Privacy Policy — pin4d

This Privacy Policy (hereinafter "Policy") is issued by pin4d (hereinafter "pin4d", "we", "us", "our"), the operator of the online gambling and sports betting platform accessible at https://pin4d.click. This Policy governs the collection, use, storage, disclosure, and protection of personal data submitted to or collected by pin4d in connection with your use of the platform.

pin4d is committed to protecting the privacy of our members and visitors. We recognise that Malaysian users place a high degree of trust in the platforms they use for financial transactions, and we take that responsibility seriously. This Policy is designed to be read and understood — written in plain English, not legal obfuscation.

This Policy applies to all personal data collected through the pin4d website, account registration, payment processing, customer support interactions, and any other touchpoints through which you share information with us. It applies to all Members across Malaysia, including players based in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, Ipoh, and Kota Kinabalu.

By registering for an account, making a deposit, or accessing any part of the pin4d platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein. If you do not consent to these practices, you should not use the platform and may request account closure in accordance with our Terms & Conditions.

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

• Personal Data: Any information that identifies or could reasonably be used to identify a living individual, including name, identification number, contact details, financial data, and device identifiers.
• Processing: Any operation performed on personal data, including collection, recording, organisation, storage, use, disclosure, or deletion.
• Data Controller: pin4d, as the entity that determines the purposes and means of processing your personal data.
• Data Processor: A third party that processes personal data on behalf of pin4d, such as payment service providers, KYC verification vendors, and cloud infrastructure providers.
• Member / User: Any individual who has registered an account on the pin4d platform or who visits and interacts with the platform without registration.
• Consent: A freely given, specific, informed, and unambiguous indication of agreement to the processing of personal data for a defined purpose.
• KYC: Know Your Customer — the identity and age verification procedure required for regulatory compliance prior to withdrawal processing.
• Sensitive Data: A subset of personal data that warrants heightened protection, including identification document data, financial account details, and data relating to health or vulnerability (e.g., responsible gambling self-exclusion status).

pin4d collects personal data through multiple channels in the course of providing its services. The categories of data we collect include:

pin4d uses personal data for the following defined purposes. We do not process personal data for purposes incompatible with those listed below without obtaining fresh consent or establishing a separate legal basis:

pin4d processes personal data only where a lawful basis exists for doing so. The primary legal bases applicable to our processing activities are:

• Contractual Necessity: Processing required to perform the contract between pin4d and the Member — account creation, transaction processing, game operation, and withdrawal fulfilment.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC obligations, AML requirements, gaming licence conditions, and responses to lawful regulatory requests.
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gambling monitoring, where those interests are not overridden by the Member's fundamental rights and freedoms.
• Consent: Processing for direct marketing and non-essential analytics, where you have provided specific, informed consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

pin4d does not sell, rent, or trade your personal data to third parties for their own commercial marketing purposes. We share personal data only in the following limited circumstances:

• Payment Service Providers: We share necessary financial and identity data with our payment processing partners — including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, and USDT TRC20 network processors — to facilitate deposits and withdrawals.
• KYC & Identity Verification Vendors: Identity document data is processed by specialist KYC verification providers operating under contractual data processing agreements that bind them to equivalent data protection standards.
• Cloud Infrastructure & Hosting Providers: Platform data is stored on secure cloud infrastructure. Our hosting providers process data as data processors under our instruction and are bound by appropriate data protection agreements.
• Regulatory & Law Enforcement Authorities: We will disclose personal data to competent regulatory bodies, law enforcement agencies, or courts where we are legally required to do so, or where disclosure is necessary to prevent, detect, or investigate crime, including money laundering and fraud.
• Professional Advisers: We may share data with legal, accounting, or auditing advisers under obligations of professional confidentiality, where necessary for the conduct of our business.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all of our assets, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections. Members will be notified of any such transfer.

pin4d retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention principles apply:

Upon expiry of the applicable retention period, data is securely deleted or anonymised. Where anonymisation is applied, the resulting data may be retained indefinitely for statistical and analytical purposes as it no longer constitutes personal data.

pin4d implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data we process. These measures are designed to protect your data against unauthorised access, accidental loss, alteration, disclosure, or destruction.

While pin4d employs rigorous security practices, no internet-based transmission is entirely immune to risk. You are responsible for maintaining the security of your own login credentials and for reporting any suspected unauthorised account access to our support team immediately.

pin4d uses cookies and similar tracking technologies (including local storage and session identifiers) to operate the platform, maintain session state, prevent fraud, and analyse usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, security tokens, and load-balancing identifiers. These cannot be disabled without preventing platform access.
• Functional Cookies: Remember your preferences, such as language settings, display options, and last-used payment method, to improve your experience on return visits.
• Analytical Cookies: Collect anonymised data about how pages are used — which features are accessed, session durations, and navigation paths. This data is used to improve the platform. No personally identifiable data is included in analytical cookie payloads.
• Security & Fraud Prevention Cookies: Support our fraud detection systems by recording device fingerprint characteristics used to identify anomalous login or transaction behaviour.

Non-essential cookies (analytical and functional) can be disabled via your browser settings or our cookie preference panel. Disabling strictly necessary cookies will prevent platform access. pin4d does not use third-party advertising tracking cookies or sell cookie-derived data to advertisers.

As a Member of pin4d, you hold the following rights in respect of your personal data. These rights are subject to applicable legal obligations that may limit their exercise in specific circumstances — for example, data required to be retained for regulatory compliance cannot be deleted on request alone.

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Rights Request". We will respond within 30 days of receiving a valid request. Identity verification may be required before processing certain requests.

pin4d's services are strictly for individuals aged 21 years and above. We do not knowingly collect, process, or retain personal data from any person under the age of 21. Age verification is enforced as a mandatory step in the KYC process prior to the release of any withdrawal.

Where pin4d becomes aware or reasonably suspects that personal data has been collected from a person under the age of 21, we will:

• Immediately suspend the account pending investigation.
• Retain the minimum data required to investigate the breach and comply with any applicable reporting obligations.
• Delete all other personal data associated with the underage registration as promptly as legally permissible.
• Return any deposited funds to the verified payment source, less any applicable regulatory holds.

If you are a parent or guardian and believe your child has accessed pin4d, please contact us immediately at [email protected]. We take all such reports seriously and will act promptly.

In the course of providing its services, pin4d may transfer personal data to third-party processors located outside Malaysia. Such transfers may occur in connection with cloud hosting, KYC verification processing, or payment network operations.

Where personal data is transferred internationally, pin4d ensures that appropriate safeguards are in place, including contractual data processing agreements that require the recipient to apply data protection standards comparable to those mandated under applicable Malaysian law and this Policy.

By using pin4d's services, you acknowledge and consent to the transfer of your personal data to the extent necessary for the provision of the services described in this Policy, subject to the safeguards described above.

pin4d reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or operational developments. The current version of this Policy is always the version published on this page, identified by the "Last Updated" date at the top of the document.

Where amendments are material — meaning they substantially affect how we use your data or the rights available to you — pin4d will notify Members by email to their registered address and/or by a prominent in-platform notification, with a minimum of 14 days' notice before the amended Policy takes effect.

Your continued use of the pin4d platform after the effective date of any amendment constitutes acceptance of the revised Policy. If you do not accept the revised Policy, you should cease using the platform and may request account closure in accordance with the Terms & Conditions.

For any privacy-related queries, data rights requests, or complaints regarding pin4d's data handling practices, please contact us through the following channels: