Sistem4D Privacy Policy —
Your Data, Your Rights

Sistem4D ("we", "us", "the Platform", or "Sistem4D") operates the online betting and gaming platform accessible at sistem4d.cam. This Privacy Policy ("Policy") sets out how Sistem4D collects, uses, discloses, stores, and protects the personal data of users ("you", "the user", "the player") who access or use the Platform.

This Policy applies to all personal data processed in connection with your use of the Sistem4D Platform, including data collected during account registration, KYC verification, deposits and withdrawals, customer support interactions, and general Platform usage. It should be read alongside our Terms & Conditions and Responsible Gambling Policy.

By registering an account on the Sistem4D Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not create an account or use the Platform.

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that relates to an identified or identifiable natural person, including but not limited to name, email address, phone number, date of birth, and payment details.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" means Sistem4D, the entity that determines the purposes and means of processing personal data.
• "Data Processor" means any third party that processes personal data on behalf of Sistem4D under a data processing agreement.
• "KYC" means Know Your Customer — the identity verification process required by regulatory obligations before a user may withdraw funds.
• "Cookies" means small text files placed on your device when you visit the Platform, used to enhance functionality and user experience.
• "Consent" means any freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data.

Sistem4D collects the following categories of personal data in connection with the operation of the Platform:

We do not intentionally collect sensitive personal data such as racial or ethnic origin, religious beliefs, or health information, except where required for responsible gambling assessments at a player's request.

Sistem4D collects personal data through the following means:

• Direct interactions: Data you provide when creating an account, submitting KYC documents, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Data collected automatically when you use the Platform, including via cookies, log files, and analytics scripts;
• Third-party payment processors: Transaction confirmation data received from payment providers including Touch'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, and USDT TRC20 gateway operators;
• Identity verification services: Data received from KYC and fraud-prevention service providers engaged to verify identity documents;
• Publicly available sources: In limited circumstances, information from public registries or databases may be used to supplement identity verification or fraud screening processes.

Sistem4D processes your personal data on the following legal bases:

• Contractual necessity: Processing required to create and operate your Account, process transactions, and provide Platform services as described in our Terms & Conditions;
• Legal obligation: Processing required to comply with applicable anti-money laundering (AML) regulations, KYC obligations, and gambling regulatory requirements, including the retention of transaction records;
• Legitimate interests: Processing carried out to detect and prevent fraud, maintain platform security, improve our services, and manage responsible gambling obligations — where these interests are not overridden by your privacy rights;
• Consent: Where processing is based on your freely given consent, such as for marketing communications, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

Sistem4D uses the personal data we hold about you for the following purposes:

• To create, maintain, and administer your Account, including processing login authentication;
• To process deposits and withdrawals, verify payment method ownership, and maintain accurate financial records in MYR;
• To conduct KYC and age verification in compliance with our regulatory obligations — this applies to all players regardless of location within Malaysia;
• To detect, investigate, and prevent fraudulent transactions, unauthorised account access, money laundering, and other forms of prohibited conduct as defined in our Terms & Conditions;
• To personalise your Platform experience, including game recommendations and eligible promotion notifications;
• To send account-related communications, including transaction confirmations, security alerts, policy update notifications, and responses to support queries;
• To assess and manage responsible gambling concerns, including applying deposit limits, session limits, or self-exclusion measures where requested or required;
• To improve the Platform's technical performance, user interface, and game offering through analytics and usage data review.

Sistem4D does not sell, rent, or trade your personal data to third parties for their own commercial or marketing purposes. We share your personal data only in the following limited circumstances:

• Payment service providers: To process deposits and withdrawals, we share necessary transaction data with payment processors including Touch 'n Go, Boost, GrabPay, DuitNow, FPX member banks (Maybank, CIMB, Public Bank, Hong Leong Bank), and USDT TRC20 gateway operators. These parties act as Data Processors under contractual obligations;
• Identity verification providers: KYC document data is shared with regulated identity verification service providers solely for the purpose of verifying your identity and age;
• Fraud prevention and AML services: Data may be shared with fraud detection, anti-money laundering screening, and responsible gambling monitoring services as required by our operating obligations;
• Legal and regulatory authorities: We may disclose personal data to government authorities, regulators, or law enforcement agencies where required by applicable law, court order, or gaming regulation;
• Platform technology providers: Technical service providers (hosting, security, analytics) may process limited data on our behalf under strict data processing agreements;
• Business transfers: In the event of a merger, acquisition, or sale of assets involving Sistem4D, user data may be transferred as part of that transaction, subject to equivalent privacy protections.

Sistem4D uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit sistem4d.cam. They allow the Platform to remember your preferences, maintain your session, and gather anonymised usage analytics.

We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function — including session management, login authentication, and security tokens. These cannot be disabled without affecting Platform functionality;
• Functional Cookies: Remember your preferences such as language settings, currency display (MYR), and previous session data to improve your experience;
• Analytics Cookies: Collect anonymised data about how users navigate the Platform, which pages are most visited, and where errors occur. This data is used to improve Platform performance;
• Marketing Cookies: Used where consent has been given to track interactions with promotional content and measure campaign effectiveness. These are optional and may be declined.

You may manage or withdraw your cookie preferences at any time through your browser settings. Please note that disabling certain cookie categories may affect Platform functionality.

Sistem4D retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable regulatory and legal obligations. Our general retention periods are as follows:

• Account data and KYC records: Retained for a minimum of five (5) years following account closure, in line with standard AML record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years following each transaction date;
• Customer support communications: Retained for two (2) years following the resolution of the relevant query;
• Technical and usage data: Retained in anonymised or aggregated form for up to three (3) years for analytics purposes;
• Marketing consent records: Retained until consent is withdrawn and for one (1) year thereafter as an audit record.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be attributed to an identified individual.

Sistem4D implements the following security controls to protect your personal data:

• AES-256 encryption for all stored personal and financial data;
• TLS 1.3 encryption for all data transmitted between user devices and Sistem4D servers;
• Role-based access controls ensuring that personal data is accessible only to authorised staff with a legitimate operational need;
• Full access audit logging for all administrative interactions with personal data systems;
• Regular vulnerability assessments and penetration testing of Platform infrastructure;
• Two-factor authentication available to users to protect Account access.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, Sistem4D will notify affected users without undue delay and take immediate remedial action.

Subject to applicable law and any overiding regulatory obligations, you have the following rights in respect of your personal data held by Sistem4D:

• Right of Access: You may request a copy of the personal data Sistem4D holds about you at any time;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held about you;
• Right to Erasure: 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;
• Right to Restrict Processing: You may request that we limit the way we use your data in certain circumstances — for example, while a rectification request is being assessed;
• Right to Data Portability: You may request a structured, machine-readable copy of personal data you have provided to us, for transfer to another service provider;
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling for marketing purposes;
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact Sistem4D's support team via Live Chat or by email to [email protected]. We will respond to all data rights requests within thirty (30) calendar days of receipt. Where a request is complex or numerous, we may extend this period by a further sixty (60) days with prior notice.

If Sistem4D becomes aware that personal data has been submitted by an individual who is under 21 years of age, that data will be deleted immediately and the associated Account closed. Parents or guardians who believe their child may have registered on the Platform should contact our support team immediately so that the Account can be investigated and closed without delay.

Sistem4D reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or Platform operations. The "Last Updated" date at the top of this document will be revised accordingly following each material change.

Where a change is material — meaning it significantly affects how we use your personal data or your rights in relation to it — we will notify registered users via their registered email address no less than fourteen (14) days before the change takes effect. Your continued use of the Platform following the effective date of an amendment constitutes acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how Sistem4D protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way Sistem4D handles your personal data, please contact us through the following channels:

• Live Chat: Available24/7 via the Platform — our fastest channel, with an average response time under five minutes;
• Email: [email protected] — for formal data rights requests and privacy inquiries, with responses within 12–24 hours for general queries and within 30 days for formal data rights requests;
• Languages: Support is available in English, Bahasa Melayu, and Mandarin — serving players across Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and all regions of Malaysia.

All formal data subject access requests, rectification requests, and erasure requests should be submitted in writing via email and will be handled in accordance with Section 11 of this Policy.