Privacy Policy

For the purposes of this Privacy Policy, the following terms carry the meanings defined below. These definitions are consistent with those used in ttm4d's Terms & Conditions and apply across all communications between ttm4d and its members.

2.1 Scope. This Privacy Policy applies to all Personal Data collected and processed by ttm4d in connection with your use of the platform at https://ttm4d.cam, including account registration, gameplay, financial transactions, customer support interactions, and any communications between you and ttm4d.

2.2 Data Controller. ttm4d acts as the Data Controller for all Personal Data collected from Members through the platform. All decisions regarding the purposes and methods of data processing described in this policy are made by ttm4d's data governance team in accordance with applicable data protection law.

2.3 Acceptance. By registering an account or continuing to use the ttm4d platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your Personal Data as described herein. If you do not agree with any part of this policy, you should discontinue use of the platform and contact our support team to close your account.

2.4 Relationship to Terms & Conditions. This Privacy Policy forms part of ttm4d's Terms & Conditions and should be read alongside them. In the event of any conflict between this policy and the Terms & Conditions on a data-related matter, this Privacy Policy shall prevail.

3.1 ttm4d collects the following categories of Personal Data from Members:

3.2 Sensitive Data. ttm4d does not intentionally collect sensitive personal data categories (such as racial or ethnic origin, political opinions, religious beliefs, or biometric data) except where strictly required for identity verification purposes (e.g., a photograph on a government-issued ID). Such data is processed solely for KYC purposes and is not used for any other processing activity.

ttm4d collects Personal Data through the following methods:

• Direct Provision: Data you actively provide when registering an account, completing KYC verification, making deposits or withdrawals, configuring responsible gaming settings, or contacting our support team;
• Automated Collection: Technical data collected automatically when you access the ttm4d platform, including via cookies, web beacons, server logs, and similar tracking technologies described in Clause 10;
• Third-Party Sources: Identity verification data from KYC service providers; fraud-screening data from risk and compliance partners; payment transaction confirmation data from Indonesian banks and e-wallet operators;
• Inferred Data: Behavioural insights derived from your gameplay patterns and platform interactions, used solely for responsible gaming monitoring and product personalisation.

5.1 ttm4d processes Personal Data only where a lawful basis exists. The primary purposes and their corresponding legal bases are set out in the table below:

5.2 Withdrawal of Consent. Where processing is based on your consent (for example, receipt of promotional communications), you may withdraw that consent at any time by contacting our support team at [email protected] or updating your Account preferences. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

6.1 ttm4d does not sell or rent your Personal Data to any third party. We share data only in the following limited circumstances and only to the extent necessary:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum financial data required to process your transactions;
• KYC and Fraud-Screening Providers: Identity verification and risk-scoring platforms receive relevant identity documents and data points solely for the purpose of verifying your identity and assessing fraud risk on ttm4d's behalf;
• Game Content Providers: Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Pocket Games Soft, and Spribe receive a pseudonymised player identifier and session data necessary to operate game mechanics and record game outcomes. They do not receive your name, contact details, or financial information;
• Cloud and IT Infrastructure Providers: Data hosting, backup, and infrastructure services providers process data on ttm4d's servers under strict data processing agreements;
• Legal and Regulatory Authorities: ttm4d will disclose Personal Data to government agencies, law enforcement bodies, or financial intelligence units where required by applicable law, court order, or regulatory instruction. ttm4d will notify affected Members of such disclosure requests where legally permitted to do so;
• Professional Advisers: Legal counsel, auditors, and compliance consultants may access Personal Data on a need-to-know basis under binding confidentiality obligations.

7.1 ttm4d's primary data infrastructure is located in data centres serving the Southeast Asian region. However, some of our third-party service providers — including certain game content studios and cloud infrastructure partners — may process or store data in jurisdictions outside Indonesia.

7.2 Wherever Personal Data is transferred internationally, ttm4d ensures that appropriate safeguards are in place to protect that data to a standard equivalent to or higher than that applied within Indonesia. These safeguards include contractual data processing agreements incorporating standard contractual clauses, and — where relevant — adequacy assessments of the destination country's data protection framework.

7.3 You may request further information about the international transfer safeguards applicable to your data by contacting us at [email protected].

8.1 ttm4d retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following retention periods apply:

• Account and Identity Data: Retained for the duration of the Member's Account plus 5 years following account closure, in accordance with anti-money laundering record-keeping requirements;
• Financial Transaction Records: Retained for 7 years from the date of the transaction, in compliance with applicable financial record-keeping obligations;
• KYC Documents: Retained for 5 years from the date of verification or from account closure, whichever is later;
• Gameplay Records: Retained for 3 years from the date of the relevant session, or longer if required for dispute resolution or regulatory investigation;
• Customer Support Communications: Retained for 2 years from the date of the final communication in each ticket or conversation thread;
• Technical and Log Data: Retained for 12 months from collection, after which it is deleted or anonymised.

8.2 Upon expiry of the applicable retention period, Personal Data is either securely and permanently deleted from ttm4d's systems or rendered irreversibly anonymous such that it can no longer be linked to an identifiable individual.

9.1 ttm4d implements a comprehensive set of technical and organisational security measures designed to protect Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Security: 256-bit SSL/TLS encryption for all data in transit between Members' devices and ttm4d's servers;
• Storage Security: Data at rest is encrypted using AES-256 encryption on all servers and storage systems;
• Access Controls: Role-based access controls (RBAC) restrict internal access to Personal Data strictly to those employees and contractors whose roles require it. All access is logged and audited;
• Two-Factor Authentication (2FA): Available to all Members to add a second layer of login security to their Accounts;
• Penetration Testing: Regular third-party penetration tests and security audits are conducted to identify and remediate vulnerabilities;
• Fraud Monitoring: Automated and manual monitoring systems operate continuously to detect unusual account activity, login anomalies, and payment irregularities;
• Staff Training: All ttm4d staff with access to Personal Data receive mandatory data protection and security awareness training upon joining and on an annual basis thereafter.

9.2 Data Breach Response. In the event of a confirmed Personal Data breach that poses a risk to Members' rights and freedoms, ttm4d will notify affected Members without undue delay and — where required by applicable law — notify the relevant data protection authority within the legally prescribed timeframe. Notifications will include the nature of the breach, the categories of data affected, and the steps taken to mitigate the impact.

10.1 The ttm4d platform uses cookies and similar tracking technologies to enable core platform functionality, improve your experience, and gather analytics data. The following cookie categories are used:

• Strictly Necessary Cookies: Required for the platform to function. These include session cookies that keep you logged in, security tokens, and load-balancing cookies. These cannot be disabled without breaking platform functionality;
• Functional Cookies: Remember your preferences such as language settings, responsible gaming tool configurations, and display preferences to personalise your experience;
• Analytics Cookies: Collect anonymised data on how Members navigate the platform — which pages are visited, how long sessions last, and where errors occur. This data is used to improve platform performance and user experience;
• Security Cookies: Help detect and prevent fraudulent activity, multi-accounting, and bot traffic by analysing behavioural patterns across sessions.

10.2 ttm4d does not deploy third-party advertising or retargeting cookies that track your activity across other websites or deliver behavioural advertising on behalf of external advertisers.

10.3 Cookie Management. You may manage or disable non-essential cookies through your browser's settings. Please note that disabling functional or analytics cookies may affect your experience on the ttm4d platform. Strictly necessary cookies cannot be disabled via browser settings, as they are required for the platform to operate.

As a ttm4d Member, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 24 hours and provide a full response within 30 calendar days.

12.1 The ttm4d platform is strictly intended for adults aged 21 and over. ttm4d does not knowingly collect Personal Data from any individual under the age of 21. Age verification is required during registration, and mandatory KYC is enforced prior to the first withdrawal to confirm that all Members meet the minimum age requirement.

12.2 If ttm4d becomes aware that Personal Data has been collected from an individual under 21 years of age, the relevant Account will be suspended immediately, the data will be deleted as soon as practicable, and any associated transactions will be reviewed and reversed where technically feasible.

12.3 Parents and guardians who believe their minor child may have accessed the ttm4d platform should contact us immediately at [email protected] with the subject line "Minor Account Report". We will treat all such reports as a priority matter.

13.1 The ttm4d platform may occasionally reference or display content from third-party services — such as game providers' promotional assets or live score data feeds. These third parties operate their own privacy policies and data practices that are independent of ttm4d's.

13.2 ttm4d is not responsible for the privacy practices, content, or data handling of any third-party services. We encourage Members to review the privacy policies of any external services they interact with.

14.1 ttm4d reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. Material changes will be communicated to Members via email to their registered address and/or a prominent notice on the platform at least 7 days before the revised policy takes effect.

14.2 Your continued use of the ttm4d platform after the effective date of any amendment constitutes acceptance of the revised Privacy Policy. If you do not agree to the revised policy, you must cease using the platform and contact our support team to exercise your right to erasure or account closure.

14.3 The most current version of this Privacy Policy is always available at ttm4d.cam/privacy-policy. The "Last Updated" date at the top of this page reflects the date of the most recent revision.

15.1 General Privacy Enquiries. For any questions about this Privacy Policy or how ttm4d processes your Personal Data, contact our Data Protection team:

• Email: [email protected] — use subject line "Privacy Enquiry"
• Live Chat: Available 24/7 on the ttm4d platform for logged-in Members
• Data Rights Requests: [email protected] — use subject line "Data Rights Request"

15.2 Response Timeframes. Privacy enquiries will receive an acknowledgment within 24 hours (WIB business hours) and a substantive response within 14 calendar days. Data rights requests (access, erasure, portability) will receive a full response within 30 calendar days of identity verification.

15.3 Complaints. If you are not satisfied with ttm4d's handling of your Personal Data or a data rights request, you have the right to raise a formal complaint. Please submit formal complaints to [email protected] with the subject line "Formal Privacy Complaint". ttm4d will investigate and provide a written resolution within 10 business days.