Privacy Policy

Introduction

Nero4D ("we", "us", "our", "the Operator", "the Platform") is committed to protecting the privacy and personal data of all individuals who access or use the Nero4D website at https://nero4d.cam, including registered players, visitors, and prospective registrants (collectively, "you", "your", "the Data Subject").

This Privacy Policy ("Policy") sets out in full detail the types of personal data we collect, the purposes for which we process it, the legal bases upon which we rely, the parties with whom we may share it, the measures we take to keep it secure, and the rights you have in relation to your data. This Policy applies to all interactions with the Nero4D Platform, including account registration, login sessions, deposits, wagers, customer support interactions, and browsing activity on the site.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall relationship between you and Nero4D. By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

Definitions

For the purposes of this Privacy Policy, the following terms 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, identification number, contact details, financial information, IP address, and device identifiers.
• "Processing" means any operation or set of operations performed on personal data — including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" means the Nero4D Operator, which determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third party that processes personal data on behalf of the Operator under contractual obligation, such as payment processors, KYC providers, and hosting services.
• "Consent" means freely given, specific, informed, and unambiguous agreement by a Data Subject to the processing of their personal data.
• "Cookie" means a small text file placed on a user's device by the Platform for the purposes of session management, security, and analytics.
• "KYC" means Know Your Customer — the regulatory identity and age verification process required prior to withdrawal.
• "PDPA" means the Personal Data Protection Act 2010 of Malaysia, as amended or supplemented from time to time.

Data We Collect

Nero4D collects personal data through several channels, including account registration forms, transaction processing, customer support interactions, automated platform activity logging, and third-party verification services. The categories of data we collect are as follows:

3.1 Registration & Identity Data

• Full legal name as it appears on official identification documents
• Date of birth (for age verification — all players must be 21 years of age or above)
• Malaysian IC (MyKad) number or passport number (for KYC purposes)
• Residential address, including postcode and state (e.g., Kuala Lumpur, Selangor, Penang, Johor)
• Email address and mobile phone number
• Username and encrypted password hash

3.2 Financial & Transaction Data

• Bank account details and bank name (for withdrawal processing — Maybank, CIMB, Public Bank, Hong Leong, and others)
• E-wallet account identifiers (Touch 'n Go eWallet, Boost, GrabPay)
• Cryptocurrency wallet addresses where applicable
• Deposit amounts, withdrawal amounts, and transaction timestamps
• Wagering history and account balance records

3.3 Technical & Usage Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser type
• Session duration, page views, and click-path data
• Login timestamps and failed login attempt records
• Referral source (if the user arrived via a tracked affiliate or promotional link)

3.4 KYC Document Data

• Scanned or photographed copies of government-issued ID documents
• Selfie images submitted for identity verification
• Proof of address documentation
• Third-party identity verification results and risk scores

3.5 Communication Data

• Live chat transcripts from customer support interactions
• Email correspondence with the Nero4D support team
• Feedback, complaints, and dispute records

How We Process Your Data

Nero4D processes your personal data for the following specific purposes:

Legal Basis for Processing

Nero4D processes personal data on the following legal bases as recognised under the Malaysian Personal Data Protection Act 2010 (PDPA) and applicable data protection principles:

5.1 Contract Performance

The majority of data processing activities are necessary for the performance of the contract between Nero4D and the player — that is, the provision of online gambling services including account management, game access, and payment processing. Without this data, we would be unable to fulfil our contractual obligations to you.

5.2 Legal Obligation

Certain processing activities are required by law, including identity verification (KYC), age verification, anti-money laundering (AML) checks, suspicious transaction reporting, and data retention obligations. We are legally required to collect and process this data regardless of player preference.

5.3 Legitimate Interests

Where processing is not required by contract or law, but serves a legitimate operational interest — such as fraud prevention, platform security, responsible gambling monitoring, and internal analytics — we process data on the basis of legitimate interests, provided that such interests are not overridden by the Data Subject's rights and freedoms.

5.4 Consent

Where processing is based on consent — such as the sending of promotional emails, SMS notifications, or bonus offer communications — we will obtain your explicit consent at the relevant point of collection. You may withdraw consent for consent-based processing at any time by contacting customer support, without this affecting the lawfulness of any processing that took place prior to withdrawal.

Data Sharing & Disclosure

Nero4D does not sell, rent, or trade personal data to third parties for commercial gain. Personal data may be shared with the following categories of recipients only where necessary and under appropriate contractual, security, and confidentiality obligations:

6.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process data on our behalf, including:

• Payment processors — to facilitate deposit and withdrawal transactions via DuitNow, FPX, Touch 'n Go, Boost, GrabPay, and bank transfer channels.
• KYC and identity verification providers — to perform document verification, facial recognition matching, and risk assessment as part of our AML obligations.
• Cloud hosting and infrastructure providers — to host the Platform, store data securely, and ensure operational continuity.
• Fraud detection and cybersecurity services — to monitor for suspicious activity, bot usage, and account compromises in real time.
• Customer support platforms — to facilitate and record live chat and email interactions with our support team.

All Data Processors engaged by Nero4D are bound by data processing agreements that prohibit them from using your data for any purpose other than the delivery of services to Nero4D.

6.2 Regulatory and Law Enforcement Authorities

We may be required to disclose personal data to regulatory bodies, law enforcement agencies, tax authorities, or courts where we are legally compelled to do so, where we are responding to a lawful court order or subpoena, or where disclosure is necessary to protect the rights, property, or safety of Nero4D, its players, or the public.

6.3 Business Transfers

In the event that Nero4D undergoes a merger, acquisition, or sale of all or substantially all of its assets, personal data held by the Operator may be transferred to the acquiring entity as part of the transaction, subject to the acquirer assuming the same privacy obligations set out in this Policy.

Data Security

Nero4D implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your device and Nero4D is encrypted using TLS 1.2 or higher with 256-bit SSL certificates.
• Encryption at Rest: Personal data stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: Internal access to personal data is restricted based on role and operational necessity. All access is logged and subject to regular audit.
• Two-Factor Authentication: Players may enable 2FA on their accounts to add an additional layer of login security. Staff accounts with access to personal data require 2FA as mandatory.
• Intrusion Detection: Automated systems monitor the Platform 24/7 for unusual access patterns, brute-force attempts, and known attack signatures.
• Data Segmentation: KYC document data is stored in a segregated environment with stricter access controls than general account data.
• Security Audits: Periodic internal and third-party security assessments are conducted to identify and remediate vulnerabilities.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, Nero4D will take prompt remediation action and notify affected Data Subjects in a timely manner in accordance with applicable legal requirements.

Data Retention

Personal data is retained by Nero4D only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely and permanently deleted or anonymised such that it can no longer be associated with any identifiable individual. Requests to delete data before the end of the applicable retention period will be considered and actioned where legally permissible.

Cookies & Tracking Technologies

Nero4D uses cookies and similar tracking technologies on its Platform. Cookies are small text files placed on your device when you visit the site. They serve several functional and analytical purposes as described below.

9.1 Types of Cookies Used

9.2 Third-Party Advertising Cookies

Nero4D does not use third-party advertising or tracking cookies on its Platform. We do not permit advertising networks or social media platforms to place tracking cookies through our site.

9.3 Managing Cookies

You may manage or disable cookies through your browser's settings. Note that disabling essential cookies will affect the functionality of the Platform — you may not be able to log in or maintain a session if essential cookies are blocked. Instructions for managing cookies are available through the help documentation of your specific browser.

Your Rights

As a Data Subject, you have the following rights in relation to your personal data held by Nero4D. These rights are subject to applicable legal limitations and may be affected by regulatory retention obligations as described in Section 8.

• Right of Access: You have the right to request a copy of the personal data we hold about you and to receive information about how it is being processed. We will provide this within 30 days of receiving a valid request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. For minor updates (e.g., phone number, email), you may make changes directly through your account settings.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (for consent-based processing), or where processing is unlawful. This right does not apply where retention is required by law.
• Right to Restrict Processing: You may request that we restrict the processing of your personal data in certain circumstances — for example, while a rectification request is pending or where processing is disputed.
• Right to Data Portability: Where processing is based on contract or consent and is carried out by automated means, you may request a copy of your personal data in a structured, machine-readable format.
• Right to Object: You may object to the processing of your personal data where the legal basis is legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time with immediate effect on future processing. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

To exercise any of the above rights, please contact us via live chat or by emailing [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 5 business days and aim to resolve it within 30 calendar days.

Protection of Minors

The Nero4D Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect, process, or store personal data from individuals under the age of 21. Age verification is a mandatory component of our KYC process, and we take every reasonable step to prevent minors from accessing or registering on the Platform.

If we become aware that personal data has been collected from an individual under 21 years of age, we will take immediate steps to permanently delete that data and close the associated account, returning any deposited funds to their source where possible.

If you are a parent or guardian and believe that your child has registered on or interacted with the Nero4D Platform, please contact us immediately via our support channels so that we may investigate and take appropriate action without delay.

International Data Transfers

In the course of providing services through Nero4D, certain personal data may be transferred to or processed in jurisdictions outside Malaysia — for example, where our cloud hosting providers, KYC verification services, or technology partners operate infrastructure in other countries.

Where such transfers occur, Nero4D takes appropriate steps to ensure that the receiving party maintains an adequate level of data protection, including through the use of contractual safeguards such as standard data processing agreements, data transfer impact assessments, and where applicable, binding corporate rules.

By using the Nero4D Platform, you consent to the transfer of your personal data to such jurisdictions for the purposes described in this Policy, subject to the safeguards described above.

Policy Amendments

Nero4D reserves the right to update, amend, or replace this Privacy Policy at any time. Where changes are material — such as changes to the categories of data collected, the purposes of processing, or Data Subject rights — we will provide notice by updating the "Last Updated" date at the top of this page and, where practicable, by notifying registered players via their registered email address.

Your continued use of the Platform following the posting of an updated Privacy Policy constitutes acceptance of the revised Policy. If you do not agree to any changes, you should cease using the Platform and close your account before the effective date of the revised Policy.

The current version of this Privacy Policy will always be accessible at https://nero4d.cam/privacy-policy.

Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Nero4D, please contact us through the following channels. We take all privacy-related communications seriously and will respond promptly.