request.

7.2 Right to Rectification

If any of your personal information is inaccurate or incomplete, you have the right to request correction. You can update most information directly through your account settings, or contact our support team for assistance with changes to verified data (name, date of birth from KYC documents).

7.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data under certain circumstances:

• The data is no longer necessary for the purposes for which it was collected.
• You withdraw consent on which processing was based (for marketing communications).
• You object to processing and there are no overriding legitimate grounds for continued processing.

However, we may be required to retain certain data to comply with legal obligations (AML/KYC records must be kept for 5-7 years after account closure), resolve disputes, or enforce our Terms & Conditions.

7.4 Right to Restrict Processing

You can request that we limit how we use your data while we verify its accuracy or assess whether we have legitimate grounds to continue processing it.

7.5 Right to Data Portability

You have the right to receive your personal data in a portable format and transmit it to another service provider, where technically feasible.

7.6 Right to Object

You may object at any time to processing of your personal data for direct marketing purposes. Once you opt out, we will no longer send you promotional communications, though essential service emails (transaction confirmations, security alerts) will continue.

7.7 Right to Withdraw Consent

Where we process your data based on consent (marketing, cookies), you have the right to withdraw that consent at any time without affecting the lawfulness of processing conducted before withdrawal.

7.8 How to Exercise Your Rights

To exercise any of these privacy rights, please contact our Data Protection team:

• Email: [email protected] with subject line "Data Privacy Request"
• Include your full name, registered email address, and account username for identity verification
• Clearly state which right you wish to exercise and provide any relevant details

We will respond to your request within 30 days. In some cases, we may ask for additional information to verify your identity before fulfilling the request, to prevent unauthorized disclosure of personal data.

8. Data Retention Periods

kode4 retains your personal information only for as long as necessary to fulfill the purposes described in this Policy and to comply with legal obligations:

• Account Data: Retained for the duration of your active account plus 7 years after account closure, as required by AML/KYC regulations and our gaming licenses.
• KYC Documents: Identification documents (KTP, selfies, proof of address) are retained for 7 years after account closure to comply with international financial regulations.
• Transaction Records: All financial transactions (deposits, withdrawals, bets, winnings) are retained for 7 years for accounting, auditing, and dispute resolution purposes.
• Gaming History: Betting history, game sessions, and outcomes are retained for 5 years for operational purposes, fraud prevention, and regulatory compliance.
• Support Communications: Customer support inquiries and chat logs are retained for 3 years for quality assurance and dispute resolution.
• Marketing Communications: If you opt out of marketing, we retain your email address on a suppression list indefinitely to ensure we do not accidentally contact you again.

After the applicable retention period expires, personal data is securely deleted or anonymized so that it can no longer identify you. Anonymized data may be retained indefinitely for statistical analysis and business intelligence purposes.

9. Children's Privacy (21+ Only)

kode4 is strictly an adult-only service. We do not knowingly collect personal information from individuals under 21 years of age. Our Terms & Conditions explicitly prohibit anyone under 21 from creating an account or using the Service.

If we discover that we have inadvertently collected personal information from a user under 21 years of age, we will immediately:

• Suspend or terminate the account permanently.
• Delete all associated personal data from our systems.
• Forfeit any deposits and winnings in the account.
• Report the incident to relevant authorities if required by law.

If you believe a minor has accessed kode4 and provided personal information, please contact us immediately at [email protected] so we can take appropriate action.

10. Changes to This Privacy Policy

kode4 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes that significantly affect your privacy rights, we will:

• Update the "Last Updated" date at the top of this Policy.
• Notify you via email to your registered address and/or prominent notice on the Platform homepage.
• In some cases (where required by law), request your renewed consent to continue processing your data under the new terms.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. Your continued use of the Service after changes to this Policy become effective constitutes your acceptance of the updated terms.

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

11. Contact Information and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us through the following channels:

General Privacy Inquiries:

• Email: [email protected]
• Customer Support: Available 24/7 via live chat, WhatsApp, or [email protected]

Data Protection Officer:

kode4 Data Protection Officer
Email: [email protected]
Subject Line: "Data Privacy Inquiry - [Your Account Username]"

For legal notices, formal complaints, or regulatory inquiries:

kode4 Legal Department
Email: [email protected]

When contacting us about privacy matters, please include your full name, registered email address, account username, and a clear description of your inquiry or request. We aim to respond to all privacy-related inquiries within 30 days.