Privacy Policy

This Privacy Policy ("Policy") is issued by Tunas4D ("the Company", "we", "us", "our"), the operator of the online gambling platform accessible at https://tunas4d.cam and all associated subdomains, mobile interfaces, and related services (collectively, "the Platform").

This Policy describes how Tunas4D collects, uses, discloses, stores, and protects the personal data of individuals who access or use our Platform ("you", "User", "Player"). It is intended to provide you with a transparent and comprehensive understanding of our data practices, in accordance with applicable data protection principles and our obligations as a licensed online gambling operator.

This Policy applies to all personal data collected in connection with your use of the Tunas4D platform, including data collected during account registration, identity verification (KYC), payment processing, customer support interactions, and general browsing of our website. It applies regardless of whether you access the Platform from Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, or any other location.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, each of which is incorporated by reference into our overall framework of user-facing policies.

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, identification number, IP address, financial data, and device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, alteration, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means Tunas4D, which determines the purposes and means of processing your personal data.
• "Data Processor" means a third party that processes personal data on behalf of Tunas4D, subject to a data processing agreement.
• "KYC Data" means identity verification documents submitted by a user during the Know Your Customer process, including government-issued identification, proof of address, and supporting photographs.
• "Cookies" means small text files stored on your device by the Platform for functional, performance, or analytics purposes.
• "Third Party" means any organisation or individual that is not Tunas4D or the user whose data is being processed.

Tunas4D collects personal data across several categories depending on the nature of your interaction with the Platform. The following table summarises the categories of data we collect and the primary context in which each category arises:

We do not collect or process special categories of sensitive personal data (such as health data, racial or ethnic origin, political opinions, or religious beliefs) unless expressly required in connection with a responsible gambling assessment at your specific request.

Tunas4D collects personal data through the following channels and methods:

• Direct submission: Data you voluntarily provide during account registration, KYC document upload, payment transactions, or when contacting our support team via live chat or email.
• Automated technical collection: Technical data such as IP addresses, device identifiers, browser characteristics, and session information collected automatically when you access or interact with the Platform.
• Cookies and similar technologies: Session and persistent cookies placed on your device for functional and performance purposes, as described in the Cookies section of this Policy.
• Third-party payment providers: Transaction confirmation data received from payment processors including FPX banking partners, e-wallet providers (Touch 'n Go, Boost, GrabPay, DuitNow), and cryptocurrency processing services, for the purpose of reconciling your account transactions.
• Identity verification services: Where Tunas4D uses a third-party KYC verification partner, identity confirmation data may be returned to us confirming whether submitted documents have been authenticated.
• Fraud prevention services: Aggregated risk signals from licensed third-party fraud detection providers may be received to assist in identifying potentially fraudulent account activity.

Tunas4D processes your personal data only where a lawful basis exists for doing so. The primary legal bases on which we rely are as follows:

• Contractual necessity: Processing of identity, contact, financial, and account data is necessary to perform our obligations under the Terms & Conditions you have accepted — specifically, to register your account, process deposits and withdrawals in MYR, and deliver gambling services.
• Legal obligation: Processing of KYC documents and transaction records is required to comply with anti-money laundering (AML) regulations, age verification obligations (21+ requirement), and record-keeping requirements imposed by our gaming licence conditions.
• Legitimate interests: Technical data and gameplay data are processed based on Tunas4D's legitimate interest in maintaining platform security, detecting fraud, preventing bonus abuse, and improving the user experience — where such interests are not overridden by your rights and interests.
• Consent: Marketing communications, including promotional emails and in-platform notifications about new games, bonuses, and Liga Super or EPL betting offers, are sent only where you have explicitly opted in. You may withdraw this consent at any time via your account settings or by contacting support.

Tunas4D uses the personal data it collects for the following purposes:

• To create, manage, and maintain your Tunas4D account, including account authentication and security;
• To process deposits and withdrawals in Malaysian Ringgit (MYR) through your chosen payment method;
• To perform KYC identity verification as required by our gaming licence obligations and anti-money laundering procedures;
• To enforce our 21+ age restriction requirement and prevent access by underage individuals;
• To detect and prevent fraudulent activity, bonus abuse, multi-accounting, and other forms of platform manipulation;
• To comply with AML obligations, including monitoring of transactions for suspicious patterns and reporting to relevant regulatory bodies where legally required;
• To provide customer support via live chat and email, including resolution of account, payment, and game-related enquiries;
• To administer bonuses, promotions, VIP tier programmes, and the Refer a Friend reward scheme;
• To send marketing and promotional communications, but only where you have provided explicit opt-in consent;
• To analyse platform usage patterns and improve game selection, user experience, and technical performance;
• To comply with any applicable legal obligations, court orders, or regulatory requests.

We do not use your personal data for automated individual decision-making that produces legal or similarly significant effects on you, except where such processing is necessary for fraud prevention or AML compliance, in which case you retain the right to request human review of any automated decision.

Tunas4D does not sell, rent, or commercially disclose your personal data to third parties. We may share your data only in the following limited and specific circumstances:

• Payment processors: We share transaction data with payment service providers including FPX banking partners, Touch 'n Go eWallet, Boost, GrabPay, DuitNow, and cryptocurrency processing partners, solely for the purpose of processing your deposits and withdrawals.
• KYC verification providers: Where a third-party document verification service is used to authenticate your identity documents, we share only the minimum data necessary for that verification process.
• Fraud and AML service providers: Aggregated risk data may be shared with licensed fraud prevention and AML compliance platforms to detect and prevent financial crime on the Platform.
• Technology and infrastructure providers: Cloud hosting, database management, and security monitoring services operated by contracted third-party vendors who are bound by data processing agreements requiring them to process data only on our instructions.
• Legal and regulatory authorities: We will disclose personal data to law enforcement agencies, regulators, or courts where required to do so by applicable law, valid legal process, or our gaming licence obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of the Company's assets, personal data held by Tunas4D may be transferred to the successor entity, subject to equivalent data protection commitments.

All third-party data processors engaged by Tunas4D are required to implement appropriate technical and organisational security measures and to process personal data only in accordance with our documented instructions.

Tunas4D retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any applicable legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that renders it irreversibly non-identifiable. Where you request deletion of your data before the expiry of a retention period, we will action your request to the extent permitted by our legal obligations, and will notify you of any categories of data that we are legally required to retain.

Tunas4D uses cookies and similar tracking technologies to operate and improve the Platform. A "cookie" is a small text file stored on your browser or device when you visit a website. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the operation of the Platform. These include session authentication cookies, security tokens, and cookies that remember your login state. These cookies cannot be disabled without impairing core platform functionality.
• Functional Cookies: Enable the Platform to remember your preferences — such as your selected language, display settings, and notification preferences — to provide a more personalised experience.
• Performance and Analytics Cookies: Used to measure aggregate website traffic, understand how users navigate the Platform, and identify areas for improvement. These cookies collect anonymised data only and do not track individual users for advertising purposes.

Tunas4D does not use advertising, retargeting, or social media tracking cookies. We do not allow any third-party advertising networks to place cookies on your device through our Platform.

You may configure your browser to block or delete cookies; however, please note that disabling strictly necessary cookies will prevent core functionality of the Platform — including login and payment processing — from working correctly.

Tunas4D implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher (256-bit SSL);
• Encryption at rest: Sensitive data fields — including financial records, KYC document files, and password hashes — are encrypted in our database using AES-256 encryption;
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and regular security training;
• Two-factor authentication (2FA): Available for all player accounts and mandatory for all internal administrative access to systems containing personal data;
• Network security: Our infrastructure is protected by enterprise-grade firewalls, DDoS mitigation systems, and intrusion detection systems;
• Third-party security audits: Tunas4D conducts regular third-party penetration testing and vulnerability assessments of its platform and infrastructure;
• Incident response: We maintain a documented data breach response procedure. In the event of a security incident that materially affects your personal data, we will notify you and the relevant supervisory authority within the timeframes required by applicable law.

While Tunas4D takes reasonable and appropriate precautions to protect personal data, no method of internet transmission or electronic storage is entirely secure. You are also responsible for maintaining the security of your own account credentials and should take appropriate steps to prevent unauthorised access.

Subject to applicable data protection law and the limitations imposed by our legal and regulatory obligations, you have the following rights with respect to your personal data held by Tunas4D:

To exercise any of these rights, please contact our support team at [email protected] with the subject line "Data Subject Request". We will respond to all requests within thirty (30) calendar days of receipt, or notify you if a longer period is required due to the complexity of your request.

We will take reasonable steps to verify your identity before processing any data subject request to protect against unauthorised disclosure of personal data.

The Tunas4D platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or retain the personal data of individuals under the age of 21.

As part of our KYC verification process, all users are required to submit valid age-verifying identification prior to processing any withdrawal. Where we discover or have reasonable grounds to suspect that personal data has been provided by or collected in relation to a person under the age of 21, we will:

• Immediately suspend the relevant account pending further investigation;
• Delete or anonymise any personal data collected in relation to the underage individual to the extent not required for legal compliance purposes;
• Report the matter to relevant regulatory or law enforcement authorities where required by applicable law.

As an online platform serving Malaysian users, Tunas4D may store or process personal data on servers located outside of Malaysia. Where personal data is transferred to countries or territories that do not provide an equivalent level of data protection to the jurisdiction in which you reside, Tunas4D will implement appropriate safeguards to ensure that your personal data remains protected to a standard consistent with this Policy.

Such safeguards may include:

• Standard contractual clauses or data transfer agreements with the receiving entity;
• Requiring the receiving entity to implement technical security measures at least equivalent to those described in Clause 10 of this Policy;
• Restricting access by the receiving entity to only the minimum personal data necessary for their specific processing purpose.

By using the Tunas4D platform, you acknowledge and consent to the transfer of your personal data to servers and processors located in other countries, subject to the safeguards described above.

Tunas4D reserves the right to modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our service offerings. The most recent version of this Policy will always be accessible at https://tunas4d.cam/privacy-policy.

Where we make material changes to this Policy — such as introducing new categories of data collection, new sharing arrangements, or changes to your rights — we will provide notice by:

• Displaying a notification banner on the Platform at your next login;
• Sending an email notification to your registered email address.

Your continued use of the Platform following the effective date of any material amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated terms, please discontinue your use of the Platform and contact our support team to discuss your options.

The date of the most recent update to this Policy is displayed at the top of the Table of Contents and in the page header. We encourage you to review this Policy periodically to stay informed about how Tunas4D protects your personal information.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Tunas4D, please contact our Data Protection team through the following channels:

When submitting a data subject request, please include your registered account email address and a clear description of your request. We may ask for additional information to verify your identity before processing sensitive requests such as data deletion or access.

For complaints relating to our handling of your personal data that cannot be resolved through our internal process, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.