Privacy Policy — dana5d

Definitions

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

Data We Collect

dana5d collects Personal Data across the following categories, strictly limited to what is necessary for the purposes described in Clause 4:

We do not collect Special Category Data (such as racial or ethnic origin, health data, religious beliefs, or biometric data) except where a KTP photograph is submitted as part of KYC, in which case it is used solely for identity verification and is not processed for any other purpose.

How We Collect Data

Personal Data is collected through the following means:

1. Direct submission: Information you provide during account registration, KYC verification, deposit and withdrawal requests, support interactions, and promotional opt-ins.
2. Automated collection: Technical and behavioural data gathered automatically as you navigate the Platform, via server logs, session cookies, and first-party analytics tools.
3. Third-party providers: Identity verification partners, payment gateway processors, and fraud-detection services may share limited data with us as p art of the KYC and transaction-processing workflows. These third parties are contractually bound to handle data only for the specific purpose for which it was shared and may not use it for their own commercial ends.
4. Publicly available sources: In limited circumstances, such as fraud investigations, we may consult publicly available records to verify information provided by a Member.

Purposes of Processing

dana5d processes Personal Data for the following defined purposes only:

• Account Management: Creating, maintaining, and securing your Member account, including authentication, password recovery, and account-level communications.
• Identity Verification (KYC): Confirming that you are who you claim to be, that you meet the minimum age requirement of 21 years, and that you are not listed on any sanctions or self-exclusion register.
• Transaction Processing: Facilitating deposits and withdrawals in Indonesian Rupiah (IDR) through your chosen payment channel — including local banks such as BCA, BRI, BNI, Mandiri, CIMB Niaga, and BSI, and e-wallets such as OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, collusion, multi-accounting, and other forms of prohibited conduct as defined in our Terms & Conditions.
• Regulatory Compliance: Meeting obligations under applicable international anti-money-laundering (AML), counter-terrorism financing (CTF), and know-your-customer (KYC) standards.
• Platform Improvement: Analysing aggregated, anonymised behavioural data to improve the usability, performance, and content of the Platform — including game offerings, betting markets, and customer service workflows.
• Customer Support: Resolving queries, complaints, and disputes raised through our 24/7 live chat and email support channels.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to Members who have explicitly opted in to receive such communications. You may withdraw consent at any time.
• Responsible Gaming: Monitoring play patterns for indicators of problem gambling behaviour and proactively reaching out to Members who may benefit from our responsible gaming tools, in accordance with our Responsible Gaming policy.

Legal Basis for Processing

dana5d processes Personal Data on one or more of the following legal bases, depending on the specific processing activity:

1. Contractual Necessity: Processing required to perform the contract between dana5d and the Member — including account creation, transaction processing, and service delivery.
2. Legitimate Interests: Processing necessary for dana5d's legitimate business interests, such as fraud prevention, platform security, and service improvement, where those interests are not overridden by the Member's fundamental rights.
3. Legal Obligation: Processing required to comply with applicable international AML, CTF, and KYC regulatory frameworks.
4. Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and certain analytics activities. Consent may be withdrawn at any time without affecting the lawfulness of processing conducted prior to withdrawal.

Sharing & Disclosure of Personal Data

dana5d does not sell, rent, or commercially trade your Personal Data. We share data only in the following strictly defined circumstances:

1. Service Providers: Trusted third-party vendors engaged to support Platform operations — including payment processors, KYC verification providers, cloud infrastructure operators, and customer-support platform providers. All service providers are bound by data-processing agreements that restrict their use of your data to the specific service they perform for dana5d.
2. Fraud & Security Partners: Specialist fraud-detection and cybersecurity firms that assist in identifying and mitigating threats to the Platform and its Members. Data shared for this purpose is limited to technical identifiers and is used solely for security analysis.
3. Legal & Regulatory Disclosure: Where dana5d is required by a valid court order, regulatory directive, or applicable law to disclose Personal Data, we will comply with such requirements. Where legally permissible, we will notify affected Members before disclosure occurs.
4. Business Transfers: In the event of a merger, acquisition, or sale of all or a material portion of dana5d's assets, Personal Data may be transferred to the successor entity, subject to equivalent privacy protections. Members will be notified of any such transfer via a prominent Platform notice at least 30 days in advance.
5. With Your Consent: For any disclosure not covered by the above, dana5d will seek your explicit prior consent before sharing your data with any third party.

Cookies & Tracking Technologies

The dana5d Platform uses cookies and similar tracking technologies to deliver a secure, personalised, and high-performance experience. The following categories of cookies are used:

You can manage your cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies will prevent you from logging in and using core Platform features. dana5d does not use third-party advertising network cookies or cross-site tracking pixels.

Data Retention

Personal Data is retained only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable international compliance obligations. The following standard retention periods apply:

Upon expiry of the applicable retention period, Personal Data is either securely deleted using certified data-destruction procedures or fully anonymised so that it can no longer be linked to any individual.

Security Measures

dana5d employs a layered security architecture to protect Member data against unauthorised access, disclosure, alteration, and destruction. Our principal security controls include:

• Encryption in Transit: All data exchanged between your device and the Platform is protected by TLS 1.3, the current industry-standard transport encryption protocol.
• Encryption at Rest: Sensitive stored data — including KYC documents and financial records — is encrypted using AES-256, with encryption keys managed through a dedicated key-management system.
• Access Controls: Personnel access to Member data is restricted on a strict need-to-know basis. All internal access is logged, audited, and subject to multi-factor authentication requirements.
• Penetration Testing: The Platform undergoes regular independent security assessments, including penetration testing and vulnerability scanning, to identify and remediate weaknesses before they can be exploited.
• Incident Response: dana5d maintains a documented data-breach response procedure. In the event of a breach that poses a material risk to Members, affected individuals will be notified within 72 hours of the breach being confirmed, along with clear guidance on protective steps they should take.

Your Rights Over Your Personal Data

As a Member of dana5d, you hold the following rights with respect to your Personal Data. To exercise any of these rights, contact our support team via live chat or at the email address provided in Clause 14:

1. Right of Access: You may request a copy of all Personal Data we hold about you, along with information about how it is used and with whom it has been shared.
2. Right to Rectification: You may request that inaccurate or incomplete Personal Data be corrected or updated without undue delay.
3. Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where processing has been unlawful. Note that certain data must be retained for the mandatory periods specified in Clause 8 regardless of an erasure request.
4. Right to Restrict Processing: You may request that processing of your data be restricted — for example, while you contest the accuracy of data we hold — so that it is stored but not actively used.
5. Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request a copy of your data in a structured, commonly used, machine-readable format.
6. Right to Object: You may object to processing based on legitimate interests — including profiling for fraud-prevention purposes — unless dana5d can demonstrate compelling legitimate grounds that override your interests.
7. Right to Withdraw Consent: Where processing is based solely on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

All rights requests will be acknowledged within 5 business days (WIB) and substantively responded to within 30 calendar days. Where a request is complex or numerous, we may extend this period by a further 30 days with prior notice to you.

Minors

The dana5d Platform is strictly restricted to individuals aged 21 years and older. We do not knowingly collect Personal Data from anyone under the age of 21. If you are a parent or guardian and have reason to believe that a minor has registered an account or submitted Personal Data to the Platform, please contact us immediately via live chat or at the email address in Clause 14.

Upon receiving a substantiated report of a minor's account, dana5d will promptly suspend the account, securely delete all associated Personal Data to the extent permitted by our regulatory retention obligations, and return any real-money balance to the payment method used for deposit, after completing appropriate verification.

International Data Transfers

dana5d operates globally and may transfer your Personal Data to servers or service providers located outside of Indonesia. Where such transfers occur, we ensure that equivalent safeguards are in place to protect your data, including:

• Contractual clauses requiring recipient entities to uphold data protection standards equivalent to those applied by dana5d;
• Transfer only to jurisdictions that maintain internationally recognised data-protection frameworks;
• Regular review of transfer mechanisms to ensure continued adequacy as standards evolve.

Regardless of where your data is processed, dana5d applies the same privacy standards and security controls described in this policy to all Personal Data under our control.

Policy Amendments

dana5d may update this Privacy Policy from time to time to reflect changes in our data practices, service offerings, or applicable legal requirements. When material changes are made, we will notify Members via a prominent Platform notice and, where practicable, by email to the registered account address, at least 7 calendar days before the updated policy takes effect.

The "Effective Date" at the top of this policy indicates when the current version came into force. We encourage all Members to review this policy periodically. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated terms.

Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the dana5d privacy team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via your account portal. This is the fastest route for urgent data-related queries.
• Email (plain text — not a clickable link): [email protected]
• Response Commitment: All privacy-related enquiries will receive an initial acknowledgement within 2 business days (WIB) and a full substantive response within 30 calendar days.

If you believe that dana5d has processed your Personal Data in breach of this policy or applicable data-protection standards, you have the right to lodge a formal complaint. Begin by submitting a written complaint to our support team, who will escalate it to the appropriate internal review authority. If you are dissatisfied with the outcome of the internal review, you may escalate your complaint to a relevant international data-protection supervisory body.