Privacy Policy

1. Introduction

to123 ("we", "us", "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you visit our website at https://to123.cam or use our online betting services (collectively, the "Platform").

By accessing or using the to123 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with the terms of this Privacy Policy, please do not use our services.

This Privacy Policy applies to all users of the to123 platform, including visitors who browse our website without creating an account and registered users who actively use our betting and gaming services. We process personal data in accordance with applicable international data protection regulations and industry best practices for online gaming operators.

2. Information We Collect

to123 collects various types of information to provide, maintain, and improve our services, as well as to comply with legal and regulatory requirements. The categories of information we collect include:

Personal Identification Information

When you register for an account on the to123 platform, we collect personal identification information including:

• Full legal name as it appears on your government-issued identification
• Date of birth (to verify you are at least 21 years of age)
• Residential address including city, province, and postal code
• Email address for account communications and notifications
• Mobile phone number for account verification and security purposes
• Username and password credentials for account access
• Copies of government-issued identification documents (Indonesian National ID/KTP, passport, or driver's license) for KYC verification
• Proof of address documents (utility bills, bank statements) if required for enhanced verification

Financial Information

To process deposits and withdrawals, we collect financial information such as:

• Bank account details including bank name, account number, and account holder name
• E-wallet account information for OVO, DANA, GoPay, ShopeePay, or LinkAja
• Credit or debit card information (processed securely through our payment providers and not stored on our servers)
• Transaction history including deposits, withdrawals, and payment method preferences

Usage and Activity Data

We automatically collect information about your interaction with the to123 platform, including:

• Betting history, wagers placed, games played, and winnings
• Login dates and times, session duration, and access frequency
• Device information including device type, operating system, browser type, and version
• IP address, geolocation data, and connection information
• Pages viewed, links clicked, and navigation patterns on our website
• Customer support interactions including chat logs and email correspondence

Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect information about your browsing behavior and preferences. For more details, please see Section 8: Cookies Policy below.

3. How We Use Your Data

to123 uses the collected information for various legitimate business purposes to operate, provide, and enhance our services. Specifically, we use your personal data to:

Account Management and Service Delivery

• Create and maintain your user account on the to123 platform
• Verify your identity and age to comply with legal requirements (21+ restriction)
• Process deposits, withdrawals, and other financial transactions
• Enable you to place bets, play games, and access all platform features
• Calculate and credit winnings, bonuses, and promotional offers
• Maintain accurate records of your gaming activity and transaction history

Communication and Customer Support

• Send account-related notifications including transaction confirmations and balance updates
• Respond to your inquiries, support requests, and feedback
• Provide customer service through live chat, email, WhatsApp, and in-app messaging
• Send promotional communications about bonuses, special offers, and new features (with your consent)
• Conduct customer satisfaction surveys and gather feedback to improve our services

Security and Fraud Prevention

• Detect, prevent, and investigate fraudulent transactions, money laundering, and other prohibited activities
• Monitor for duplicate accounts, bonus abuse, and violations of our Terms and Conditions
• Protect the security and integrity of the to123 platform and our users
• Verify the source of funds and comply with anti-money laundering (AML) regulations
• Implement responsible gaming measures and identify patterns of problem gambling behavior

Legal Compliance and Regulatory Obligations

• Comply with international gaming regulations and licensing requirements
• Maintain records as required by law for auditing and regulatory purposes
• Respond to legal requests from government authorities, courts, or law enforcement agencies
• Enforce our Terms and Conditions and other policies
• Resolve disputes and protect our legal rights

Platform Improvement and Analytics

• Analyze usage patterns and user behavior to optimize platform performance
• Develop new features, games, and services tailored to user preferences
• Conduct market research and understand demographic trends in the Indonesian betting market
• Test new technologies and improve the user experience across devices

4. Data Sharing and Disclosure

to123 does not sell or rent your personal information to third parties for marketing purposes. However, we may share your data with certain trusted third parties under the following circumstances:

Service Providers and Business Partners

We engage reputable third-party service providers to support our operations, including:

• Payment processors: To facilitate deposits and withdrawals through Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallets (OVO, DANA, GoPay, ShopeePay)
• Game providers: To deliver live casino games, slot titles, and other gaming content on our platform
• Identity verification services: To conduct KYC checks and verify the authenticity of submitted documents
• Customer support platforms: To provide live chat, email ticketing, and WhatsApp support services
• Cloud hosting providers: To securely store data on protected servers
• Analytics services: To analyze user behavior and platform performance (all data is anonymized)

All third-party service providers are contractually obligated to protect your data, use it only for specified purposes, and comply with applicable data protection laws.

Legal and Regulatory Authorities

We may disclose your personal information to government agencies, regulatory bodies, law enforcement, or courts when:

• Required by law, court order, or legal process
• Necessary to comply with anti-money laundering (AML) or counter-terrorist financing (CTF) obligations
• Requested by licensing authorities or gambling regulators
• Needed to protect the rights, property, or safety of to123, our users, or the public
• Required to investigate suspected fraud, criminal activity, or terms violations

Business Transfers

In the event that to123 undergoes a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on our website before your data is transferred and becomes subject to a different privacy policy.

5. Data Security Measures

Protecting your personal information is a top priority for to123. We implement industry-standard technical, administrative, and physical security measures to safeguard your data from unauthorized access, disclosure, alteration, or destruction.

Technical Security

• 256-bit SSL encryption: All data transmitted between your device and our servers is encrypted using Secure Socket Layer (SSL) technology, the same standard used by major financial institutions
• Secure data storage: Personal information is stored on protected servers located in secure data centers with restricted physical access
• Firewall protection: Our network infrastructure is protected by advanced firewalls that block unauthorized access attempts
• Regular security audits: We conduct periodic security assessments and penetration testing to identify and address vulnerabilities
• Two-factor authentication (2FA): Optional 2FA is available to add an extra layer of security to your account

Administrative Security

• Access to personal data is restricted to authorized personnel only, on a need-to-know basis
• All employees and contractors with access to user data are bound by confidentiality agreements
• Regular training is provided to staff on data protection best practices and privacy regulations
• We maintain detailed logs of data access and modifications for audit purposes

User Responsibilities

While we implement robust security measures, you also play a crucial role in protecting your account:

• Use a strong, unique password that combines letters, numbers, and special characters
• Never share your login credentials with anyone
• Log out of your account when using shared or public computers
• Report any suspicious activity or unauthorized access to our support team immediately
• Keep your registered email address and phone number secure

Despite our best efforts, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. If you have reason to believe that your account security has been compromised, contact us immediately at [email protected].

6. Data Retention Period

to123 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

For active user accounts, we retain personal and transactional data for the duration of your account relationship with to123. This includes your profile information, betting history, financial transactions, and communication records.

Closed Accounts

When you close your account, we retain certain information for legal and regulatory compliance purposes:

• Transaction records: Financial transaction data is retained for a minimum of 7 years to comply with anti-money laundering (AML) regulations and tax requirements
• Identification documents: KYC verification documents are retained for 5-7 years as required by international gaming regulations
• Betting history: Records of bets placed and game outcomes are retained for 5 years for audit and dispute resolution purposes
• Communication logs: Customer support conversations are retained for 3 years for quality assurance and training purposes

Inactive Accounts

Accounts that remain inactive (no login activity) for 12 consecutive months may be classified as dormant. We may delete or anonymize non-essential data from dormant accounts while retaining records necessary for regulatory compliance.

Data Deletion

After the applicable retention period expires, personal data is securely deleted or anonymized so that it can no longer be associated with you. Anonymized data may be retained indefinitely for statistical analysis and business intelligence purposes.

7. Your Privacy Rights

As a user of the to123 platform, you have certain rights regarding your personal data. We are committed to facilitating the exercise of these rights in accordance with applicable data protection laws.

Right to Access

You have the right to request access to the personal information we hold about you. This includes the right to obtain confirmation of whether we are processing your data and, if so, to receive a copy of that data along with information about how it is being used.

Right to Rectification

If you believe that any personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request that we correct or update it. You can update most of your account information directly through your account dashboard or by contacting customer support.

Right to Erasure (Right to be Forgotten)

In certain circumstances, you may request that we delete your personal data. However, this right is not absolute and may be limited by legal or regulatory requirements that mandate data retention (such as AML regulations requiring us to retain financial records for 7 years).

Right to Restrict Processing

You have the right to request that we limit the processing of your personal data in certain situations, such as when you contest the accuracy of the data or object to our processing activities.

Right to Data Portability

You may request to receive your personal data in a structured, commonly used, and machine-readable format, or request that we transmit this data directly to another service provider where technically feasible.

Right to Object

You have the right to object to our processing of your personal data for direct marketing purposes. If you no longer wish to receive promotional communications from to123, you can opt-out by clicking the unsubscribe link in any marketing email or contacting our support team.

Right to Withdraw Consent

Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

How to Exercise Your Rights

To exercise any of these rights, please contact us at:

• Email: [email protected] with the subject line "Privacy Rights Request"
• Live chat: Available 24/7 on our website
• WhatsApp: +62 812 3456 7890

We will respond to your request within 30 days and may ask you to verify your identity before processing your request to ensure data security.

8. Cookies and Tracking Technologies

to123 uses cookies and similar tracking technologies to enhance your browsing experience, analyze platform usage, and deliver personalized content. This section explains what cookies are, how we use them, and how you can manage your cookie preferences.

What Are Cookies?

Cookies are small text files that are stored on your device (computer, smartphone, or tablet) when you visit a website. They allow the website to recognize your device and remember certain information about your visit, such as your preferences and login status.

Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for the website to function properly. Enable core features like account login, security, and payment processing.	Session or Persistent
Performance Cookies	Collect information about how you use our website, such as which pages you visit most often, to help us improve site performance.	Persistent (up to 2 years)
Functionality Cookies	Remember your preferences (language, currency, display settings) to provide a personalized experience.	Persistent (up to 1 year)
Targeting/Advertising Cookies	Track your browsing habits to deliver relevant promotional content and measure the effectiveness of marketing campaigns.	Persistent (up to 1 year)

Managing Cookies

Most web browsers allow you to control cookies through their settings. You can typically:

• View and delete cookies stored on your device
• Block all cookies from being set
• Block third-party cookies only
• Clear cookies when you close your browser

Please note that disabling certain cookies may affect the functionality of the to123 platform and prevent you from accessing certain features, such as staying logged into your account.

9. Updates to This Privacy Policy

to123 reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this policy, we will notify you by:

• Posting the updated Privacy Policy on this page with a new "Last Updated" date
• Sending an email notification to the email address associated with your account
• Displaying a prominent notice on our website or within your account dashboard

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information. Your continued use of the to123 platform after we post changes to this Privacy Policy constitutes your acceptance of those changes.

If you do not agree with the updated terms, you should discontinue using our services and may request account closure and data deletion (subject to legal retention requirements).

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please do not hesitate to contact our dedicated privacy team:

We are committed to addressing your privacy concerns promptly and transparently. Our customer support team is trained to handle privacy-related inquiries and will respond to your request within 30 days. For urgent matters involving potential data breaches or security incidents, please contact us immediately via live chat for expedited assistance.

By using the to123 platform, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein.