desa4d Privacy Policy

desa4d ("we", "us", "our", "the Company") is the operator of the online gaming and sports betting platform accessible at desa4d.click (the "Platform"). We are committed to protecting the personal data of all individuals who interact with our Platform, including registered members, prospective users, and visitors.

This Privacy Policy ("Policy") describes in plain, formal terms how desa4d collects, processes, stores, shares, and protects personal data. It also explains the rights available to data subjects — including registered players based in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and elsewhere in Malaysia — in respect of their personal data held by desa4d.

This Policy applies to all personal data processed by desa4d in connection with: account registration and management; deposits and withdrawals via Malaysian payment methods including DuitNow, FPX, Maybank2u, CIMB Clicks, Touch 'n Go eWallet, Boost, and GrabPay; gaming and betting activity on the Platform; participation in promotional programmes; and all communications between desa4d and its users.

This Policy should be read together with desa4d's Terms and Conditions, which are available at desa4d.click/terms-conditions. In the event of any conflict between this Policy and the Terms and Conditions on a privacy-related matter, this Policy shall take precedence.

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

• "Personal Data" means any information relating to an identified or identifiable natural person — including but not limited to a name, identification number, location data, online identifier, or any factor specific to the physical, physiological, economic, or social identity of that person.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, transmission, erasure, or destruction, whether by automated means or otherwise.
• "Data Controller" means desa4d, as the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third party engaged by desa4d to process personal data on its behalf, such as payment service providers, identity verification services, and cloud hosting providers.
• "Data Subject" means the individual to whom personal data relates — in the context of this Platform, this primarily refers to registered players and Platform visitors.
• "KYC Data" means identity and age verification documentation collected in connection with the Know Your Customer process, including copies of national identity cards, passports, proof of address, and payment method evidence.
• "Sensitive Data" means a subset of personal data that warrants heightened protection, including financial data, identity document data, and data related to health or gambling behaviour.

desa4d collects personal data through several channels: information you provide directly during registration and subsequent account activity; data generated automatically through your use of the Platform; and data received from third-party service providers engaged for payment processing and identity verification.

• Device and Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution, and network connection type.
• Usage Data: Pages visited, games played, bets placed, session duration, click patterns, and navigation paths through the Platform.
• Transaction Data: Automated records of all deposits, withdrawals, bonus claims, wagers, and account balance changes.
• Cookies and Tracking Data: Data collected through cookies and similar tracking technologies as described in Section 9 of this Policy.

desa4d may receive personal data from third-party service providers, including identity verification agencies used in the KYC process, payment service providers that confirm successful transactions, and fraud detection and risk management services that flag suspicious account activity.

desa4d processes personal data only where a lawful basis for processing exists. The applicable legal bases under which desa4d processes your personal data are as follows:

• Performance of a Contract: Processing that is necessary to fulfil our contractual obligations to you as a registered player — including account management, processing deposits and withdrawals through Malaysian payment channels, providing access to games, and administering bonuses and promotions.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations — including anti-money laundering (AML) checks, identity verification, record-keeping requirements under international gaming licensing standards, and responses to lawful requests from law enforcement or regulatory authorities.
• Legitimate Interests: Processing that is in the legitimate interests of desa4d and does not override your fundamental rights — including fraud prevention, security monitoring, platform analytics, responsible gambling monitoring, and improving the quality of our services for Malaysian players.
• Consent: Processing that relies on your freely given, informed, and unambiguous consent — principally for the use of non-essential cookies and for direct marketing communications where required. You may withdraw consent at any time without affecting the lawfulness of prior processing.

desa4d uses the personal data it collects for the following specific purposes. We do not use personal data for any purpose that is incompatible with the purpose for which it was originally collected without providing prior notice and, where required, obtaining consent.

• Account Registration and Management: To create, verify, maintain, and close your Player Account, including processing your identity during the KYC verification stage prior to your first withdrawal.
• Payment Processing: To facilitate deposits and withdrawals in Malaysian Ringgit (MYR) through your chosen payment method — whether DuitNow, FPX, Maybank2u, CIMB Clicks, Touch 'n Go eWallet, Boost, GrabPay, or other supported channels.
• Service Delivery: To provide access to games, process bets, calculate and credit winnings, apply bonus funds, and administer VIP programme tier benefits.
• Fraud Prevention and Security: To detect and prevent fraudulent transactions, multi-accounting, money laundering, bonus abuse, and other prohibited activities that may harm the Platform or other players.
• Legal and Regulatory Compliance: To comply with applicable anti-money laundering requirements, to respond to lawful requests from law enforcement or regulatory authorities, and to maintain records as required under our international gaming licence obligations.
• Responsible Gambling Monitoring: To monitor gaming behaviour for indicators of problem gambling, to enforce self-exclusion and deposit limit settings, and to contact players who may be showing signs of gambling-related harm.
• Customer Support: To respond to enquiries, resolve complaints, and provide assistance to players with account or transaction issues.
• Marketing Communications (Where Consented): To send promotional emails, bonus notifications, and relevant platform updates to players who have opted in to receive such communications. You may unsubscribe at any time.
• Platform Improvement: To analyse usage patterns, optimise the Platform experience for Malaysian users, and develop new features based on aggregated, anonymised behavioural data.

desa4d does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the specific circumstances described below, and only to the extent necessary for the stated purpose.

• Payment Service Providers: We share financial and identity data with payment processors and banking partners — including providers facilitating transactions via DuitNow, FPX, Maybank2u, CIMB Clicks, Touch 'n Go eWallet, Boost, and GrabPay — to process deposits and withdrawals in MYR on your behalf.
• Identity Verification (KYC) Providers: We share identity documentation with accredited third-party KYC and age-verification service providers for the purpose of confirming your eligibility to use the Platform in compliance with our licensing obligations.
• Fraud and Risk Management Providers: We share certain transaction and behavioural data with third-party fraud detection services to protect the integrity of the Platform and the security of player accounts.
• Cloud Infrastructure and Technology Providers: We share data with cloud hosting and technology vendors that provide the infrastructure on which the Platform operates. These providers act as data processors bound by contractual obligations to process data only under our instruction.
• Legal and Regulatory Authorities: We will disclose personal data to law enforcement agencies, courts, regulators, or government authorities where we are legally required to do so, or where we believe in good faith that disclosure is necessary to protect the legal rights, safety, or property of desa4d, its players, or third parties.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or substantially all of desa4d's assets, player personal data may be transferred as part of that transaction. Affected players will be notified in advance where legally required.

As an internationally licensed gaming platform, desa4d may transfer personal data to countries outside of Malaysia for the purposes of processing, storage, or service delivery. Such transfers may occur where, for example, our cloud infrastructure or KYC providers are based in other jurisdictions.

Where personal data is transferred internationally, desa4d takes reasonable measures to ensure that such data receives adequate protection equivalent to the standards applied within Malaysia. These safeguards may include the use of contractual data protection clauses with service providers, transfer to jurisdictions that provide an adequate level of data protection under internationally recognised standards, and the application of technical security measures to data in transit.

Where data is transferred to countries that do not have equivalent data protection frameworks, desa4d will only proceed with such transfers where appropriate contractual safeguards have been put in place and where the transfer is otherwise consistent with the lawful bases for processing described in Section 4 of this Policy.

desa4d retains personal data for only 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 or enforce our agreements with players.

• Active Account Data: Personal data associated with an active Player Account is retained for the duration of the account's existence and for a period of five (5) years following the permanent closure of the account.
• Financial Transaction Records: Records of all MYR deposits, withdrawals, bets, and bonus transactions are retained for a minimum of five (5) years in accordance with anti-money laundering record-keeping requirements.
• KYC Documentation: Identity verification documents submitted during the KYC process are retained for five (5) years from the date of submission or from the date of account closure, whichever is later.
• Customer Support Records: Records of support interactions, complaints, and dispute resolutions are retained for three (3) years from the date of the relevant interaction.
• Inactive Account Data: Where a Player Account has been inactive for a period of twelve (12) consecutive months, desa4d may notify you prior to applying a data minimisation process to anonymise non-essential personal data.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents reconstruction or re-identification, unless a longer retention period is required by applicable law.

desa4d uses cookies and similar tracking technologies on the Platform to deliver core functionality, maintain session security, and — where you have provided consent — to improve the user experience and analyse Platform usage. A cookie is a small data file stored on your browser or device when you visit a website.

You may manage your cookie preferences through your browser settings at any time. Disabling non-essential cookies will not affect your ability to use the core features of the Platform, but may result in a less personalised experience. Strictly necessary cookies cannot be disabled without impacting the functioning of the Platform.

As a data subject, you hold specific rights in relation to your personal data held by desa4d. These rights are set out below. To exercise any of these rights, please contact our Data Protection team at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 5 business days and respond in full within 30 calendar days.

Please note that certain rights may be limited where desa4d has overriding legal obligations — for example, financial transaction records must be retained for a minimum of five years regardless of erasure requests, due to anti-money laundering regulatory requirements.

desa4d implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures are reviewed regularly and updated in response to evolving security standards and threat landscapes.

• Encryption: All data transmitted between your browser or device and the desa4d Platform is encrypted using 256-bit SSL (Secure Sockets Layer) / TLS (Transport Layer Security) protocols. Data at rest in our databases is subject to AES-256 encryption.
• Access Controls: Access to personal data within desa4d's internal systems is restricted on a need-to-know basis. Staff with data access are subject to confidentiality obligations and regular security training.
• Two-Factor Authentication: Players are strongly encouraged to enable two-factor authentication (2FA) on their desa4d accounts. This provides an additional layer of protection against unauthorised access, even if login credentials are compromised.
• Penetration Testing and Security Audits: desa4d conducts periodic security assessments, including vulnerability scanning and penetration testing, to identify and remediate potential security weaknesses in the Platform infrastructure.
• Data Breach Procedures: In the event of a personal data breach, desa4d has documented breach response procedures in place. Affected individuals will be notified in accordance with applicable legal obligations where a breach is likely to result in risk to their rights or freedoms.

Notwithstanding the foregoing, no system of data transmission or storage can be guaranteed to be completely secure. While desa4d takes all reasonable measures to protect your data, we cannot warrant the absolute security of information transmitted to or from the Platform.

The desa4d Platform is strictly intended for individuals who are aged 21 years or above. desa4d does not knowingly collect, process, or retain personal data from any individual under the age of 21. Age verification is a mandatory component of the KYC process, and the Platform employs controls to detect and prevent access by minors.

If desa4d becomes aware that personal data has been collected from a person under the age of 21 — whether through registration fraud or any other means — we will take immediate steps to delete all associated personal data and permanently close the relevant Player Account. Any funds associated with such an account will be handled in accordance with applicable anti-money laundering requirements.

Parents and guardians are encouraged to make use of parental control tools and monitoring software to prevent underage access to online gaming platforms. If you have reason to believe that a minor has registered or is using a desa4d account, please contact our support team at [email protected] immediately.

desa4d reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, data processing practices, or Platform functionality. The most current version of this Policy will be published at desa4d.click/privacy-policy, along with the effective date of the revision.

Where a revision constitutes a material change to the way in which we process your personal data — for example, a new category of data sharing or a new purpose for existing data — we will provide advance notice via the email address associated with your Player Account and/or through a prominent notification on the Platform upon your next login.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to the changes, you must cease using the Platform and may request deletion of your personal data in accordance with the rights set out in Section 10.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by desa4d, please contact our Data Protection team. We are committed to responding to all privacy-related enquiries promptly and transparently.

desa4d is committed to resolving all privacy-related concerns in a fair, transparent, and timely manner. Where a request is complex or requires escalation to our compliance team, we will communicate an estimated resolution timeline clearly and keep you informed of progress.