Privacy Policy — pp444

1 Overview & Scope

This Privacy Policy applies to all personal data processed by pp444 in connection with the operation of the platform accessible at https://pp444.lat (the "Platform"). It covers data collected through account registration, gameplay, deposits and withdrawals, customer support interactions, marketing communications, and your general browsing of the Platform.

This policy applies to all Players, prospective Players, and visitors who interact with the Platform, regardless of the device or browser used. It should be read together with our Terms & Conditions and Responsible Gaming policy, both of which form part of your agreement with pp444.

pp444 targets Players located in Indonesia. All natural-language content on this Platform is presented in English, consistent with the preferences of our international-brand-preference user base. Personal data is processed in accordance with internationally recognized data protection principles, including purpose limitation, data minimization, storage limitation, integrity, and confidentiality.

This policy does not apply to third-party websites, payment processors, or game studios that may be linked to or integrated within the Platform. Those parties operate under their own privacy policies, and pp444 encourages you to review those documents independently.

2 Data Controller

pp444 acts as the Data Controller in respect of all personal data collected through the Platform. As Data Controller, pp444 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection law and the principles set out in this policy.

For all data protection enquiries, rights requests, or complaints, Players may contact our designated Data Protection contact via the support channels described in Section 15 of this policy. pp444 aims to acknowledge all data-related requests within 5 business days (WIB, UTC+7) and to resolve them within 30 calendar days.

Where pp444 engages third-party service providers to process data on its behalf — such as payment processors, KYC verification vendors, and cloud infrastructure providers — those parties act as Data Processors and are bound by contractual obligations that restrict their use of your data to the specific purposes for which it was shared.

3 Data We Collect

pp444 collects the minimum personal data necessary to operate the Platform safely, legally, and in the interests of all Players. The categories of data we collect, and the primary source of each, are set out in the table below:

pp444 does not collect or process sensitive special-category data (such as racial or ethnic origin, religious beliefs, health data, or political opinions) except where strictly necessary for responsible gaming purposes — for example, recording a self-exclusion request or processing a gambling disorder declaration — and only with your explicit consent.

4 How We Use Your Data

pp444 processes personal data only for specific, legitimate purposes. The table below maps each processing purpose to the category of data used and the lawful basis on which we rely (see Section 5 for a full explanation of legal bases):

pp444 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent. Where we intend to use your data for a materially new purpose, we will notify you in advance and provide you with the opportunity to object.

5 Legal Basis for Processing

For each processing activity, pp444 relies on one or more of the following legal bases:

• Contractual Necessity: Processing required to enter into or perform the contract between you and pp444 — including account registration, payment processing, and game provision. Without this processing, pp444 cannot provide the services described in the Terms & Conditions.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC verification, AML screening, and the maintenance of transaction records.
• Legitimate Interests: Processing that serves pp444's legitimate business interests where those interests are not overridden by your data protection rights — for example, fraud detection, platform security monitoring, responsible gaming analytics, and internal audit functions.
• Consent: Processing carried out on the basis of your freely given, specific, and informed consent — primarily for marketing communications and for the collection of any special-category data referenced in Section 3. You may withdraw your consent at any time by contacting our support team or updating your Account settings. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6 Data Sharing & Disclosure

pp444 does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Your data may be shared only in the following limited circumstances:

• Payment Service Providers: Financial data is shared with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) to the extent necessary to process deposits and withdrawals. These parties act as independent controllers for the purpose of executing payment instructions.
• KYC & Identity Verification Vendors: Identity and verification data is shared with licensed third-party KYC providers to facilitate age verification and document authentication in compliance with our licensing obligations.
• Game Studio Providers: A session token and the minimum necessary account identifiers may be shared with third-party game studios (such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Pocket Games Soft, and Spribe) to initialize and authenticate game sessions. These studios do not receive your full profile, financial data, or contact details.
• Cloud & Infrastructure Providers: Technical and gaming data is stored and processed on secure cloud infrastructure. All cloud providers engaged by pp444 are contractually required to process data only on pp444's instructions and to maintain security standards equivalent to those described in Section 8.
• Regulatory Authorities: pp444 may be required by law, court order, or regulatory instruction to disclose personal data to competent authorities. In such cases, pp444 will disclose only the minimum data required to comply with the legal obligation and, where permitted, will notify the affected Player of the disclosure.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of pp444's business, personal data held by pp444 may be transferred to the acquiring entity, subject to equivalent data protection obligations being contractually imposed on the acquirer.

7 Data Retention

pp444 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with applicable legal and regulatory obligations, and to resolve any disputes that may arise. The following retention periods apply as a general guide:

• Account and Identity Data: Retained for the duration of the active Account relationship and for a minimum of 5 years following Account closure, in compliance with AML and licensing record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of 5 years from the date of each transaction in IDR, in accordance with standard financial record-keeping obligations.
• KYC Verification Documents: Retained for the duration of the Account relationship and for 5 years following Account closure or the last transaction, whichever is later.
• Customer Support Communications: Retained for 2 years from the date of the last communication in each support thread, unless the matter relates to an active dispute or legal claim.
• Marketing Preferences and Consent Records: Retained for the duration of the Account relationship and for 3 years following Account closure or withdrawal of consent, to demonstrate compliance with consent obligations.
• Technical and Log Data: Retained for 12 months from the date of collection, after which it is either deleted or anonymized for aggregate analytics purposes.

At the end of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected until secure deletion is possible.

8 Security Measures

pp444 implements a comprehensive suite of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Key measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the pp444 Platform is encrypted using industry-standard TLS 1.2 or higher. No personal or financial data is ever transmitted in plain text.
• Encryption at Rest: Sensitive data — including identity documents, financial records, and KYC materials — is encrypted at rest using AES-256 encryption on all storage systems.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All pp444 staff with data access are subject to confidentiality obligations and receive regular data protection training.
• Multi-Factor Authentication: Administrative access to systems holding personal data requires multi-factor authentication. Players are also strongly encouraged to enable any available 2FA options on their Account.
• Intrusion Detection and Monitoring: pp444 employs continuous network monitoring and intrusion detection systems to identify and respond to anomalous activity in real time.
• Penetration Testing: pp444 conducts regular independent security assessments, including penetration testing and vulnerability scanning, to identify and remediate potential weaknesses.
• Incident Response: pp444 maintains a documented data breach response plan. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pp444 will notify affected Players without undue delay.

9 Cookies & Tracking Technologies

pp444 uses cookies and similar tracking technologies to operate the Platform, improve user experience, analyze traffic patterns, and deliver relevant content. The following categories of cookies are used:

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies; however, disabling Strictly Necessary cookies will impair your ability to log in and use core Platform features. Disabling Functional cookies may reset your preferences on each visit. Instructions for managing cookies are available in your browser's help documentation.

pp444 does not use cookies to track your activity on third-party websites beyond the pp444 domain. No third-party advertising networks are granted access to cookie data collected on the Platform.

10 Your Data Rights

As a Player whose data is processed by pp444, you hold the following rights in respect of your personal information. pp444 is committed to facilitating the exercise of these rights without undue delay and at no cost to you:

To exercise any of the above rights, please contact our support team in writing via the channels described in Section 15. pp444 may need to verify your identity before processing a rights request. We will respond within 30 calendar days; where a request is complex or numerous, we may extend this period by a further 30 days and will notify you accordingly.

Note that certain rights are subject to limitations under applicable law. In particular, the right to erasure does not apply where pp444 is required to retain data to comply with a legal obligation (such as AML record-keeping) or to establish, exercise, or defend legal claims.

11 Protection of Minors

pp444 implements mandatory age verification as part of the KYC process. Any Account found to belong to a person under the age of 21 will be immediately suspended. Any funds in such an Account will be returned to the payment method from which they originated, net of any winnings, which will be forfeited. All personal data associated with an underage Account will be securely deleted upon confirmation of the individual's age, except where retention is required to document the incident for compliance purposes.

If you are a parent or guardian and believe that a person under your care has created an Account on pp444, please contact our support team immediately at the address in Section 15. We will investigate and take all appropriate action within 24 hours of your report.

pp444 also encourages the use of parental control software for households where minors may have unsupervised access to internet-connected devices. Tools such as Net Nanny, Kaspersky Safe Kids, and similar applications can assist in restricting access to gambling websites.

12 Cross-Border Data Transfers

pp444 operates infrastructure and engages service providers that may process personal data in jurisdictions outside Indonesia. Where personal data is transferred outside Indonesia, pp444 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections afforded under applicable data protection law.

Safeguards used for cross-border transfers include:

• Contractual clauses that impose data protection obligations on the recipient party equivalent to those applicable under internationally recognized standards.
• Transfers only to jurisdictions or service providers that maintain recognized data protection frameworks and security certifications (such as ISO 27001).
• Data minimization — only the minimum data necessary for the specific cross-border processing purpose is transferred.

Where you request information about the specific safeguards applied to any cross-border transfer of your personal data, you may do so by contacting our Data Protection contact as described in Section 15.

13 Marketing Communications

pp444 may send you promotional communications about bonuses, new game releases, seasonal promotions (such as Idul Fitri offers or Chinese New Year / Imlek specials), and platform updates where you have given your consent to receive such communications during registration or through your Account settings.

You can opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link in any marketing email sent by pp444.
• Updating your marketing preferences in the "Account Settings" section of the Platform.
• Contacting our support team in writing and requesting removal from all marketing lists.

Opt-out requests are processed within 5 business days (WIB, UTC+7). Please note that opting out of marketing communications will not affect the delivery of transactional or service-related messages, such as deposit confirmations, withdrawal notifications, KYC requests, and security alerts — these communications are sent on the basis of contractual necessity and cannot be disabled while your Account remains active.

pp444 does not engage in unsolicited cold-calling, SMS spam, or any other intrusive marketing practice. All marketing communications identify pp444 as the sender and provide a clear and accessible opt-out mechanism.

14 Policy Amendments

pp444 reserves the right to update or revise this Privacy Policy at any time. Changes may be made to reflect updates in applicable law, modifications to Platform features, new data processing activities, or improvements in our privacy practices.

Where a change is material — meaning it could reasonably be expected to affect your privacy rights or the way in which your personal data is processed — pp444 will provide at least 14 days' prior notice by publishing the updated policy on the Platform and, where practicable, notifying registered Players via email. The "Last Updated" date at the top of this document reflects the most current revision.

Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy. If you do not agree with the updated policy, you should cease using the Platform and submit an Account closure request before the effective date of the change.

We encourage all Players to review this Privacy Policy periodically to remain informed of how pp444 protects and processes their personal data. The version history of this document is available on request from our support team.

15 Contact Us

For all data protection enquiries, rights requests, complaints, or questions about this Privacy Policy, please contact pp444 through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 through the Platform, with Indonesian and English-speaking agents covering WIB (UTC+7), WITA (UTC+8), and WIT (UTC+9) time zones.
• Response Time: pp444 acknowledges all data protection requests within 5 business days (WIB, UTC+7) and aims to resolve them fully within 30 calendar days. Complex requests may require up to 60 days with prior notification.

When submitting a data rights request, please include your registered Account email address and a clear description of the right you wish to exercise. pp444 will verify your identity before processing the request to ensure that personal data is not disclosed to unauthorized parties.