Privacy Policy

1 Introduction

Pohon4D ("we", "us", "our", "the Company") operates the online betting and casino platform accessible at https://pohon4d.cam. This Privacy Policy ("Policy") governs the collection, use, storage, disclosure, and protection of personal data provided by or collected from individuals ("Members", "Users", "you") who access or use the Pohon4D platform and its associated services ("Services").

Pohon4D is committed to handling your personal data responsibly and in accordance with applicable data protection principles. This Policy is designed to be transparent about our data practices so that you can make informed decisions about sharing your personal information with us.

By registering an account, making a deposit, or otherwise using any Pohon4D Services, you acknowledge 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 any part of this Policy, you should not use the Pohon4D platform.

2 Definitions

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

• "Personal Data" means any information that identifies or could be used to identify a natural person, either directly or indirectly, including but not limited to name, identification number, contact details, financial account information, and online identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means Pohon4D, which determines the purposes and means of processing your personal data.
• "Data Processor" means any third party that processes personal data on behalf of Pohon4D under a contractual arrangement.
• "Cookies" means small data files placed on your device by a website that record information about your browsing activity for functional, analytical, or preference-based purposes.
• "KYC" (Know Your Customer) means the identity and address verification process Pohon4D is legally required to conduct before processing withdrawal requests or where enhanced due diligence is warranted.

3 Personal Data We Collect

Pohon4D collects the following categories of personal data in connection with your use of our Services:

4 How We Collect Your Data

Pohon4D collects personal data through the following channels and methods:

4.1 Information You Provide Directly

This includes data you enter when registering an account, completing your member profile, submitting a deposit or withdrawal request, undergoing KYC verification, contacting our customer support team, or responding to surveys or promotional communications.

4.2 Automatically Collected Data

When you visit the Pohon4D website or use our platform, our servers and analytics tools automatically collect technical and usage data including your IP address, device identifiers, browser characteristics, referring URL, pages visited, and interaction events. This data is collected via server logs, cookies, and similar tracking technologies as described in Section 8.

4.3 Data from Third Parties

We may receive personal data about you from the following categories of third parties:

• Payment Processors: Transaction confirmation data, payment method verification results, and fraud screening signals from providers such as FPX operators, e-wallet platforms, and card networks.
• Identity Verification Services: Results and risk scores from our contracted KYC and anti-money laundering compliance vendors.
• Fraud Prevention Databases: Screening results against watchlists and politically exposed person (PEP) databases as required by applicable regulations.

5 Purpose of Processing

Pohon4D processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your Pohon4D member account, including authentication and access control.
• Transaction Processing: To process deposits and withdrawal requests via Malaysian payment channels including DuitNow, FPX, Touch 'n Go eWallet, Maybank, CIMB, Public Bank, and Hong Leong Bank.
• Identity Verification (KYC): To verify your identity and age (minimum 21 years) in compliance with applicable regulatory obligations, and to prevent underage gambling and fraud.
• Regulatory Compliance: To fulfil our obligations under applicable anti-money laundering legislation, sanctions screening requirements, and gambling regulatory requirements.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, money laundering, cheating, multi-accounting, and other prohibited activities on the platform.
• Customer Support: To respond to your enquiries, process complaints, and provide technical assistance.
• Service Improvement: To analyse usage patterns, game performance metrics, and platform behaviour in order to improve the quality, performance, and personalisation of Pohon4D Services.
• Responsible Gambling: To monitor gambling behaviour, enforce self-exclusion requests, apply deposit and spending limits, and identify members who may be experiencing gambling-related harm.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to Members who have consented to receiving such communications. You may withdraw consent at any time.
• Legal Obligations: To comply with court orders, regulatory requests, lawful government enquiries, and other legally mandated obligations.

6 Legal Basis for Processing

Pohon4D processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under the Pohon4D Terms and Conditions, including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC verification, anti-money laundering screening, and tax reporting obligations.
• Legitimate Interests: Processing necessary for the legitimate business interests of Pohon4D, including fraud prevention, security monitoring, platform improvement, and responsible gambling monitoring, where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, particularly in relation to optional marketing communications. You may withdraw this consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

7 Data Sharing & Disclosure

Pohon4D does not sell, rent, or commercially disclose your personal data to unaffiliated third parties. We may share your personal data with the following categories of recipients solely as necessary to deliver our Services or comply with legal obligations:

• Payment Service Providers: We share transaction data with payment processors necessary to execute your deposit and withdrawal requests, including FPX network operators, Maybank, CIMB, Public Bank, Hong Leong Bank, and e-wallet providers.
• KYC and Compliance Vendors: We share identity documents and verification data with contracted identity verification and AML screening service providers under strict data processing agreements.
• Fraud Detection Services: Technical and behavioural data may be shared with fraud prevention platforms to protect the integrity of the Pohon4D platform and its members.
• Technology and Infrastructure Partners: Hosting, cloud storage, analytics, and security service providers who process data exclusively on our behalf under contractual data protection obligations.
• Regulatory and Law Enforcement Authorities: Where required by law, court order, or government directive Pohon4D will disclose personal data to competent authorities. We will notify affected Members of such disclosures where legally permissible.

8 Cookies & Tracking Technologies

Pohon4D uses cookies and similar technologies to provide a functional, secure, and improved platform experience. The following categories of cookies are used on the Pohon4D website:

8.1 Strictly Necessary Cookies

These cookies are essential for the platform to function correctly. They enable core features such as session management, login authentication, and security verification. These cookies cannot be disabled without impairing platform functionality.

8.2 Analytical and Performance Cookies

We use analytical cookies to collect aggregated, anonymised data about how Members interact with the Pohon4D platform — including pages visited, session duration, game selections, and error events. This data is used solely to improve platform performance and user experience.

8.3 Preference Cookies

Preference cookies store your platform settings and choices such as language preferences, notification settings, and display configurations so that your preferences are remembered across sessions.

8.4 Cookie Management

You may manage or disable non-essential cookies via your browser settings. Please note that disabling certain cookies may affect the functionality and performance of the Pohon4D platform. Pohon4D does not deploy third-party advertising or cross-site tracking cookies.

9 Data Retention

Pohon4D retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, tax, or accounting obligations. The following general retention guidelines apply:

• Account and Identity Data: Retained for the duration of your active membership and for minimum period of five (5) years following account closure, as required by applicable anti-money laundering record-keeping regulations.
• Transaction and Financial Data: Retained for a minimum of seven (7) years from the date of each transaction in compliance with applicable financial record-keeping requirements.
• KYC Verification Documents: Retained for a minimum of five (5) years following account closure or the date of last transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of last communication unless the content of the communication is relevant to an active legal or compliance matter.
• Marketing Consent Records: Retained for the duration of your consent or until withdrawal of consent, plus a reasonable period for compliance verification purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in manner that prevents re-identification.

10 Data Security

Pohon4D implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and Pohon4D servers.
• Encrypted storage of sensitive data fields including financial account identifiers and identity document data.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for administrative and privileged system access.
• Regular independent penetration testing and vulnerability assessment of platform infrastructure.
• Automated intrusion detection and real-time security monitoring systems.
• Formal incident response procedures for data breach detection, containment, and notification.

11 Your Data Rights

Subject to applicable law and relevant regulatory restrictions, you have the following rights in relation to your personal data held by Pohon4D:

• Right of Access: You may request a copy of the personal data we hold about you, together with supplementary information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold 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 temporarily restrict certain processing activities while a dispute regarding the accuracy or lawfulness of your data is resolved.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on our legitimate interests, and to receiving direct marketing communications at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact our Data Protection team via live chat on the Pohon4D website or by email at [email protected]. We will respond to all valid requests within 30 calendar days. In complex cases, this period may be extended by a further 30 days, of which you will be notified.

12 Children's Privacy

The Pohon4D platform is strictly intended for adults aged21 years and above. Pohon4D does not knowingly collect, process, or retain personal data from persons under the age of 21. If you are under 21, you must not register an account or use any Pohon4D Services.

If Pohon4D becomes aware that personal data has been collected from an individual under the minimum age requirement, that data will be deleted promptly, the associated account will be closed, and any deposited funds will be returned in accordance with applicable legal requirements.

13 International Data Transfers

Pohon4D primarily processes and stores personal data within secure infrastructure serving the Malaysian market. Where personal data is transferred to or accessed by service providers operating in jurisdictions outside of Malaysia, Pohon4D ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that which it receives in Malaysia.

Such safeguards may include contractual data processing agreements incorporating standard data protection clauses, adequacy decisions, or other mechanisms recognised under applicable data protection frameworks. By using Pohon4D Services, you acknowledge and consent to such transfers where necessary for the delivery of our Services.

14 Amendments to This Policy

Pohon4D reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform Services. Where changes are material, we will provide reasonable advance notice via on-site notification, email to your registered address, or both.

The effective date at the top of this page will be updated with each revision. We encourage you to review this Policy periodically. Continued use of the Pohon4D platform following the publication of any amended Privacy Policy constitutes your acceptance of the revised terms.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way Pohon4D processes your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the Pohon4D website — the fastest way to reach our support and data protection team.
• Email: [email protected] (plain text only — this is not a clickable link).
• Response Time: Data rights requests will be acknowledged within 3 business days and fully responded to within 30 calendar days.

For questions about our responsible gambling tools and Member protection features, please visit our dedicated Responsible Gambling page.