At sma4d, your privacy is not a formality — it is a core commitment. This Privacy Policy explains exactly what personal data we collect, why we collect it, how it is stored and protected, and what rights you hold over your own information. Please take the time to read this document carefully.
Summary for Convenience: sma4d collects personal data only to deliver and improve its services, verify your identity, process payments, and meet legal obligations. We do not sell your data. We protect it with industry-standard encryption. You have rights over your data at all times. The full details are set out below.
sma4d ("we", "us", "our") operates the online gambling platform accessible at https://sma4d.cam (the "Platform"). This Privacy Policy describes how sma4d collects, receives, uses, stores, shares, transfers, and protects personal information provided by players and visitors who access or use the Platform.
This Privacy Policy applies to all registered players, prospective players who browse the Platform without registering, and any individual who contacts sma4d's customer support team. It applies equally to users accessing the Platform from Jakarta, Surabaya, Medan, Bandung, Bali, Yogyakarta, Semarang, and all other cities and regions across Indonesia.
This Privacy Policy forms an integral part of sma4d's Terms & Conditions and should be read together with that document. By registering an account or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.
sma4d is committed to handling personal data responsibly, transparently, and in accordance with applicable data protection principles. If you have any questions about this Privacy Policy or our data practices, please contact us as described in Section 15.
In this Privacy Policy, the following terms carry the meanings defined below:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information that identifies or could reasonably be used to identify a natural person, directly or in combination with other data. |
| "Processing" | Any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transfer, or deletion. |
| "Data Controller" | sma4d, the entity that determines the purposes and means of processing Personal Data. |
| "Data Processor" | Any third party that processes Personal Data on behalf of sma4d (e.g., payment processors, KYC providers, hosting providers). |
| "Player" / "You" / "User" | Any individual who registers for, accesses, or uses the sma4d Platform. |
| "KYC" | Know Your Customer — the identity and age verification process required before withdrawal processing. |
| "Cookies" | Small data files stored on your device by your web browser when you visit the sma4d Platform. |
sma4d collects only the Personal Data that is necessary for the specific purposes described in this Privacy Policy. We do not collect data beyond what is proportionate and relevant to those purposes. The categories of Personal Data we collect are as follows:
3.1 Registration Data. When you create a sma4d account, we collect your full legal name, date of birth, email address, and residential address in Indonesia (including city and province, such as Jakarta, Bandung, Surabaya, Medan, or Bali). This information is required to create and maintain your account.
3.2 Identity Verification (KYC) Data. To comply with anti-money laundering obligations and age verification requirements, sma4d collects copies of government-issued identification documents (e.g., your Indonesian National Identity Card — KTP — or valid passport), proof of residential address, and in some cases a selfie photograph for liveness verification. KYC data is handled with heightened security and access controls.
3.3 Financial Data. We collect information about your deposit and withdrawal transactions, including the payment method used (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, or LinkAja), transaction amounts in Indonesian Rupiah (IDR), timestamps, and reference numbers. We do not store full bank account numbers or card numbers on our servers — payment data is tokenised and handled by certified payment processors.
3.4 Gaming Activity Data. We maintain a record of your gaming activity on sma4d, including bet history, game types played (football betting, live casino, togel — Indonesia's traditional numbers lottery — slot games, and others), session durations, stakes, wins, and losses. This data is used to deliver your gaming history, detect fraud, and monitor responsible gaming indicators.
3.5 Technical Data. When you access the Platform, we automatically collect your IP address, browser type and version, operating system, device type, screen resolution, referring URL, pages visited, and session timestamps. This data is collected automatically via server logs and analytics tools.
3.6 Communications Data. When you contact sma4d's customer support team — whether by email, live chat, or any other channel — we retain a record of that communication, including the content of messages, timestamps, and any attachments you provide. This data is used to resolve your enquiry and improve our support services.
3.7 Responsible Gaming Data. If you activate responsible gaming tools (deposit limits, cooling-off periods, self-exclusion), we record those preferences and enforce them across your account. This data is treated with additional sensitivity and is not used for marketing purposes.
sma4d collects Personal Data through the following channels:
sma4d does not purchase marketing lists or acquire Personal Data from data brokers for promotional purposes. All Personal Data we hold originates from your direct interaction with the Platform or from service providers acting on our behalf.
sma4d processes Personal Data for the following specific purposes:
| Purpose | Data Categories Used | Legal Basis |
|---|---|---|
| Account creation & management | Registration Data, Technical Data | Contractual necessity |
| Identity & age verification (KYC) | KYC Data, Registration Data | Legal obligation; contractual necessity |
| Payment processing | Financial Data, Registration Data | Contractual necessity |
| Delivering gaming services | Gaming Activity Data, Technical Data | Contractual necessity |
| Fraud prevention & security | All categories as relevant | Legitimate interest; legal obligation |
| Responsible gaming monitoring | Gaming Activity Data, Responsible Gaming Data | Legal obligation; legitimate interest |
| Customer support | Communications Data, Registration Data | Contractual necessity; legitimate interest |
| Platform analytics & improvement | Technical Data, Gaming Activity Data | Legitimate interest |
| Marketing communications | Registration Data, Gaming Activity Data | Consent (opt-in only) |
| Legal & regulatory compliance | All categories as required | Legal obligation |
sma4d will not use your Personal Data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing a new lawful basis.
sma4d processes Personal Data only where a valid legal basis exists. The primary legal bases we rely upon are:
6.1 Contractual Necessity. The majority of sma4d's data processing activities are necessary for the performance of the contract between sma4d and the Player — specifically, the Terms & Conditions you accept upon registration. Without processing your Registration Data, Financial Data, and Gaming Activity Data, sma4d cannot operate your account, process your transactions, or deliver gaming services to you.
6.2 Legal Obligation. Certain processing activities are required by applicable law. These include KYC identity verification, anti-money laundering screening, age verification (confirming you are 21 or older), record-keeping obligations, and responding to lawful requests from competent authorities.
6.3 Legitimate Interest. sma4d processes some data on the basis of its legitimate business interests, provided those interests are not overridden by your fundamental rights. Legitimate interest processing covers fraud detection, platform security, responsible gaming monitoring, analytics, and service improvement. You have the right to object to processing based on legitimate interest — see Section 11.
6.4 Consent. Where sma4d relies on your consent as the legal basis for processing — most notably for marketing communications — you have the right to withdraw that consent at any time by contacting our support team or using the unsubscribe mechanism in any marketing email. Withdrawing consent does not affect the lawfulness of processing that occurred prior to withdrawal.
7.1 Service Providers. sma4d shares Personal Data with carefully selected third-party service providers who process data on our behalf as Data Processors. These include payment processors handling transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja; KYC and identity verification providers; game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft; cloud hosting and infrastructure providers; and customer support platform providers. All Data Processors are bound by contractual obligations to process data only as instructed by sma4d and to maintain appropriate security measures.
7.2 Legal Disclosure. sma4d may disclose Personal Data to law enforcement agencies, regulatory authorities, or courts where required to do so by applicable law, court order, or governmental instruction. sma4d will notify affected players of such disclosure where legally permitted to do so.
7.3 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or part of sma4d's business, Personal Data may be transferred to the acquiring entity. Players will be notified in advance of any such transfer and of any material changes to the privacy practices that will apply to their data.
7.4 No Sale of Data. sma4d does not sell, rent, or otherwise trade Personal Data to third parties for their own marketing, advertising, or commercial purposes. This prohibition is absolute and applies to all Player data without exception.
Note on Game Studio Data: When you play live casino games powered by third-party studios (e.g., Evolution Gaming), certain gameplay data is transmitted to and processed by those studios in order to deliver the live game experience. Each studio operates under its own privacy and data security standards. sma4d only works with studios that maintain industry-standard security and confidentiality obligations.
sma4d retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention period required by applicable law.
8.1 Active Accounts. For active player accounts, we retain all Personal Data for the full duration of the account relationship and for a period of five (5) years following account closure. This retention period is required to fulfil anti-money laundering obligations, resolve potential disputes, and support any regulatory enquiries that may arise after account closure.
8.2 KYC Documents. Identity verification documents (KTP copies, passport scans, proof of address) are retained for a minimum of five (5) years following account closure in accordance with applicable financial crime prevention regulations.
8.3 Transaction Records. All financial transaction records — including deposit and withdrawal histories in Indonesian Rupiah — are retained for a minimum of five (5) years for accounting and legal compliance purposes.
8.4 Support Communications. Customer support communications are retained for two (2) years from the date of the final message in a given thread, to support quality assurance and dispute resolution.
8.5 Technical Logs. Server access logs and technical data are retained for ninety (90) days for security monitoring and fraud detection purposes, after which they are securely deleted.
8.6 Deletion. Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised such that it can no longer be linked to any identifiable individual. You may request early deletion of certain data — see Section 11 for your rights in this respect.
sma4d implements a comprehensive range of technical and organisational security measures designed to protect Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. Key measures include:
Despite these measures, no internet-based system can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights, sma4d will notify affected players without undue delay and will take all necessary remedial action.
Your Role in Security: You are responsible for maintaining the confidentiality of your sma4d account password. Choose a strong, unique password and do not share it with anyone. If you suspect that your account has been accessed without your authorisation, contact sma4d support immediately at [email protected].
sma4d uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, analyse usage patterns, and support fraud detection. Below is a summary of the cookie categories we use:
| Cookie Category | Purpose | Can Be Disabled? |
|---|---|---|
| Strictly Necessary | Required for the Platform to function — session management, login authentication, security tokens. | No — essential for Platform operation |
| Functional | Remember your preferences (e.g., language, display settings) to personalise your experience. | Yes — disabling may reduce functionality |
| Analytics | Collect anonymised usage data to help us understand how players navigate the Platform and identify areas for improvement. | Yes — anonymised data only |
| Fraud Detection | Identify suspicious access patterns, detect bot activity, and protect account security. | No — required for platform security |
You can manage cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling strictly necessary or fraud detection cookies may prevent you from accessing certain features of the sma4d Platform. sma4d does not use third-party advertising cookies or cross-site tracking technologies for behavioural advertising purposes.
You hold the following rights over your Personal Data held by sma4d. To exercise any of these rights, contact our support team at [email protected] with the subject line "Data Rights Request". We will respond within 30 days of receiving a valid request.
Request a copy of the Personal Data sma4d holds about you, including the categories collected, the purposes for which it is used, and any third parties with whom it has been shared.
Request correction of any inaccurate or incomplete Personal Data we hold about you. We will update your records without undue delay upon receiving a valid rectification request.
Request deletion of your Personal Data where it is no longer necessary for the purposes collected, subject to legal retention obligations that may require us to retain certain records.
Request that we limit how we use your Personal Data in certain circumstances — for example, while the accuracy of data is being contested or a legitimate interest objection is being assessed.
Request your Personal Data in a structured, commonly used, machine-readable format (e.g., CSV or JSON) so that you may transfer it to another service provider if you choose.
Object to processing based on legitimate interest or for direct marketing purposes. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
sma4d is strictly an adults-only platform. You must be at least 21 years of age to register an account or use any service offered by sma4d. This age restriction applies to all users regardless of location within Indonesia or any other jurisdiction.
sma4d does not knowingly collect Personal Data from individuals under the age of 21. If we discover or have reason to believe that a registered account belongs to a person under 21, we will immediately suspend the account, conduct a review, and permanently close the account if the age restriction is confirmed to have been breached. Any balance associated with such an account may be withheld pending investigation.
If you are a parent or guardian and believe that a minor has accessed or registered with sma4d using your or their own details, please contact us immediately at [email protected]. We will investigate and take prompt corrective action.
21+ Only. sma4d's services are exclusively for adults aged 21 and above. Underage gambling is illegal, harmful, and strictly prohibited on this Platform. Please visit our Responsible Gaming page for further guidance.
sma4d operates as an internationally licensed gaming platform. As a result, your Personal Data may be transferred to, stored on, or processed by systems located outside Indonesia. This may include cloud hosting infrastructure, KYC verification systems, game studio servers, and customer support platforms operated in other countries.
Where Personal Data is transferred internationally, sma4d ensures that appropriate safeguards are in place to protect the data to a standard equivalent to that applicable within the jurisdiction of collection. These safeguards may include contractual data processing agreements with Data Processors, adherence to internationally recognised data protection frameworks, and technical security measures consistent with those described in Section 9.
By registering an account with sma4d and accepting this Privacy Policy, you explicitly consent to the international transfer of your Personal Data as described in this section, subject to the safeguards outlined above.
sma4d reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform services. When material changes are made, sma4d will publish a notice on the Platform and update the "Last Updated" date at the top of this document.
The most current version of this Privacy Policy will always be accessible at https://sma4d.cam/privacy-policy. Your continued use of the sma4d Platform following publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Privacy Policy, you must cease using the Platform and request account closure.
Where a change to this Privacy Policy is required by applicable law or regulatory instruction, it may take effect immediately upon publication without prior notice to Players. sma4d recommends that you review this Privacy Policy periodically to stay informed of how we protect your data.
For significant changes that materially affect your rights, sma4d will make reasonable efforts to notify active players directly via the email address registered to their account.
For all enquiries relating to this Privacy Policy, including requests to exercise your data rights, questions about how we use your Personal Data, or complaints regarding our data practices, please contact the sma4d data team through the following channels:
sma4d will acknowledge receipt of all data rights requests within 5 business days and aims to provide a full substantive response within 30 calendar days. Where a request is complex or involves a large volume of data, this period may be extended by a further 60 days, in which case we will notify you of the extension and the reason for it.
Indonesian-speaking support agents are available at all times and are equipped to assist with data-related enquiries in both English and Bahasa Indonesia. However, the official record of any data rights process will be maintained in English.
Our Privacy Commitments
From the moment you register to the moment you withdraw, your personal information is handled with the highest standard of care and security.
Every byte of data transmitted between your device and sma4d is protected by bank-grade 256-bit SSL encryption — the same standard used by leading financial institutions worldwide.
sma4d has never sold, rented, or traded player data to third-party marketers, advertisers, or data brokers. Your personal information belongs to you — not to the highest bidder.
We collect only what is strictly necessary to deliver our services and meet our legal obligations. No excessive data gathering, no unnecessary profiling beyond what is required for responsible gaming.
Personal Data is kept only for as long as necessary. Once retention periods expire, data is securely deleted or anonymised — no indefinite storage of inactive player records.
Access, correct, export, or delete your data at any time. sma4d honours all data subject rights requests and responds within 30 days — no bureaucratic runaround.
Our 24/7 support team includes agents trained specifically to handle data enquiries. Reach us any time at [email protected] — Indonesian-speaking agents are always on standby.
Our support team is available around the clock to answer any questions about how sma4d handles your personal data. You can also explore our full Terms & Conditions or read our FAQ for quick answers.
🔞 Adults only — 21+ | SSL Encrypted | Provably Fair | sma4d supports responsible gaming