Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is published by pos4d ("pos4d", "we", "us", "our"), the operator of the online gaming platform accessible at https://pos4d.lat (the "Platform"). This Policy describes how pos4d collects, uses, discloses, stores, and protects personal data provided by or obtained from individuals ("you", "your", "User", "Player") who access or use the Platform, or who otherwise interact with pos4d in connection with the services offered thereon.

pos4d is committed to handling all personal data responsibly and in accordance with applicable data protection legislation, including the Personal Data Protection Act 2010 of Malaysia (PDPA 2010) and such other applicable international data protection standards as may govern our operations based on the jurisdictions we serve.

By registering an account on pos4d or by otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with the terms of this Policy, you should not use the Platform.

2 Definitions

For the purposes of this Policy, the following terms shall carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, financial information, and online identifiers such as IP addresses.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, erasure, or destruction.
• "Data Controller" means pos4d, in its capacity as the entity that determines the purposes and means of Processing Personal Data.
• "Data Processor" means any third party engaged by pos4d to process Personal Data on its behalf and under its instructions.
• "Sensitive Personal Data" means Personal Data that includes information pertaining to health, financial circumstances, biometric data, or any other category designated as sensitive under applicable law.
• "Cookies" means small text files placed on a User's device by the Platform for the purpose of storing preferences, session data, and analytics information.
• "KYC Data" means identity verification documentation submitted by a Player as part of the Know Your Customer compliance process, including government-issued identification and proof of address.
• "PDPA 2010" means the Personal Data Protection Act 2010 of Malaysia, as amended from time to time.

3 Categories of Personal Data We Collect

pos4d collects the following categories of Personal Data from Players and Platform users:

pos4d does not intentionally collect Sensitive Personal Data unless required for regulatory compliance purposes (such as health-related information provided voluntarily in the context of a responsible gambling self-exclusion request). Where such data is collected, it is processed only to the extent strictly necessary and with appropriate safeguards in place.

4 How We Collect Your Data

pos4d collects Personal Data through the following channels and mechanisms:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making a deposit via FPX, DuitNow, Maybank, CIMB, Public Bank, or cryptocurrency channels, contacting our support team, or submitting a complaint.
• Automated Technologies: Data collected automatically when you access and navigate the Platform, including through cookies, server logs, session tracking tools, and device fingerprinting systems used for fraud prevention.
• Third-Party Verification Services: Identity and address verification data obtained from KYC and AML screening service providers engaged by pos4d to fulfil its compliance obligations.
• Payment Processing Partners: Transaction-related data received from payment processors, banking institutions, and electronic money service providers in connection with deposit and withdrawal operations.
• Publicly Available Sources: In limited circumstances, pos4d may supplement account data with information from publicly available sources for the purposes of fraud prevention and AML screening.

5 Purpose of Processing & Legal Basis

pos4d processes Personal Data for the following purposes, each supported by an appropriate legal basis:

• Account Registration and Management: Processing is necessary for the performance of the contract between pos4d and the Player. We use Identity and Contact Data to create and maintain your Account, authenticate your identity on login, and communicate essential account-related information.
• Financial Transactions: Processing is necessary for the performance of the contract and to comply with legal obligations. Financial Data is used to process deposits and withdrawals via supported Malaysian payment methods including DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, Touch 'n Go eWallet, Boost, GrabPay, and supported cryptocurrency networks.
• Regulatory and Legal Compliance: Processing is required by applicable law. KYC, AML, and identity verification data is processed to satisfy pos4d's obligations under applicable gaming licensing conditions and anti-money laundering regulations.
• Fraud Prevention and Platform Security: Processing is necessary for the purposes of pos4d's legitimate interests in maintaining a secure and fair Platform. Technical and Usage Data are analysed to detect and prevent fraudulent activity, account compromise, and abuse.
• Customer Support and Dispute Resolution: Processing is necessary for the performance of the contract and pos4d's legitimate interests in resolving complaints efficiently. Communication Data is retained and used to investigate and respond to support enquiries and formal complaints.
• Responsible Gambling Monitoring: Processing is necessary to comply with regulatory obligations and to protect Player welfare. Usage and Compliance Data are used to monitor for indicators of problem gambling and to enforce self-exclusion and deposit limit arrangements activated by Players.
• Marketing Communications: Where you have given your explicit consent, pos4d may contact you with promotional offers, bonuses, and platform updates via email or in-platform notifications. You may withdraw consent at any time by updating your communication preferences within your Account settings.

6 Disclosure & Data Sharing

pos4d does not sell, rent, or trade Personal Data to third parties for their own commercial purposes. We may disclose Personal Data to the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Service Providers: Banks and electronic payment operators (including FPX system participants, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, and cryptocurrency payment processors) require limited financial and identity data to execute deposit and withdrawal transactions.
• KYC and AML Compliance Providers: Third-party identity verification and screening services engaged by pos4d to fulfil Know Your Customer and anti-money laundering obligations.
• Technology and Infrastructure Partners: Cloud hosting providers, cybersecurity vendors, and platform software providers engaged to operate, maintain, and secure the Platform under binding data processing agreements.
• Regulatory Authorities: pos4d may be required by law or by a competent regulatory, judicial, or law enforcement authority to disclose Personal Data. In such cases, pos4d will disclose only what is legally required and, where permissible, will notify the affected Player.
• Professional Advisers: Lawyers, auditors, and other professional advisers retained by pos4d may access limited Personal Data in connection with the provision of their services, subject to applicable professional confidentiality obligations.

All third parties to whom pos4d discloses Personal Data are required to handle such data in accordance with applicable data protection standards. Where pos4d engages a third party as a Data Processor, a written data processing agreement is put in place governing the scope, nature, and purpose of the processing.

7 International Data Transfers

pos4d's primary data infrastructure is hosted within data centres that maintain internationally recognised security certifications. In the course of operating the Platform and engaging service providers, Personal Data may be transferred to or processed in jurisdictions outside Malaysia. Where such transfers occur, pos4d ensures that appropriate safeguards are in place to protect the Personal Data, including:

• Transfers to jurisdictions with an adequate level of data protection as recognised by applicable law;
• Implementation of standard contractual clauses or equivalent binding data transfer mechanisms with the receiving entity;
• Ensuring that third-party processors receiving transferred data are contractually bound to data protection standards equivalent to those applied by pos4d.

Players who have questions about specific international transfer arrangements applicable to their data may contact pos4d's Data Protection team using the details provided in the Contact Us section of this Policy.

8 Data Retention

pos4d retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, to maintain your Account, and to comply with applicable legal and regulatory obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of the Player's account relationship with pos4d, plus a period of not less than five (5) years following Account closure, in accordance with applicable AML and gaming regulatory requirements.
• KYC and Identity Data: Retained for a minimum of five (5) years from the date of last transaction or Account closure, as required by applicable AML regulations.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Support and Communication Records: Retained for a period of three (3) years from the date of the relevant communication, or longer if required for ongoing dispute resolution.
• Marketing Consent Records: Retained for as long as a marketing relationship is maintained and for a reasonable period thereafter as evidence of consent.

Upon expiry of the applicable retention period, Personal Data is securely deleted, anonymised, or de-identified in a manner that prevents re-identification of the data subject.

9 Security Measures

pos4d implements and maintains a comprehensive range of technical and organisational security measures designed to protect Personal Data against unauthorised access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• Encryption: All data transmitted between the Player's browser and the Platform is encrypted using TLS 1.3 (256-bit SSL encryption). Personal Data stored at rest is encrypted using industry-standard encryption algorithms.
• Access Controls: Access to Personal Data within pos4d's systems is restricted on a strict need-to-know basis. Staff members with access to Personal Data are subject to confidentiality obligations and undergo regular data protection training.
• Two-Factor Authentication: pos4d offers two-factor authentication (2FA) to all registered Players as an additional layer of Account security. Players are strongly encouraged to enable this feature.
• Fraud and Intrusion Detection: Real-time monitoring systems are deployed to detect and respond to suspicious activity, attempted intrusions, and abnormal data access patterns.
• Regular Security Assessments: pos4d conducts periodic security assessments, vulnerability scans, and where appropriate, independent penetration testing to identify and remediate potential security weaknesses.

10 Cookies & Tracking Technologies

pos4d uses cookies and similar tracking technologies on the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly and cannot be disabled. They include session management cookies that keep you logged in during a gaming session, and security cookies used for fraud prevention and platform integrity.
• Functional Cookies: These cookies remember your preferences and settings (such as language preference and display options) to provide a more personalised experience on subsequent visits.
• Analytics Cookies: These cookies collect aggregated, anonymised information about how Players use the Platform — such as which pages are visited most frequently and how users navigate between sections. This data is used solely to improve Platform performance and user experience.
• Security and Fraud Prevention Cookies: These cookies assist pos4d in detecting and preventing fraudulent activity, account takeover attempts, and other forms of platform abuse by analysing device characteristics and session behaviour.

You may manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the functionality of the Platform. Strictly Necessary Cookies cannot be disabled as they are required for the Platform to operate.

11 Your Data Protection Rights

Subject to applicable law and certain exemptions, you have the following rights in relation to your Personal Data held by pos4d. To exercise any of these rights, please contact our Data Protection team using the details in the Contact Us section below.

pos4d will respond to all verified data subject requests within thirty (30) days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

12 Minors & Age Restriction

The pos4d Platform is strictly intended for use by individuals who are 21 years of age or older. pos4d does not knowingly collect Personal Data from persons under the age of 21. The collection of Personal Data from minors is strictly prohibited under our Terms & Conditions and this Policy.

Where pos4d becomes aware that Personal Data has been collected from a person under the age of 21 — whether through the registration process, KYC review, or any other means — the relevant Account will be immediately closed, all Personal Data collected will be deleted or securely disposed of to the extent permissible by law, and any funds deposited will be returned to their source.

pos4d employs age verification checks as part of its registration and KYC processes specifically to prevent underage individuals from accessing the Platform. If you believe that a minor has registered an Account on pos4d, please contact us immediately at the email address in the Contact Us section below.

13 Third-Party Services & Links

The Platform may contain references to or integrations with third-party services, including payment gateways operated by Maybank, CIMB, Public Bank, Hong Leong, FPX network participants, DuitNow infrastructure operators, and electronic money service providers including Touch 'n Go eWallet, Boost, and GrabPay. Where you interact with these third-party services, your Personal Data may be subject to the privacy policies of those third parties.

pos4d is not responsible for the privacy practices of third-party service providers. We encourage you to review the privacy policies of any third-party services you use in connection with the Platform. pos4d's obligations under this Policy extend only to data processed by or on behalf of pos4d directly.

14 Changes to This Privacy Policy

pos4d reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services we offer. Where changes are material, pos4d will endeavour to provide advance notice by email to registered Players or by prominent notice on the Platform prior to the updated Policy taking effect.

The effective date of the current version of this Policy is shown at the top of this page. Players are encouraged to review this Policy periodically. Continued use of the Platform following publication of an updated Policy constitutes acceptance of the revised terms.

15 Contact Us

If you have any questions, concerns, or requests in relation to this Privacy Policy or the processing of your Personal Data by pos4d, please contact our Data Protection team through the following channels:

• Email: [email protected] — please use the subject line "Privacy Enquiry — [Your Username]" for all data protection-related correspondence.
• Live Chat: Available 24/7 directly on the Platform. Our agents can direct your query to the appropriate Data Protection team member where necessary.
• Response Time: We aim to acknowledge all data protection enquiries within two (2) business days and to provide a substantive response within thirty (30) days.

Players located in Malaysia who are dissatisfied with pos4d's handling of a data protection concern may also contact the relevant national data protection supervisory authority, being the Department of Personal Data Protection (Jabatan Perlindungan Data Peribadi — JPDP) of Malaysia.