Privacy Policy — mil04d

1 Definitions

The following terms have the meanings set out below throughout this Privacy Policy:

• "Platform" — the mil04d website at https://mil04d.cam and all associated services, features, and sub-pages.
• "Company", "mil04d", "We", "Us", "Our" — mil04d and its operating entities responsible for processing your personal data.
• "Player", "You", "Your" — any natural person who registers a Player Account with mil04d or visits the Platform.
• "Personal Data" — any information that identifies or could reasonably identify a living natural person, including name, email address, date of birth, device identifiers, and financial account details.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "KYC" — Know Your Customer; the identity and age verification procedure applied to all Player Accounts.
• "Service Providers" — third-party entities engaged by mil04d to deliver specific operational services (e.g., payment processors, KYC verification partners, fraud detection providers).
• "IDR / Rp" — Indonesian Rupiah, the sole currency of all Platform transactions.

2 Scope & Controller

This Privacy Policy applies to all Personal Data collected by mil04d through the Platform, including data collected during account registration, KYC verification, payment transactions, customer support interactions, and general browsing of the Platform.

mil04d acts as the data controller in respect of all Personal Data collected via the Platform. As data controller, mil04d determines the purposes and means by which your Personal Data is processed. Where mil04d engages Service Providers to process data on its behalf, those providers act as data processors and are bound by contractual obligations that restrict their use of your data to the specific services they provide.

This Policy applies to Players based throughout Indonesia — including those accessing the Platform from Jakarta, Surabaya, Bandung, Medan, Bali, Semarang, Yogyakarta, and all other regions of the archipelago — as well as to any other visitors who access the Platform regardless of location.

3 Data We Collect

mil04d collects the following categories of Personal Data, limited to what is necessary for the purposes described in this Policy:

Category	Examples	Required For
Identity Data	Full legal name, date of birth, nationality, government-issued ID number (KTP / passport)	Account registration, KYC verification, age verification
Contact Data	Email address, phone number	Account communication, support, security alerts
Financial Data	Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history	Deposits, withdrawals, anti-money-laundering checks
Technical Data	IP address, browser type, device type, operating system, session timestamps	Platform security, fraud detection, service optimisation
Usage Data	Pages visited, games played, wager amounts, session duration, feature interactions	Responsible gaming monitoring, product improvement
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Customer support, dispute resolution, quality assurance
Verification Documents	Scanned copies of KTP, passport, driving licence (SIM), proof-of-address documents	KYC compliance, regulatory obligations

mil04d does not collect or process special categories of sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information) unless specifically required by a regulatory authority and with your explicit prior consent.

4 How Data Is Collected

mil04d collects Personal Data through the following means:

• Direct interactions: Data you provide when completing the registration form, submitting KYC documents, making deposits or withdrawals, contacting customer support, or responding to surveys and promotions.
• Automated technologies: Technical and Usage Data collected automatically as you navigate the Platform, using cookies, server logs, and similar tracking technologies. See Section 9 (Cookies & Tracking) for full details.
• Third-party Service Providers: Identity verification results, fraud-risk scores, and payment confirmation data received from our KYC partners and payment processors when you initiate a transaction or verification check.
• Publicly available sources: In limited circumstances where required for fraud prevention or regulatory compliance, mil04d may cross-reference your data against publicly available records or sanctions lists.

5 Purpose & Legal Basis

mil04d processes your Personal Data only where a valid legal basis exists. The table below summarises the primary processing purposes and their corresponding legal bases:

Purpose	Legal Basis
Creating and managing your Player Account	Performance of contract
Processing deposits and withdrawals	Performance of contract
KYC identity and age verification (21+)	Legal obligation; legitimate interest
Anti-money-laundering and fraud prevention checks	Legal obligation; legitimate interest
Responsible gaming monitoring and intervention	Legitimate interest; legal obligation
Sending transactional and security notifications	Performance of contract; legitimate interest
Sending promotional communications and bonus offers	Consent (you may withdraw at any time)
Platform analytics and product improvement	Legitimate interest
Responding to customer support requests	Performance of contract; legitimate interest
Compliance with regulatory and legal obligations	Legal obligation

6 Sharing Your Data

mil04d does not sell, rent, or trade your Personal Data. We may share your data only in the following limited circumstances:

• Service Providers: mil04d engages carefully selected third-party providers to support specific operational functions, including payment processing (Indonesian bank transfer and e-wallet networks), KYC and identity verification services, fraud detection and risk-scoring platforms, and customer support tooling. These providers are contractually obligated to process your data only as instructed by mil04d and to apply appropriate security measures.
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order, or a lawful request from a competent authority, mil04d will disclose Personal Data to the extent mandated. mil04d will notify you of any such disclosure where it is legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of mil04d's 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 any material change to this Privacy Policy resulting from it.
• Anti-Fraud and Shared Risk Networks: mil04d may share limited data (such as device fingerprints or flagged account identifiers) with industry anti-fraud consortiums for the purpose of detecting and preventing bonus abuse, multi-accounting, and financial crime. No personally identifiable financial data is shared in this context without a specific legal basis.

In all cases, data sharing is governed by written data-processing agreements that impose confidentiality obligations and restrict the receiving party's use of the data to the stated purpose.

7 Data Retention

mil04d retains your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, to meet legal and regulatory obligations, and to resolve disputes or enforce agreements. The following general retention periods apply:

• Active account data (identity, contact, financial): retained for the duration of your active Player Account plus a minimum of 5 years following account closure, in compliance with anti-money-laundering record-keeping requirements.
• KYC documents (copies of KTP, passport, proof of address): retained for a minimum of 5 years from the date of submission or account closure, whichever is later.
• Transaction records (deposit and withdrawal history, wager logs): retained for a minimum of 5 years following the date of each transaction.
• Support communications (chat transcripts, email correspondence): retained for 3 years from the date of the interaction, or longer if related to an ongoing dispute.
• Technical and Usage Data (IP logs, session data): retained for 12 months on a rolling basis, unless required for a specific security investigation.
• Marketing consent records: retained for the duration of the consent plus 2 years to demonstrate compliance.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with mil04d's data disposal procedures.

8 Data Security

mil04d implements a multi-layered approach to data security, combining technical, organisational, and procedural controls to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. Measures include, but are not limited to:

• Transport Encryption: All data transmitted between your browser and our servers is protected by 256-bit SSL/TLS encryption.
• Database Encryption: Sensitive fields within our databases — including financial account identifiers and government ID numbers — are stored in encrypted form.
• Access Controls: Access to systems containing Personal Data is restricted to authorised employees on a need-to-know basis, enforced through role-based access control and multi-factor authentication.
• Intrusion Detection: Our infrastructure is monitored continuously for suspicious activity. Automated alerting systems flag anomalous access patterns for immediate review.
• Penetration Testing: The Platform undergoes periodic third-party security assessments to identify and remediate vulnerabilities before they can be exploited.
• Staff Training: All mil04d personnel with access to Personal Data receive mandatory data protection training at onboarding and on an annual basis thereafter.

While mil04d applies industry best-practice security controls, no system can be guaranteed as completely impenetrable. You are responsible for maintaining the confidentiality of your own login credentials and for notifying mil04d immediately if you suspect that your account has been compromised.

9 Cookies & Tracking Technologies

mil04d uses cookies and similar tracking technologies to enhance the functionality of the Platform, maintain your session, and gather analytics data that helps us improve the user experience. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to operate. These cookies enable core functions such as maintaining your login session, remembering your language preference, and securing your account. They cannot be disabled without significantly impairing Platform functionality.
• Functional Cookies: Used to remember your preferences and personalise your experience, such as recalling your preferred payment method or display settings.
• Analytics Cookies: Collect aggregated, anonymised data about how visitors interact with the Platform — pages visited, time spent, and navigation paths. This data is used solely to improve Platform performance and does not identify you personally.
• Security Cookies: Used to detect and prevent fraudulent activity, including session hijacking attempts and abnormal login patterns.

mil04d does not use third-party advertising or retargeting cookies. Your browsing activity on the Platform is not shared with external advertising networks.

You can control cookie preferences through your browser settings. Blocking strictly necessary cookies may prevent you from accessing the Platform or logging into your account. Disabling analytics and functional cookies will not affect your ability to place wagers or make transactions.

10 Your Rights

Subject to applicable law, you have the following rights in relation to the Personal Data that mil04d holds about you:

• Right of Access: You may request a copy of the Personal Data mil04d holds about you, along with information about how it is processed.
• Right to Rectification: You may request that inaccurate or incomplete Personal Data be corrected. You can update certain account details directly from within your Player Account settings.
• Right to Erasure: In certain circumstances you may request that mil04d delete your Personal Data. This right is subject to our legal obligation to retain specific data categories (see Section 7). Where erasure is not possible due to a legal obligation, we will restrict processing instead.
• Right to Restrict Processing: You may request that mil04d limit the processing of your data while a dispute regarding its accuracy or the lawfulness of processing is resolved.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, you may request a structured, commonly used, machine-readable copy of your Personal Data for transfer to another service.
• Right to Object: You may object at any time to processing based on mil04d's legitimate interests, including processing for direct marketing purposes. Where you object to marketing, we will cease such processing immediately.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, submit your request in writing to [email protected]. mil04d will acknowledge your request within 5 business days and provide a substantive response within 30 days. In complex cases, this period may be extended by a further 30 days, and you will be informed of the extension in advance.

11 Minors

The mil04d Platform is strictly intended for adults aged 21 and above. mil04d does not knowingly collect Personal Data from any person under the age of 21. If mil04d discovers or is notified that Personal Data has been collected from a person under 21, it will take immediate steps to delete that data and close the associated account.

Parents and guardians who have reason to believe that a minor has registered an account on the Platform are encouraged to contact us immediately at [email protected]. mil04d will investigate and act without delay.

12 International Data Transfers

mil04d's operational infrastructure and certain Service Providers are located outside of Indonesia. As a result, your Personal Data may be transferred to and processed in countries other than the country in which you reside. mil04d ensures that all such international transfers are conducted in accordance with applicable data protection standards, including through the use of:

• Contractual safeguards — data processing agreements that impose obligations on recipients equivalent to those described in this Policy.
• Transfers to jurisdictions that are recognised as providing an adequate level of data protection by relevant international standards.
• Technical and organisational measures appropriate to the risk profile of the transfer, including encryption in transit and at rest.

By using the Platform, you acknowledge and consent to the transfer of your Personal Data to countries outside Indonesia where mil04d or its Service Providers operate, subject to the safeguards described above.

13 Policy Amendments

mil04d reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, registered Players will be notified via the email address associated with their account and/or through a prominent notice on the Platform.

The "Last Updated" date at the top of this page will always reflect the date on which the current version was published. We encourage you to review this Policy periodically. Your continued use of the Platform after an updated Policy has been posted constitutes your acceptance of the revised terms.

14 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a privacy-related complaint, please contact the mil04d data protection team using the details below. Our support agents are available 24 hours a day, 7 days a week (WIB), with native Indonesian-speaking staff on hand.

mil04d takes all privacy complaints seriously. Upon receipt of a complaint, we will:

1. Acknowledge your complaint within 2 business days.
2. Assign the complaint to a qualified member of our data protection team for review.
3. Provide a substantive written response within 15 business days.
4. Escalate to senior management and, where required, to our external privacy advisors if the matter cannot be resolved at the first-response stage.

If you are not satisfied with mil04d's response to your privacy complaint, you have the right to escalate the matter to the relevant data protection supervisory authority or regulatory body in your jurisdiction.