Privacy Policy

1 Definitions

The following definitions apply throughout this Privacy Policy:

• "cod4d", "We", "Us", "Our" — the international gaming operator that owns and operates the cod4d platform at https://cod4d.org.
• "You", "Player", "User" — any individual who visits, registers, or uses services on the cod4d platform.
• "Personal Data" — any information that identifies or could reasonably be used to identify a natural person, including name, date of birth, email address, phone number, payment details, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, or deletion.
• "Platform" — the cod4d website, mobile-optimised interface, and all related digital services accessible at https://cod4d.org.
• "KYC" — Know Your Customer; the identity and age verification procedures required of players under applicable compliance frameworks.
• "Third-Party Service Provider" — any external company engaged by cod4d to provide services that may involve access to Personal Data, including payment processors, identity verification agencies, fraud detection services, and licensed game studios.
• "Cookies" — small text files placed on your device by the Platform to enable functionality, remember preferences, and gather analytics data.

2 Scope & Application

2.1 This Privacy Policy applies to all Personal Data collected and processed by cod4d in connection with your use of the Platform, regardless of whether you are a registered player or a visitor who has not yet created an account.

2.2 This Policy is directed at players residing in Indonesia. It reflects cod4d's commitment to handling player data responsibly in accordance with internationally recognised data protection principles.

2.3 This Privacy Policy should be read alongside our Terms & Conditions, which govern your use of the Platform more broadly. By accessing the Platform or registering an account, you acknowledge that you have read and understood this Privacy Policy.

2.4 This Policy does not apply to third-party websites or services that may be referenced or linked from the Platform. cod4d is not responsible for the privacy practices of any third party.

3 Data We Collect

3.1 cod4d collects only the Personal Data necessary to operate the Platform, verify player identities, process transactions, and meet our legal and compliance obligations. The categories of data we collect are set out in the table below.

3.2 cod4d does not collect sensitive categories of personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where identity photographs are submitted as part of a KYC document verification process.

4 How We Collect Data

cod4d collects Personal Data through the following means:

• Direct Submission: Data you voluntarily provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or entering a promotion.
• Automated Technical Collection: Data collected automatically when you access the Platform, including IP addresses, device identifiers, browser fingerprints, and session activity logs, via server logs and analytics tools.
• Cookies and Similar Technologies: Preference and analytics data collected via cookies, web beacons, and local storage as described in Clause 10.
• Third-Party Verification Partners: Identity data returned by licensed KYC and fraud-screening agencies where you have consented to verification checks as part of the account registration or withdrawal process.
• Payment Processors: Transaction confirmation data returned by payment partners (including local Indonesian bank transfer gateways and e-wallet providers) necessary to reconcile your account balance.

5 Purpose & Legal Basis for Processing

5.1 Contract Performance. The majority of data processing on the Platform is necessary for the performance of the contract between you and cod4d — specifically, the provision of gaming services, processing of IDR deposits and withdrawals, management of your account balance, and resolution of disputes.

5.2 Legal Obligation. Certain data processing activities are required by law or regulatory obligation, including the retention of transaction records, the performance of KYC identity checks, the maintenance of responsible gaming records, and the reporting of suspicious activity to competent authorities.

5.3 Legitimate Interests. cod4d processes Technical Data and Communication Data on the basis of its legitimate interests in operating a secure, fair, and commercially sustainable gaming platform. These interests include fraud prevention, platform security, service quality monitoring, and responsible gaming compliance. We balance these interests against your privacy rights and will not use this basis where your interests override ours.

5.4 Consent. Where cod4d processes your data for purposes beyond those described above — such as sending promotional communications about new games, seasonal offers, or platform updates — we rely on your freely given, specific, and informed consent. You may withdraw this consent at any time by updating your communication preferences in your account settings or by contacting customer support.

6 Data Sharing & Disclosure

6.1 cod4d does not sell, rent, or share your Personal Data with third parties for their own commercial or marketing purposes. Data is shared only in the following limited circumstances:

• Payment Service Providers: Financial institutions and payment gateway operators (including local bank transfer partners and e-wallet providers such as OVO, DANA, GoPay, ShopeePay, and LinkAja) receive only the data necessary to process your specific transaction.
• Identity Verification Partners: Licensed KYC and anti-fraud agencies may receive your identity documents and associated data for the purpose of verifying your age and identity in accordance with our compliance obligations.
• Licensed Game Studios: Game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive pseudonymous player identifiers and session data necessary for the delivery and fair operation of their games. These providers are contractually prohibited from using this data for any purpose other than game delivery.
• Customer Support Platforms: Third-party tools used to deliver live chat and ticketing support may store Communication Data for quality assurance purposes, subject to confidentiality obligations.
• Legal and Regulatory Authorities: cod4d may disclose Personal Data to law enforcement, regulatory bodies, or judicial authorities where required to do so by applicable law, court order, or official request. Where permissible, we will notify you of such disclosure.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of cod4d's business, your Personal Data may be transferred to the successor entity, subject to equivalent privacy protections.

6.2 All Third-Party Service Providers who receive Personal Data from cod4d are subject to written data processing agreements that prohibit them from using your data for any purpose other than the specific service they provide to us.

7 International Data Transfers

7.1 cod4d is operated by an internationally licensed gaming entity, and your Personal Data may be transferred to and stored on servers located outside Indonesia. Where such transfers occur, cod4d ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that required under internationally recognised data protection frameworks.

7.2 Safeguards employed for international data transfers include standard contractual clauses, binding corporate rules, and transfers to jurisdictions recognised as providing adequate levels of data protection.

7.3 You may request further information about the international transfer safeguards applicable to your data by contacting us at the address set out in Clause 14.

8 Data Retention

8.1 cod4d retains Personal Data for as long as your account remains active and for a defined period thereafter, in accordance with the following retention schedule:

• Account and Identity Data: Retained for the duration of your account and for a minimum of 5 years following account closure, to satisfy regulatory record-keeping requirements.
• Financial and Transaction Data: Retained for a minimum of 5 years from the date of each transaction, in accordance with standard financial record-keeping obligations.
• Gaming Activity Data: Retained for 3 years from the date of the activity, and for longer periods where a dispute remains unresolved or where required by a regulatory body.
• Technical and Log Data: Retained for 12 months from collection, after which it is anonymised or securely deleted.
• Communication Data: Retained for 2 years from the date of the communication, or for longer where the communication is relevant to an ongoing dispute or investigation.

8.2 Upon expiry of the applicable retention period, Personal Data is either securely deleted or anonymised so that it can no longer be attributed to an identified or identifiable individual.

9 Security Measures

9.1 cod4d employs a layered, defence-in-depth security architecture to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. Key measures include:

• Encryption: AES-256 encryption for data at rest; TLS 1.3 for all data in transit between your device and our servers.
• Access Controls: Role-based access control (RBAC) ensures that only authorised personnel can access Personal Data, and only to the extent required by their specific job function.
• Two-Factor Authentication: Player accounts support two-factor authentication (2FA) to reduce the risk of unauthorised access resulting from compromised credentials.
• Intrusion Detection: Automated intrusion detection and prevention systems monitor platform traffic in real time to identify and respond to anomalous access patterns.
• Penetration Testing: cod4d conducts regular third-party security assessments and penetration tests to identify and remediate potential vulnerabilities before they can be exploited.
• Data Breach Response: A documented incident response plan is in place to ensure rapid detection, containment, and notification in the event of a personal data breach.

9.2 While cod4d takes all reasonable steps to protect your data, no digital platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and should contact us immediately if you suspect any unauthorised access to your account.

10 Cookies & Tracking Technologies

10.1 The cod4d Platform uses cookies and similar tracking technologies to enhance your browsing experience, maintain your session, and gather analytics data that helps us improve the Platform. The categories of cookies we use are described below:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session management cookies that keep you logged in during your visit and security cookies that protect against cross-site request forgery. These cookies cannot be disabled without significantly impairing Platform functionality.
• Functional Cookies: Remember your preferences, such as your selected language and responsible gaming limit settings, so that they persist across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform — including pages visited, time on page, and navigation paths — to help us understand usage patterns and improve the player experience. These cookies do not identify you personally.
• Performance Cookies: Monitor Platform performance metrics such as page load times and error rates to support our technical operations team in maintaining service quality.

10.2 cod4d does not use third-party advertising or retargeting cookies. We do not permit third-party ad networks to place tracking cookies on the Platform.

10.3 You may manage your cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies may prevent you from accessing certain areas of the Platform or using certain features. Disabling analytics and functional cookies will not prevent you from using the core gaming services.

11 Your Rights Over Your Personal Data

11.1 As a registered player on the cod4d platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, contact our support team using the details in Clause 14. We will respond to all valid requests within 30 days.

• Right of Access: You may request a copy of all Personal Data we hold about you, along with information about how it is processed and the legal basis for its processing.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• 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, where you withdraw consent (where consent was the legal basis), or where you object to processing and there are no overriding legitimate grounds. Note that regulatory retention obligations (Clause 8) may prevent full erasure in certain cases.
• Right to Restriction of Processing: You may request that we limit our processing of your data in certain circumstances — for example, while a dispute about the accuracy of your data is being resolved.
• Right to Data Portability: Where processing is based on your consent or on contract performance, you may request that we provide your data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

11.2 cod4d will not charge a fee for responding to data rights requests, except in cases where requests are manifestly unfounded or excessive, in which case a reasonable administrative fee may be applied.

12 Minors

12.1 The cod4d Platform is strictly intended for adults aged 21 and over. We do not knowingly collect Personal Data from individuals under the age of 21. If we become aware that an account has been registered by or on behalf of a minor, we will immediately suspend the account, delete the associated Personal Data to the extent permissible by law, and report the matter to our compliance team.

12.2 If you are a parent or guardian and believe that a minor in your care has registered an account on the Platform, please contact us immediately using the details in Clause 14. We will act swiftly to investigate and close any such account.

13 Changes to This Privacy Policy

13.1 cod4d reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, Platform features, or applicable legal requirements. Material changes will be communicated to registered players via a notice displayed prominently on the Platform or sent to the registered email address on file, with a minimum of 7 days' notice before the revised policy takes effect.

13.2 The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically. Your continued use of the Platform following the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms.

13.3 If you do not agree to the revised Privacy Policy, you should cease using the Platform and may request account closure in accordance with the Terms & Conditions.

14 Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or the way cod4d handles your Personal Data, please contact our dedicated privacy support team through any of the following channels:

For responsible gaming concerns — including self-exclusion requests, deposit limit queries, or problem gambling support — please visit our Responsible Gaming page, where a full suite of player-protection tools is available.

For a full understanding of your rights and obligations as a cod4d player, please also read our Terms & Conditions and visit our FAQ page for answers to the most common questions.