ubm4d Privacy Policy

1 Definitions

The following definitions apply throughout this Policy:

• "Personal Data" — Any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, Indonesian national ID (KTP) number, bank account details, IP address, and device identifiers.
• "Processing" — Any operation performed on Personal Data, whether by automated means or otherwise, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" — The entity that determines the purposes and means of Processing Personal Data. ubm4d is the Data Controller for all Personal Data collected via the Platform.
• "Data Processor" — A third party that processes Personal Data on behalf of ubm4d, under contract and subject to ubm4d's instructions.
• "Member" — Any individual who has registered a ubm4d account.
• "Services" — All gaming, betting, payment, customer support, and ancillary services available via the ubm4d Platform.
• "KYC" — Know Your Customer — identity and payment verification procedures required before a Member may withdraw funds.

2 Data Controller

ubm4d is the Data Controller responsible for Personal Data collected and processed through the ubm4d Platform. ubm4d operates under an international gaming licence and processes data in compliance with applicable international data protection standards.

For all data protection inquiries, rights requests, and complaints, Members may contact the ubm4d Data Protection team at [email protected]. Requests are acknowledged within 48 hours and resolved within 30 calendar days.

3 Data We Collect

ubm4d collects the categories of Personal Data described in the table below. We collect only what is necessary for the stated purposes.

ubm4d does not collect sensitive personal data beyond what is strictly required for KYC verification and responsible gaming compliance (e.g., self-exclusion status). We do not process racial or ethnic origin data, political opinions, religious beliefs, or biometric data beyond standard document-based identity verification.

4 How We Collect Data

ubm4d collects Personal Data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, depositing or withdrawing funds, contacting support, or filling in your account profile.
• Automated collection: Technical Data collected automatically when you access the Platform, including IP address, device identifiers, session cookies, and page interaction data gathered via our server-side analytics infrastructure.
• Payment processors: Transaction confirmation data received from our payment partner network (including Indonesian bank transfer gateways and e-wallet processors for OVO, DANA, GoPay, ShopeePay, and LinkAja) after you initiate a deposit or withdrawal.
• KYC verification partners: Identity verification results and risk signals from contracted third-party KYC service providers used to confirm your identity and age in compliance with our gaming licence conditions.
• Fraud prevention services: Risk scoring data from contracted fraud-detection partners used to detect account compromise, duplicate accounts, and suspicious financial activity.

5 Purposes of Processing

ubm4d processes your Personal Data for the following purposes:

• Account creation and management: To register your account, verify your identity, maintain your member profile, and provide access to the Services.
• Payment processing: To process deposits and withdrawals in Indonesian Rupiah (IDR) via your chosen payment method, to confirm payment success, and to maintain accurate transaction records.
• KYC and age verification: To verify that you are at least 21 years of age and are who you claim to be, in compliance with our international gaming licence and responsible gaming obligations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, duplicate accounts, money laundering, account takeover, and other security threats.
• Responsible gaming compliance: To monitor gambling behaviour for indicators of problem gambling, to administer deposit limits, cool-off periods, and self-exclusion requests, and to comply with responsible gaming obligations under our licence.
• Customer support: To respond to your inquiries, resolve disputes, and maintain records of interactions for quality and training purposes.
• Legal and regulatory compliance: To comply with anti-money laundering (AML) obligations, gaming licence conditions, and any lawful requests from competent authorities.
• Platform improvement: To analyse usage patterns via aggregated, anonymised analytics data to improve the performance, design, and content of the ubm4d Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and product updates via email — only where you have consented to receive such communications. See Clause 12 for opt-out options.

6 Legal Bases for Processing

ubm4d relies on the following legal bases for processing your Personal Data, in accordance with internationally recognised data protection principles:

• Contractual necessity: Processing required to fulfil the ubm4d Terms & Conditions and to provide the Services you have requested (e.g., account creation, payment processing, game access).
• Legal obligation: Processing required to comply with applicable legal requirements, including KYC verification, AML obligations, and gaming licence conditions.
• Legitimate interests: Processing conducted for ubm4d's legitimate business interests where these are not overridden by your rights and interests — specifically fraud prevention, platform security, and aggregated analytics for service improvement.
• Consent: Processing based on your explicit opt-in consent, specifically for marketing email communications. You may withdraw consent at any time. Withdrawal of marketing consent does not affect your ability to use the Services.

7 Data Sharing with Third Parties

ubm4d shares your Personal Data with third parties only in the circumstances described below. All third-party Data Processors operate under binding data processing agreements that impose data protection obligations consistent with this Policy.

• Payment processors: Indonesian bank transfer gateways and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum data necessary to process your deposit or withdrawal transaction.
• KYC and identity verification providers: Contracted third-party services receive your identity documents and personal details for age and identity verification purposes only. Verification results are returned to ubm4d and documents are not retained by the verification provider beyond their stated data retention period.
• Fraud prevention services: Risk and fraud analytics providers receive Technical Data and anonymised transaction signals to assess account risk. Full identity data is not shared with these providers.
• Game studios: Game content providers (including Pragmatic Play, Evolution Gaming, PG Soft, NetEnt, Microgaming, and Spribe) receive a technical player session token to load game content. Game studios do not receive your full name, Indonesian ID number, bank details, or contact information.
• Legal and regulatory authorities: ubm4d will disclose Personal Data to law enforcement, regulatory bodies, or gaming licence authorities where required by law or by a valid legal order. ubm4d will notify you of such disclosures where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of ubm4d's assets, your Personal Data may be transferred to the acquiring entity, which will be required to honour this Privacy Policy or provide you with advance notice of any material changes to privacy practices.

8 International Data Transfers

ubm4d operates as an international gaming platform. Some of our Data Processors — including KYC verification providers, fraud prevention services, and game studio infrastructure — may process Personal Data outside of Indonesia. Where such transfers occur, ubm4d ensures that appropriate safeguards are in place, including:

• Contractual data processing agreements requiring the recipient to apply data protection standards consistent with this Policy.
• Transfers only to service providers in jurisdictions that maintain adequate data protection frameworks, or under standard contractual clauses providing equivalent protections.
• Technical measures including encryption in transit and at rest to protect Personal Data regardless of where it is processed.

Indonesian player data is processed in compliance with applicable Indonesian data protection regulations, including the Personal Data Protection Law (UU PDP) where applicable. Members wishing to obtain further information about the safeguards applicable to international transfers may contact [email protected].

9 Data Retention

ubm4d retains Personal Data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, and licensing obligations. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be linked to an individual. Anonymised, aggregated data may be retained indefinitely for statistical analysis.

10 Security Measures

ubm4d implements a layered set of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure:

• Encryption in transit: All data transmitted between your device and the ubm4d Platform is encrypted using TLS 1.2 or higher (256-bit AES).
• Encryption at rest: Sensitive data stored on ubm4d servers — including KYC documents and financial data — is encrypted at rest using AES-256.
• Password security: Member passwords are hashed using bcrypt with a suitable cost factor before storage. Plain-text passwords are never stored or logged anywhere in the ubm4d infrastructure.
• Payment tokenisation: Bank account and e-wallet details used for recurring withdrawals are tokenised — the raw payment credentials are never stored on ubm4d's application servers.
• Access controls: Internal access to Member Personal Data is restricted to authorised personnel on a need-to-know basis, enforced through role-based access control (RBAC) and multi-factor authentication for all staff.
• Penetration testing: ubm4d conducts periodic security assessments including penetration testing and vulnerability scanning of the Platform infrastructure.
• Incident response: In the event of a data breach that poses a risk to Members' rights, ubm4d will notify affected Members and relevant authorities within the timeframes required by applicable data protection law.

11 Cookies & Tracking Technologies

ubm4d uses cookies and similar technologies solely for operational and security purposes. The cookies we deploy fall into the following categories:

• Essential cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during your visit, CSRF protection tokens, and load-balancing cookies. Essential cookies cannot be disabled without breaking core Platform functionality.
• Analytics cookies: First-party analytics cookies used to understand how Members navigate the Platform, which pages are most visited, and where technical issues occur. Analytics data is aggregated and anonymised — it is not linked to your identity. ubm4d does not use third-party analytics services that track you across websites.
• Preference cookies: Cookies that remember your language preference, display settings, and last-visited game category to improve your experience on return visits.

ubm4d does not use advertising cookies, cross-site tracking pixels, or social media tracking scripts. You can manage cookie settings through your browser; however, disabling essential cookies will prevent you from logging in to your account.

12 Marketing Communications

ubm4d may send you promotional emails about bonuses, new game launches, seasonal promotions, and platform updates only where you have explicitly opted in to receive such communications at the time of registration or in your account settings.

You may withdraw your consent to marketing communications at any time by:

• Updating your notification preferences in the ubm4d account settings dashboard.
• Clicking the unsubscribe link included in every ubm4d promotional email.
• Contacting support at [email protected] with a written opt-out request.

Unsubscribe requests are processed within five business days. Withdrawing marketing consent does not affect your ability to receive service communications (e.g., deposit confirmation emails, withdrawal notifications, account security alerts), which are sent as part of the contractual Services regardless of your marketing preference.

13 Your Data Protection Rights

As a Member of the ubm4d Platform, you hold the following rights in relation to your Personal Data. To exercise any of these rights, contact [email protected] with the subject line "Data Rights Request" and a description of your request. We will acknowledge your request within 48 hours and respond substantively within 30 days.

• Right of access: You may request a copy of all Personal Data ubm4d holds about you, together with information about how it is processed.
• Right to rectification: You may request correction of any inaccurate or incomplete Personal Data. You can update most profile information directly in your account settings.
• Right to erasure ("right to be forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to ubm4d's legal obligations to retain certain data (see Clause 9).
• Right to restrict processing: You may request that ubm4d restricts the processing of your Personal Data in certain circumstances, such as while a dispute over accuracy is being resolved.
• Right to data portability: You may request an export of your Personal Data in a structured, commonly used, machine-readable format (CSV or JSON) covering account data and transaction history.
• Right to object: You may object to processing based on ubm4d's legitimate interests at any time. ubm4d will cease such processing unless it can demonstrate compelling legitimate grounds that override your rights.
• Right to withdraw consent: Where processing is based on your consent (specifically marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

Please note that some rights requests may be limited where compliance would prevent ubm4d from meeting its legal obligations under its gaming licence, AML requirements, or fraud prevention duties. In such cases, ubm4d will explain the limitation in its response to your request.

14 Minors and Age Restriction

The ubm4d Platform is strictly for individuals aged 21 years or older. ubm4d does not knowingly collect Personal Data from persons under the age of 21. All registrations require confirmation of age, and ubm4d uses KYC verification procedures to verify that Members meet this age requirement.

If ubm4d discovers that it has inadvertently collected Personal Data from a person under 21, all such data will be deleted immediately, the associated account will be closed, and any deposits will be refunded where the source of funds can be verified.

If you are a parent or guardian and believe that a minor may have registered a ubm4d account, please contact [email protected] immediately with relevant details. We will investigate and act within 24 hours of a credible report.

15 Third-Party Links and Services

The ubm4d Platform does not contain links to third-party websites for advertising or affiliate purposes. Game content is delivered directly within the Platform via embedded game engines provided by our licensed studio partners (Pragmatic Play, Evolution Gaming, PG Soft, NetEnt, Microgaming, Spribe, and others). These studios operate their own servers and may process Technical Data necessary to deliver the game experience, subject to their own privacy practices. ubm4d selects studio partners that maintain data handling standards consistent with this Policy.

ubm4d is not responsible for the privacy practices of any third-party service that you access independently and outside the ubm4d Platform.

16 Amendments to This Policy

ubm4d reserves the right to update this Privacy Policy at any time. Where changes are material — such as a new category of data being collected, a new purpose for processing, or a new third-party data sharing arrangement — ubm4d will notify Members via their registered email address at least 14 days before the change takes effect.

Non-material changes (e.g., clarifications of existing practices, corrections to typographical errors, reorganisation of clause structure without substantive change) may be made without prior notice. The date at the top of this Policy will always reflect when it was last revised.

Your continued use of the ubm4d Platform after the effective date of a revised Policy constitutes acceptance of the updated terms. If you do not accept a revised Policy, you must close your account before the effective date by contacting support.

17 Contact & Complaints

For all questions, concerns, or requests related to this Privacy Policy or your Personal Data, contact the ubm4d Data Protection team:

• Email: [email protected] — please include "Privacy Policy" or "Data Rights Request" in the subject line.
• Live Chat: Available 24/7 within the Platform after logging in at /ubm4d-login. Native Indonesian-speaking agents are available across WIB (UTC+7), WITA (UTC+8), and WIT (UTC+9) time zones.

ubm4d takes all privacy complaints seriously. If you believe your data protection rights have been violated and ubm4d has not resolved the matter to your satisfaction, you may escalate the complaint to the data protection authority in the jurisdiction in which ubm4d holds its gaming licence, or to the relevant Indonesian regulatory body for matters governed by Indonesian law.