Privacy Policy
cie4d — Your Data, Protected.

This Privacy Policy ("Policy") describes how cie4d ("we", "us", "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you", "Member") who register an account on, or otherwise interact with, the cie4d online betting platform accessible at https://cie4d.vu.

cie4d operates as an internationally licensed online gaming platform and serves a primary user base in Indonesia. In providing our Services — which include sportsbook wagering, live casino, slot games, togel (Indonesia's traditional numbers lottery), and slot tournaments — we necessarily collect and process personal data in order to operate securely and in compliance with our legal obligations.

By registering a cie4d account, using any of our Services, or continuing to browse the platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. If you do not agree to this Policy, you should not register an account or use our Services.

This Policy should be read alongside our Terms & Conditions, which govern your overall use of the cie4d platform. In the event of any conflict between this Policy and the Terms & Conditions on a data-related matter, this Policy prevails.

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

• "Personal Data" — any information that identifies or can reasonably identify a living individual, either directly (e.g., name, email address) or indirectly (e.g., account ID combined with a device fingerprint).
• "Processing" — any operation performed on personal data, including collection, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" — cie4d, as the entity that determines the purposes and means of processing your personal data.
• "Data Processor" — a third party that processes personal data on behalf of cie4d under a written data-processing agreement (e.g., a payment gateway, a KYC verification provider).
• "KYC" — Know Your Customer; the identity and age verification process required before withdrawals are processed.
• "AML" — Anti-Money Laundering; the regulatory framework and internal controls cie4d maintains to detect and prevent financial crime.
• "Cookies" — small text files stored on your device by your browser when you visit cie4d, used to recognise your session and improve platform performance.
• "Services" — all products and features available through the cie4d platform, as further defined in the Terms & Conditions.

We collect personal data across several categories, depending on how you interact with cie4d. The table below summarises the main categories and specific data points we collect:

3.1 Sensitive Data. cie4d does not intentionally collect sensitive personal data categories such as health information, racial or ethnic origin, political opinions, or religious beliefs, except where KYC requirements may incidentally capture such information in identity document images. Any such incidental data is treated with the highest level of care and not used for any purpose beyond identity verification.

3.2 Voluntary Disclosure. If you voluntarily share additional personal information with us — for example, in a support chat or complaint email — we will process that information in accordance with this Policy.

cie4d collects personal data through the following mechanisms:

• Direct submission: Information you provide when completing the registration form, submitting KYC documents, updating your account profile, making a deposit or withdrawal request, or contacting customer support.
• Automated collection: Technical and behavioural data collected automatically when you access the cie4d platform, including through cookies, server logs, and analytics tools. See Section 10 for full details on cookies and tracking.
• Third-party sources: Identity and fraud-risk data received from KYC verification providers and AML screening services as part of our regulatory compliance process. Payment confirmation data received from banks and e-wallet providers when you make a deposit or withdrawal.
• Publicly available sources: In limited circumstances related to fraud prevention or AML compliance, cie4d may cross-reference information against publicly available databases, sanctions lists, or politically exposed person (PEP) registries.

cie4d uses your personal data only for the purposes set out below. We do not use your data for automated decision-making that produces legal or similarly significant effects without human review.

cie4d processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions — including account registration, payment processing, KYC verification, and dispute resolution.
• Legal obligation: Processing required to comply with applicable AML regulations, gaming licence conditions, and lawful authority requests.
• Legitimate interests: Processing undertaken to protect the security and integrity of the platform, prevent fraud, improve our Services, and conduct analytics — where such interests are not overridden by your privacy rights.
• Consent: Processing of data for marketing communications, where you have given explicit opt-in consent. You may withdraw this consent at any time without affecting your ability to use the platform.

7.1 cie4d does not sell, rent, or trade your personal data to third parties. We share your data only as described in this section.

7.2 Service Providers (Data Processors). We engage third-party companies to perform specific functions on our behalf. These companies act as Data Processors and are contractually prohibited from using your data for any purpose beyond the specific service they provide to cie4d. Categories of service providers include:

• KYC and identity verification providers
• AML screening and fraud detection platforms
• Payment processors and banking partners
• Cloud hosting and infrastructure providers
• Customer support software providers
• Platform analytics and performance monitoring tools

7.3 Regulatory & Legal Authorities. cie4d will disclose personal data to regulatory bodies, law enforcement agencies, or courts when required to do so by applicable law, court order, or our licensing authority. We will notify you of such disclosure where we are legally permitted to do so.

7.4 Business Transfers. In the event that cie4d or its operating entity is involved in a merger, acquisition, or sale of all or part of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the privacy commitments applicable to your data following the transaction.

7.5 Game Content Providers. Game studios such as Pragmatic Play, Evolution Gaming, PG Soft, and NetEnt may receive anonymised session and wagering data required to facilitate game delivery and RNG auditing. These providers do not receive your identity or financial data unless required for licensing compliance.

8.1 cie4d retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by our legal and regulatory obligations, whichever is longer.

8.2 Retention Periods. The following general retention periods apply:

• Account and KYC records: Retained for the duration of your active account plus a minimum of 5 years after account closure, in compliance with AML record-keeping obligations.
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction.
• Support and complaint records: Retained for 3 years from the date of resolution.
• Marketing preference records: Retained until you withdraw consent or close your account, plus 1 year for audit purposes.
• Technical and log data: Retained for up to 13 months for security and fraud analysis purposes.

8.3 After the applicable retention period expires, personal data is securely deleted or anonymised so that it can no longer be associated with any individual Member.

9.1 cie4d implements a comprehensive set of technical and organisational security controls to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These include:

• TLS 1.3 encryption for all data in transit between your device and our servers.
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records.
• Strict access controls ensuring that only authorised cie4d personnel can access personal data, on a need-to-know basis with full audit logging.
• Regular independent penetration testing and vulnerability assessments of our platform infrastructure.
• Optional two-factor authentication (2FA) for Member accounts.
• Real-time fraud and anomaly detection monitoring with automated alerting for suspicious activity.

9.2 Despite these measures, no system is completely immune to security incidents. In the event of a data breach that is likely to result in a risk to your rights and freedoms, cie4d will notify you in accordance with our obligations under applicable law, without undue delay.

10.1 cie4d uses cookies and similar tracking technologies to operate the platform, authenticate your session, maintain your preferences, and improve performance. The table below summarises the types of cookies we use:

10.2 cie4d does not use third-party advertising or retargeting cookies. We do not permit ad networks to place cookies on the cie4d platform.

10.3 You can control cookies through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your cie4d account and using the platform's core features. Disabling functional cookies may result in your preferences not being saved between sessions.

As a Member of cie4d, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team via live chat or email at [email protected]. We will respond to all rights requests within 30 days.

12.1 cie4d's Services are strictly intended for adults aged 21 and over. We do not knowingly collect personal data from individuals under the age of 21. KYC verification is mandatory for all Members, and the provision of identity documents is required to confirm age compliance before withdrawal privileges are activated.

12.2 If cie4d discovers or has reasonable grounds to believe that a Member is under the age of 21, the account will be suspended immediately. Any funds in the account representing net deposits will be returned to the source payment method; all winnings will be forfeited. The Member's data will be retained only to the extent required to document the incident and comply with regulatory reporting obligations, after which it will be securely deleted.

12.3 If you believe that a person under 21 has registered or is using a cie4d account, please contact our support team immediately at [email protected].

13.1 cie4d reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The "Last updated" date at the top of this page will be revised accordingly.

13.2 Where changes are material — meaning they significantly affect how we collect, use, or share your personal data, or your rights in relation to that data — we will notify you by email to the address registered on your account at least 7 days before the updated Policy takes effect.

13.3 Your continued use of the cie4d platform after the effective date of an updated Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must cease using the Services and request account closure prior to the effective date.

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a data-related concern, please contact cie4d through any of the following channels: