Privacy Policy

1. Introduction

Welcome to the tetoto Privacy Policy. This document outlines how tetoto ("we," "us," "our") collects, uses, stores, shares, and protects your personal information when you access or use our online betting platform at https://tetoto.cam (the "Platform"). We are committed to maintaining the highest standards of data protection and transparency in accordance with Indonesian law and international best practices.

By registering an account, accessing the Platform, or using any of our services, you acknowledge that you have read, understood, and agree to the data practices described in this Privacy Policy. If you do not agree with our privacy practices, please discontinue use of the Platform immediately.

2. Information We Collect

tetoto collects several categories of personal information to operate the Platform, provide our services, ensure security, comply with legal obligations, and improve user experience.

2.1 Information You Provide Directly

When you register an account or interact with our Platform, you voluntarily provide the following information:

• Personal Identification Data: Full legal name, date of birth, nationality, gender, and Indonesian identity card number (KTP) or passport number.
• Contact Information: Email address, phone number (including mobile number), and residential address (street, city, province, postal code).
• Account Credentials: Username, password, security questions and answers, and two-factor authentication (2FA) settings.
• Financial Information: Bank account details (account number, bank name, account holder name), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja phone numbers or account IDs), and transaction history.
• Identity Verification Documents: Copies of government-issued identification (KTP, passport, driver's license), proof of address (utility bills, bank statements), and selfie photographs for Know Your Customer (KYC) verification.
• Customer Support Communications: Messages, emails, chat transcripts, and any attachments you send when contacting tetoto support.

2.2 Information Collected Automatically

When you use the Platform, we automatically collect certain technical and behavioral data:

• Device Information: Device type (desktop, mobile, tablet), operating system (Windows, macOS, Android, iOS), browser type and version, screen resolution, device identifiers (IMEI, advertising ID).
• Usage Data: Pages visited, features used, time spent on each page, click patterns, betting history (stakes, odds, outcomes), game sessions (game type, duration, results), login timestamps, and IP addresses.
• Location Data: Approximate geographic location derived from your IP address to ensure compliance with jurisdictional restrictions.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, local storage, and similar technologies to maintain login sessions, remember preferences, and analyze user behavior. For detailed information, see Section 8 (Cookies).

2.3 Information from Third Parties

We may receive information about you from third-party sources to verify your identity, prevent fraud, and comply with regulatory requirements:

• Payment Processors: Transaction confirmation, payment method verification, and fraud detection signals from BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, and other financial service providers.
• Identity Verification Services: Age verification, identity authentication, and fraud screening results from third-party KYC/AML compliance vendors.
• Affiliate Partners: Referral source information if you accessed tetoto through an affiliate link or marketing campaign.

3. How We Use Your Information

tetoto uses your personal data for the following lawful purposes:

3.1 Service Provision and Account Management

• Create, maintain, and manage your tetoto account.
• Process deposits, withdrawals, and internal fund transfers.
• Enable you to place bets, play casino games, participate in togel draws, and use all Platform features.
• Apply bonuses, promotions, cashback, and loyalty rewards to your account.
• Communicate important account updates, transaction confirmations, and service notifications via email, SMS, or push notifications.

3.2 Identity Verification and Fraud Prevention

• Verify your age (21+ requirement) and identity to comply with Indonesian gambling regulations.
• Prevent fraud, money laundering, account abuse, bonus abuse, and other prohibited activities.
• Detect and investigate suspicious betting patterns, collusion, or use of automated betting software.
• Enforce our Terms & Conditions and protect the integrity of the Platform.

3.3 Legal and Regulatory Compliance

• Comply with Indonesian anti-money laundering (AML) and counter-terrorism financing (CTF) laws.
• Respond to lawful requests from government authorities, law enforcement agencies, or courts.
• Maintain records as required by applicable regulations and licensing requirements.
• Implement responsible gaming measures, including self-exclusion, deposit limits, and reality checks.

3.4 Platform Improvement and Analytics

• Analyze user behavior to improve Platform functionality, user experience, and game offerings.
• Conduct A/B testing, usability studies, and performance optimization.
• Generate aggregated, anonymized statistics for internal business intelligence and reporting.

3.5 Marketing and Communications (With Your Consent)

• Send promotional offers, bonus announcements, and event updates via email or SMS (you may opt out at any time).
• Personalize marketing content based on your betting preferences, game history, and engagement patterns.
• Conduct customer satisfaction surveys and request feedback on our services.

4. Legal Basis for Processing (Indonesian Context)

Under Indonesian data protection principles and international standards, tetoto processes your personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contract with you (providing betting and gaming services).
• Legal Obligation: Processing is required to comply with Indonesian law, including AML/CTF regulations, age verification, and tax reporting.
• Legitimate Interest: Processing is necessary for fraud prevention, security, Platform optimization, and business operations, balanced against your privacy rights.
• Consent: For marketing communications and non-essential cookies, we obtain your explicit consent, which you may withdraw at any time.

5. How We Share Your Information

tetoto does not sell your personal data to third parties for marketing purposes. However, we may share your information with the following categories of recipients for legitimate business and legal reasons:

Recipient Category	Purpose of Sharing	Examples
Payment Service Providers	Process deposits and withdrawals	BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja
KYC/AML Verification Vendors	Identity verification and fraud screening	Third-party identity verification services, credit bureaus
Game Providers	Deliver casino games, live dealer tables, and sports betting odds	Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, Spribe, Pocket Games Soft
Cloud Infrastructure Providers	Host Platform infrastructure and store encrypted data	Cloud hosting and database services
Analytics and Marketing Tools	Analyze user behavior and deliver targeted marketing (with consent)	Analytics platforms, email marketing services
Legal and Regulatory Authorities	Comply with legal obligations and lawful data requests	Indonesian government agencies, law enforcement, courts

All third-party service providers are contractually bound to protect your data and use it only for the specified purposes. We conduct due diligence to ensure these partners maintain adequate security standards.

6. Data Security

tetoto employs industry-leading security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and tetoto servers is protected by 256-bit SSL/TLS encryption. Sensitive data at rest (passwords, financial information) is encrypted using AES-256 or equivalent standards.
• Access Controls: Personal data is accessible only to authorized tetoto employees and contractors who require it to perform their job functions. Access is logged and monitored.
• Two-Factor Authentication (2FA): We strongly encourage all users to enable 2FA on their accounts for an additional layer of security.
• Regular Security Audits: Our infrastructure undergoes periodic security assessments, penetration testing, and vulnerability scanning by independent third parties.
• Incident Response: In the unlikely event of a data breach, we will notify affected users and relevant authorities in accordance with Indonesian law.

7. Data Retention

tetoto retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

• Active Accounts: Personal data is retained for the duration of your active account plus 5 years after account closure, as required by Indonesian AML/CTF regulations and tax laws.
• Inactive Accounts: Accounts inactive for more than 2 years may be archived, with limited data retained for compliance purposes only.
• Transaction Records: Financial transaction data (deposits, withdrawals, bets, winnings) is retained for 7 years to comply with Indonesian financial record-keeping requirements.
• Marketing Data: If you opt out of marketing communications, your contact information is retained on a suppression list to ensure we do not inadvertently contact you again.

After the applicable retention period expires, personal data is securely deleted or anonymized such that it can no longer identify you.

8. Cookies and Tracking Technologies

tetoto uses cookies and similar technologies to enhance your browsing experience, maintain login sessions, and analyze Platform usage. A cookie is a small text file stored on your device by your web browser.

8.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function (e.g., maintaining your login session, security features). These cannot be disabled.
• Performance Cookies: Collect anonymous information about how you use the Platform (pages visited, time on site) to help us improve functionality.
• Functional Cookies: Remember your preferences (language, currency, timezone) to provide a personalized experience.
• Marketing Cookies: Track your browsing behavior across websites to deliver targeted advertising (used only with your consent).

8.2 Managing Cookies

You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies, though this may impact Platform functionality (e.g., inability to stay logged in). To opt out of marketing cookies specifically, adjust your preferences in your tetoto account settings.

9. Your Privacy Rights

As a tetoto user, you have the following rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal information.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your data, subject to legal retention obligations.
• Right to Restriction: Request limitation of processing under certain circumstances.
• Right to Data Portability: Receive your data in a structured, commonly used format to transfer to another service provider.
• Right to Withdraw Consent: Withdraw consent for marketing communications or optional data processing at any time.
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.

To exercise any of these rights, contact us at [email protected] with your full name, account username, and a description of your request. We will respond within 30 days.

10. Children's Privacy

tetoto strictly prohibits use of the Platform by individuals under 21 years of age. We do not knowingly collect personal information from minors. If we discover that a user is underage, we will immediately suspend the account, void all bets, and delete associated personal data. Parents or guardians who believe their child has provided information to tetoto should contact us immediately.

11. International Data Transfers

Your personal data may be transferred to and processed in countries outside Indonesia where our service providers (cloud hosting, game providers, payment processors) operate. While Indonesia does not have a comprehensive data protection law equivalent to the EU's GDPR, tetoto ensures that all international data transfers are protected by appropriate safeguards, including:

• Standard contractual clauses approved by international data protection authorities.
• Verification that the recipient country provides adequate data protection standards.
• Binding corporate rules and industry certifications (e.g., ISO 27001).

12. Changes to This Privacy Policy

tetoto reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform features. When we make material changes, we will notify you via email, Platform banner, or push notification at least 14 days before the changes take effect. The "Last Updated" date at the top of this document indicates when the most recent revision was made.

Your continued use of the Platform after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you must discontinue use of the Platform and may request account closure.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact tetoto's Data Protection Officer:

• Email: [email protected] (Subject: "Privacy Inquiry")
• Live Chat: Available 24/7 on the tetoto Platform
• Mailing Address: tetoto Data Protection Officer, Jakarta, Indonesia