ese4d Privacy Policy

In this Privacy Policy, the following terms carry the meanings defined below:

ese4d collects Personal Data through several distinct channels during the course of your relationship with the platform. The categories of data we collect are as follows:

2.1 Registration Data

When you create an ese4d account, we collect the information you provide directly, including your full legal name, date of birth, Indonesian residential address, email address, and phone number. This data is required to create and administer your account and to comply with our age-verification and KYC obligations.

2.2 Identity Verification (KYC) Data

For withdrawal processing and fraud prevention, we may request copies of government-issued identity documents, including your Indonesian National ID (KTP), passport, or driver's licence, together with supporting proof-of-address documents. Biometric data extracted from these documents (such as your photograph) is processed solely for identity-matching purposes and is not used for any other commercial purpose.

2.3 Financial Transaction Data

We collect details of all deposits and withdrawals made through your account, including transaction amounts (in IDR), payment method identifiers (such as BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, DANA, GoPay, ShopeePay, or LinkAja account references), transaction timestamps, and transaction reference numbers. We do not store full bank account passwords or full e-wallet PINs.

2.4 Gameplay Data

ese4d automatically records gameplay activity associated with your account, including all wager placements, game outcomes, session durations, and responsible gaming tool usage (deposit limits, self-exclusion requests, cooling-off periods). This data is used to administer gameplay, detect fraud, identify problem gambling behaviour, and comply with our licensing obligations.

2.5 Technical & Device Data

When you access ese4d, we automatically collect certain technical data, including your IP address, browser type and version, operating system, device identifiers, screen resolution, referring URL, and session timestamps. This data is used for platform security, fraud detection, and performance optimisation.

2.6 Communications Data

We retain records of all communications you send to ese4d through any channel, including live chat transcripts, email correspondence, and WhatsApp message logs (content and timestamps). This data is used to respond to your enquiries, resolve disputes, and improve our support quality.

2.7 Marketing Preference Data

Where you have consented to receive marketing communications, we record your preferences, including your opted-in channels (email, WhatsApp), preferred language, and historical engagement with promotional messages (open rates, click-through events). You may withdraw marketing consent at any time.

ese4d uses the Personal Data we collect for the following purposes:

We do not use your Personal Data for automated decision-making that produces legal or similarly significant effects without human oversight, except in the context of real-time fraud-detection systems where immediate automated action is required to protect the Platform and its Players.

ese4d processes your Personal Data on the following legal bases:

• Contractual Necessity: The majority of our data processing is necessary to perform the contract between you and ese4d — specifically, to create and manage your account, process your financial transactions, and administer your gameplay. Without this processing, ese4d cannot deliver its services to you.
• Legal Obligation: Certain processing activities are required to comply with applicable legal and regulatory obligations, including anti-money laundering (AML) requirements, KYC verification obligations under our international gaming licence, and fraud-reporting duties.
• Legitimate Interests: We process certain categories of data (particularly technical and device data) on the basis of our legitimate interests in maintaining the security, integrity, and performance of the ese4d platform, provided those interests are not overridden by your rights and freedoms.
• Consent: Where we send you marketing communications or deploy non-essential cookies, we do so on the basis of your explicit, freely given consent. You may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ese4d does not sell, rent, or trade your Personal Data. We may share your data only in the following carefully defined circumstances:

• Payment Service Providers: We share transaction-relevant data (such as your name, account reference, and IDR transaction amounts) with Indonesian payment processors and e-wallet operators — including BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja — solely to process your deposits and withdrawals. These providers are bound by their own privacy obligations and are not permitted to use your data for any other purpose.
• Game Content Providers: Where you play games developed by third-party studios such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, or Pocket Games Soft, limited technical data (such as a session token) may be transmitted to their servers to facilitate gameplay. No directly identifiable personal information is transmitted beyond what is technically necessary.
• Identity Verification Partners: We may engage specialist KYC and identity-verification service providers to validate the authenticity of identity documents submitted during the verification process. These partners process your KYC data strictly under our instruction and are prohibited from retaining it beyond the verification period.
• Fraud Prevention & Security Services: ese4d may share device and behavioural data with third-party fraud-detection platforms to identify and prevent fraudulent account activity, bonus abuse, and money laundering. These services process data on a pseudonymised basis wherever technically feasible.
• Legal & Regulatory Authorities: We may disclose Personal Data to competent legal, regulatory, or law-enforcement authorities if required to do so by applicable law, court order, or our international gaming licence conditions. We will notify you of such disclosure wherever legally permissible.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of ese4d's assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent data-protection commitments. You will be notified of any such transfer in advance.

ese4d uses cookies and similar tracking technologies to operate and improve the platform. The categories of cookies we deploy are described below:

You may manage your cookie preferences at any time through your browser settings. Please note that disabling strictly necessary cookies will prevent you from accessing your ese4d account. Disabling fraud-detection cookies may result in additional manual verification steps being applied to your account activity.

ese4d does not use advertising cookies or deploy third-party tracking pixels on behalf of external advertisers.

ese4d retains your Personal Data for as long as is necessary to fulfil the purposes described in this Privacy Policy, and in compliance with our legal and regulatory obligations. The following retention periods apply:

• Active Account Data: All registration, transaction, and gameplay data is retained for the full duration of your active ese4d account relationship.
• Post-Closure Retention: Following the closure of your account (whether voluntarily or by ese4d), we retain your core account data, KYC documents, and transaction records for a minimum of five years. This period is required to comply with anti-money laundering regulations and to resolve any post-closure disputes or regulatory enquiries.
• Communications Data: Customer support transcripts and email correspondence are retained for a period of three years following the date of the last communication, or five years following account closure — whichever is later.
• Marketing Data: If you withdraw consent to marketing communications, your contact details will be suppressed from marketing distribution lists within 48 hours. Suppression records (confirming that you opted out) are retained indefinitely to prevent accidental re-enrolment.
• Anonymous/Aggregated Analytics Data: Aggregated and anonymised analytics data that cannot be linked back to an individual Player is retained indefinitely for platform improvement purposes.

Once the applicable retention period expires, Personal Data is securely deleted or permanently anonymised in accordance with our data destruction procedures.

As a Player on ese4d, you hold the following rights with respect to your Personal Data. All requests should be submitted to [email protected] with the subject line "Data Rights Request" and sufficient identification to verify your identity before we process the request.

• Right of Access: You have the right to request a copy of all Personal Data ese4d holds about you, together with information about how it is used and with whom it is shared. We will respond to access requests within 30 calendar days.
• Right to Rectification: If any Personal Data we hold is inaccurate or incomplete, you have the right to request that we correct it. Account name, address, and contact information corrections can also be made directly through your account settings panel.
• Right to Erasure: You may request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (for consent-based processing), or where you object to processing on legitimate-interest grounds. Please note that we are legally required to retain certain categories of data (such as KYC documents and transaction records) for a minimum of five years post-closure and cannot delete these in response to an erasure request during that period.
• Right to Restrict Processing: You have the right to request that we suspend the use of your Personal Data in certain circumstances — for example, while you contest the accuracy of the data or while an objection to processing is being considered.
• Right to Data Portability: Where processing is carried out on the basis of your consent or contractual necessity, you may request that we provide your Personal Data in a structured, machine-readable format that can be transferred to another service provider.
• Right to Object: You have the right to object at any time to the processing of your Personal Data for direct marketing purposes. You may also object to processing carried out on legitimate-interest grounds; we will cease such processing unless we can demonstrate compelling legitimate grounds that override your rights.
• Right to Withdraw Consent: Where processing is based on your consent (such as for marketing emails or functional cookies), you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of any processing carried out prior to the withdrawal date.

ese4d takes the security of your Personal Data seriously and has implemented a comprehensive set of technical and organisational security measures to protect it against unauthorised access, accidental loss, destruction, or disclosure:

• Encryption: All data transmitted between your device and ese4d is protected by 256-bit SSL/TLS encryption. Sensitive data stored at rest (including KYC documents and payment references) is encrypted using AES-256.
• Access Controls: Access to Personal Data within ese4d's internal systems is restricted on a strict need-to-know basis, enforced by role-based access controls and multi-factor authentication for all staff with data access privileges.
• Penetration Testing: ese4d commissions regular third-party penetration testing of its platform infrastructure to identify and remediate security vulnerabilities before they can be exploited.
• Incident Response: In the event of a data breach that poses a risk to your rights and freedoms, ese4d will notify affected Players and relevant regulatory authorities without undue delay, and in any event within 72 hours of becoming aware of the breach.
• Staff Training: All ese4d employees and contractors who handle Personal Data receive regular data-protection and information-security training as a condition of their engagement.

While ese4d employs robust security measures, no internet-based system is completely immune to risk. You are encouraged to use a strong, unique password for your ese4d account, enable two-factor authentication (2FA), and notify us immediately at [email protected] if you suspect any unauthorised access to your account.

ese4d strictly prohibits access by individuals under the age of 21. We do not knowingly collect Personal Data from anyone under 21 years of age. Our registration process includes an age declaration requirement, and we reserve the right to request KYC documents to verify age at any stage of the account lifecycle.

If ese4d becomes aware that a registered account is held by an individual under 21 years of age, that account will be immediately suspended and all Personal Data associated with it will be handled in accordance with our minor-protection procedures, which include:

• Immediate suspension of all account access and gameplay functionality.
• Review and return of any verifiable real-money deposits, subject to fraud and bonus-abuse checks.
• Deletion of all Personal Data beyond what is strictly required for legal-compliance and record-keeping purposes.
• Notification to our responsible gaming team to log the incident in accordance with our licensing obligations.

ese4d operates as an internationally licensed platform. As a result, certain Personal Data may be transferred to and processed in countries outside Indonesia, including the jurisdiction in which ese4d holds its gaming licence and the locations of our technology infrastructure providers.

Wherever Personal Data is transferred internationally, ese4d ensures that appropriate safeguards are in place to maintain the same level of protection afforded under this Privacy Policy, including:

• Binding contractual clauses with all data processors and sub-processors requiring equivalent data-protection standards.
• Restricting international transfers to jurisdictions that maintain adequate data-protection frameworks or to recipients bound by certified privacy frameworks.
• Conducting transfer-impact assessments prior to establishing new international data flows to ensure that the rights of Indonesian Players are not materially compromised.

You may request further information about the specific safeguards in place for any particular international data transfer by contacting us at [email protected].

ese4d reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data-processing practices, legal obligations, or platform functionality. When material changes are made, we will notify registered Players by email or via an on-platform notice at least 7 days before the updated policy takes effect, except where immediate changes are required for security or legal reasons.

The effective date of the current version of this Privacy Policy is displayed at the top of this page. We recommend reviewing this page periodically so that you remain informed about how we protect your Personal Data. Your continued use of ese4d following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which ese4d handles your Personal Data, please contact us using the details below. All privacy-related enquiries will receive an initial response within 5 business days (WIB).

• General Privacy Enquiries: [email protected] — subject line "Privacy Enquiry".
• Data Rights Requests: [email protected] — subject line "Data Rights Request".
• Responsible Gaming & Minor Protection: [email protected].
• Live Chat: Available 24 hours a day, 7 days a week from any page on the ese4d platform.
• WhatsApp Support: Available 08:00–24:00 WIB for Indonesian-speaking assistance.

If you are not satisfied with ese4d's response to your privacy complaint, you have the right to escalate the matter to the relevant data-protection authority or dispute-resolution body in accordance with the applicable laws of the jurisdiction governing your relationship with ese4d.