Privacy Policy

1. Introduction and Scope

pos4t ("we", "us", "our", or the "Company") operates the online gaming platform accessible at https://pos4t.cam (the "Website" or "Platform"). We are deeply committed to protecting the privacy and personal data of all individuals who visit, register on, or interact with our Platform ("Users", "you", or "your"). This Privacy Policy explains, in clear and accessible language, what personal data we collect, why we collect it, how we use and protect it, and what rights you hold over your information.

This Policy applies to all data processing activities conducted by pos4t in connection with your use of our Platform, including account registration, deposits and withdrawals, gameplay, customer support interactions, and marketing communications. It covers data collected through the Website, our customer support channels (live chat, WhatsApp, and email), and any other medium through which you communicate with pos4t.

By registering an account or continuing to use the pos4t Platform, you confirm 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 this Policy, please discontinue use of the Platform immediately and contact us to close your account.

2. Definitions

For clarity throughout this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, national identity number, residential address, email address, phone number, financial account details, and device identifiers.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, modification, or deletion.
• "Controller" means pos4t, the entity that determines the purposes and means of processing your personal data.
• "Processor" means any third-party entity that processes personal data on behalf of pos4t under our instruction and pursuant to a data processing agreement.
• "Consent" means freely given, specific, informed, and unambiguous agreement by the data subject to the processing of their personal data.
• "Cookie" means a small text file placed on your device by a website to store information about your browsing session or preferences.
• "KYC Data" means identity and verification documents provided by Users during the Know Your Customer verification process, including national identity cards (KTP), proof of address documents, and biometric photographs.

3. Personal Data We Collect

3.1 Registration and Account Data

When you create a pos4t account, we collect the following information you provide directly:

• Full legal name (as it appears on your Indonesian National Identity Card / KTP)
• Date of birth (to verify you are 21 years of age or older)
• Residential address (street, city, province, postal code, Indonesia)
• Email address
• Mobile phone number
• Username and hashed password
• Preferred language and currency settings

3.2 Identity Verification (KYC) Data

Indonesian law and our internal compliance obligations require us to verify the identity of all Users before processing withdrawals or applying higher transaction limits. KYC data we collect includes:

• A clear photographic copy of your Indonesian National Identity Card (KTP) or equivalent government-issued photo identification
• A recent proof-of-address document (utility bill, bank statement, or official government correspondence dated within the last three months)
• A selfie photograph of you holding your identity document
• In some cases, a video selfie for enhanced liveness verification

3.3 Financial and Transactional Data

To facilitate deposits and withdrawals, pos4t collects and retains:

• Bank account details (account name, account number, bank name — e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon)
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja account numbers/phone numbers)
• Transaction history: deposit amounts, withdrawal amounts, timestamps, and reference numbers
• All amounts denominated in Indonesian Rupiah (Rp)

3.4 Gameplay and Betting Data

As part of our gaming service, we automatically record:

• Game session logs: games played, bet amounts, outcomes, timestamps
• Sports betting records: markets selected, odds accepted, stake amounts, settlement results
• Togel (traditional Indonesian lottery game) bet records: markets, number selections, draw results, payouts
• Bonus and promotional participation records
• VIP tier progression and loyalty reward history

3.5 Technical and Device Data

When you access the pos4t Platform, our servers and analytics systems automatically collect:

• IP address and geolocation (country, region — used for compliance verification)
• Device type, operating system, and browser version
• Session duration, pages visited, and navigation paths
• Referring URL (the website that directed you to pos4t)
• Cookie identifiers and similar tracking data (see Section 10)

3.6 Customer Support Communications

When you contact our support team via live chat, WhatsApp, or email, we retain:

• The full text of your messages and our responses
• Timestamps and support ticket reference numbers
• Any files, screenshots, or documents you share during the support interaction
• Satisfaction ratings and feedback provided after a support session

4. How We Collect Your Data

pos4t collects personal data through the following channels and mechanisms:

• Directly from you: Registration forms, KYC document uploads, deposit/withdrawal requests, customer support messages, surveys, and promotional opt-in forms
• Automatically: Server logs, cookies, session tracking technologies, and analytics tools that record your interactions with the Platform
• From third-party payment providers: Transaction confirmation data from BCA, BRI, BNI, Mandiri, and e-wallet services (OVO, DANA, GoPay, ShopeePay, LinkAja) that process your deposits and withdrawals
• From identity verification services: Third-party KYC and anti-fraud providers that assist us in verifying the authenticity of identity documents and detecting suspicious activity
• From fraud prevention partners: Risk-scoring data from anti-money-laundering (AML) and fraud detection services

5. Purposes for Processing Your Data

pos4t processes your personal data for the following specific, legitimate purposes:

1. Account management: Creating, maintaining, and securing your player account, and enabling access to our gaming services
2. Identity verification and KYC compliance: Confirming your identity and age (21+) as required by law and our Terms and Conditions
3. Payment processing: Executing deposits and withdrawals via local Indonesian banks and e-wallets
4. Game delivery: Providing slots, live casino, sports betting, togel lottery draws, and other gaming products on the Platform
5. Fraud prevention and anti-money laundering: Detecting and preventing fraudulent activity, bonus abuse, money laundering, and other illegal uses of the Platform
6. Regulatory compliance: Meeting applicable legal obligations under Indonesian law, including financial reporting and record retention requirements
7. Customer support: Responding to your inquiries, resolving disputes, and providing technical assistance
8. Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behavior and implementing protective measures such as deposit limits and self-exclusion
9. Platform improvement: Analyzing usage patterns and technical performance to improve Platform stability, game selection, and user experience
10. Marketing and promotions: Sending you relevant bonus offers, tournament announcements, and promotional materials, where you have opted in to receive such communications

6. Legal Basis for Processing

pos4t processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you have accepted, including account creation, payment processing, and game delivery
• Legal obligation: Processing required to comply with Indonesian legal requirements, including KYC, AML regulations, financial record-keeping obligations, and tax reporting
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights
• Consent: Processing based on your explicit, freely given consent, particularly for marketing communications and optional analytics. You may withdraw consent at any time by contacting support or adjusting your account settings

7. Data Sharing and Disclosure

pos4t does not sell your personal data. We may share your information with the following categories of third parties, strictly for the purposes outlined in Section 5:

• Payment service providers: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, and LinkAja — solely to process your financial transactions
• Identity verification providers: Licensed third-party KYC and document verification services that assist us in fulfilling compliance obligations
• Fraud prevention and AML partners: Risk intelligence providers that help us identify and block suspicious activity
• Cloud infrastructure providers: Data hosting and storage services that operate under strict contractual data processing agreements with pos4t
• Analytics providers: Platform analytics tools that process aggregated, anonymized data to help us understand usage patterns and improve our services
• Game software providers: Licensed game studios (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) that supply the games available on the Platform, and who may receive anonymized session data necessary to operate their games
• Law enforcement and regulators: Indonesian government authorities, law enforcement agencies, or courts where we are required by law or court order to disclose your information

All third-party processors with whom we share personal data are contractually bound to process that data only in accordance with our instructions, to maintain adequate security standards, and to refrain from using your data for any purpose beyond those we have specified.

8. Data Retention

pos4t retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Indonesian law. Our standard retention periods are as follows:

• Account and registration data: Retained for the lifetime of your account and for a minimum of five (5) years following account closure, in accordance with Indonesian financial record-keeping regulations
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure, as required by anti-money laundering legislation
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction
• Gameplay and betting records: Retained for a minimum of three (3) years from the date of each gaming session
• Customer support communications: Retained for two (2) years from the date of each interaction
• Marketing preference data: Retained until you withdraw your consent or close your account, whichever is earlier
• Technical and device logs: Retained for twelve (12) months from the date of collection, unless required longer for security investigations

Upon expiration of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be attributed to a specific individual.

9. Data Security Measures

pos4t employs a comprehensive, layered approach to data security designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, and unlawful disclosure. Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption: All data transmitted between your device and our servers is encrypted using industry-standard Transport Layer Security (TLS 1.2 or higher)
• Encryption at rest: Sensitive personal data stored on our servers — including identity documents and financial account details — is encrypted using AES-256 encryption
• Password hashing: Account passwords are never stored in plain text; they are hashed using bcrypt with a unique salt per account
• Multi-factor authentication (MFA): Optional but strongly recommended MFA is available for all accounts via one-time passwords (OTP) delivered to your registered mobile number
• Role-based access controls: Only authorized pos4t personnel with a specific operational need may access personal data, and all such access is logged and audited
• Penetration testing and vulnerability assessments: Our infrastructure undergoes regular third-party security audits to identify and remediate vulnerabilities
• Intrusion detection and DDoS protection: Real-time monitoring systems are in place to detect and respond to unauthorized access attempts and denial-of-service attacks
• Secure data center infrastructure: Our data is hosted in certified data centers with physical access controls, redundant power systems, and continuous environmental monitoring

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that poses a significant risk to your rights and freedoms, pos4t will notify affected Users and relevant authorities as required by applicable law and within the timeframes prescribed by regulation.

10. Cookies and Tracking Technologies

10.1 Types of Cookies We Use

pos4t uses the following categories of cookies and similar technologies on the Platform:

• Strictly necessary cookies: Essential for the Platform to function — they enable login sessions, remember your cart/balance state, and maintain security tokens. These cookies cannot be disabled without impairing core Platform functionality.
• Functional cookies: Remember your preferences (language settings, display options, notification preferences) to provide a more personalized experience on return visits.
• Analytics cookies: Collect anonymized information about how Users interact with the Platform (pages visited, time on page, click paths) to help us identify usability issues and improve the service.
• Security cookies: Detect and prevent fraudulent activity, bot traffic, and account takeover attempts by associating your session with a trusted device fingerprint.

10.2 Managing Your Cookie Preferences

You can manage non-essential cookies through your browser settings at any time. Most modern browsers allow you to block or delete cookies, or to be notified when a cookie is set. Please note that disabling certain cookies may affect the functionality and performance of the pos4t Platform. Strictly necessary and security cookies cannot be disabled as they are integral to secure Platform operation.

10.3 No Cross-Site Advertising Tracking

pos4t does not use third-party advertising cookies or tracking pixels that follow your browsing activity across other websites for targeted advertising purposes. Our cookies are limited to operational, security, and analytics functions directly related to improving your experience on pos4t.

11. Your Data Rights

As a User of the pos4t Platform, you hold the following rights with respect to your personal data. To exercise any of these rights, please contact our Data Protection team using the details in Section 15.

• Right of access: You may request a copy of all personal data we hold about you, along with information about how it is being processed.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it promptly.
• 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 our legal retention obligations described in Section 8.
• Right to restriction of processing: You may request that we temporarily suspend processing of your data while a dispute about its accuracy or lawfulness is resolved.
• Right to data portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to object to marketing: You may opt out of marketing communications at any time by contacting support or using the unsubscribe mechanism in any marketing email we send you.

We will respond to all valid data rights requests within 30 calendar days of receipt. In complex cases, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

12. Children's Privacy

The pos4t Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect personal data from anyone under the age of 21. If we become aware that an account belongs to a User who is under 21 years of age, we will immediately suspend that account, void any pending transactions, and delete all associated personal data from our systems. If you believe that a minor has registered an account on pos4t, please contact our support team immediately so we can take swift corrective action.

13. International Data Transfers

pos4t is an internationally operated platform. Your personal data may be processed and stored on servers located outside Indonesia, including in countries whose data protection laws may differ from those of Indonesia. Where personal data is transferred internationally, pos4t ensures that appropriate safeguards are in place — including standard contractual clauses, data processing agreements with certified third parties, and transfers only to jurisdictions with adequate levels of data protection recognized by applicable regulatory standards. By using the pos4t Platform, you consent to the transfer of your personal data to the countries in which we and our service providers operate, subject to the protections described in this Policy.

14. Changes to This Privacy Policy

pos4t reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data practices, applicable laws, or Platform features. When we make material changes, we will update the "Last Reviewed" date at the top of this page and, where appropriate, notify registered Users by email or through a prominent notice on the Platform. We encourage you to review this Policy periodically to stay informed about how we protect your data. Your continued use of the Platform after changes have been posted constitutes your acknowledgment and acceptance of the revised Privacy Policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or the way pos4t processes your personal data, please contact our Data Protection team through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 directly on the pos4t Website
• WhatsApp: Contact details are available on the Website

Our Data Protection team is committed to addressing all privacy inquiries promptly and transparently. We aim to acknowledge every request within 3 business days and to provide a substantive response within 30 calendar days.