Privacy Policy

tot131 ("we," "us," or "our") operates the online gaming platform accessible at https://tot131.cam (the "Platform"). We understand that your personal information is important to you and we take our obligations as a data custodian seriously. This Privacy Policy describes the categories of personal data we collect, the purposes for which we process it, the circumstances under which we may share it, the security measures we apply, and the rights you may exercise in relation to your data.

By registering an Account on tot131 or using our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein. This Policy should be read together with our Terms & Conditions, which govern your general use of the Platform.

1. Definitions

For the purposes of this Privacy Policy:

• "Personal Data" means any information that identifies, or could reasonably be used to identify, a natural person — including name, email address, phone number, bank account details, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, erasure, or destruction.
• "Data Controller" refers to tot131 as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" refers to any third party that processes Personal Data on behalf of tot131 under a written data-processing agreement.
• "User" refers to any person who registers an Account or accesses the Platform.
• "KYC" means Know Your Customer — the identity-verification process we use to confirm your identity before authorizing account activity.

2. Data We Collect

We collect the following categories of Personal Data in the ordinary course of operating the Platform:

Category	Examples	Purpose
Identity Data	Full name, date of birth, nationality, government ID number (KTP/passport)	Account registration, KYC verification, age confirmation (21+)
Contact Data	Email address, mobile phone number, residential address in Indonesia	Account communications, support, notifications, security alerts
Financial Data	Bank account name and number (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP), e-wallet IDs (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history	Deposit and withdrawal processing, AML compliance, fraud detection
Technical Data	IP address, browser type, operating system, device identifiers, session tokens	Platform security, fraud prevention, performance optimization
Behavioral Data	Pages visited, games played, bet amounts, session durations, click paths	Personalization, responsible gaming monitoring, product improvement
Communications Data	Live chat transcripts, support ticket content, email correspondence	Service delivery, dispute resolution, quality assurance

We do not intentionally collect sensitive categories of Personal Data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, or biometric data. If any such data is inadvertently included in documents you submit for KYC, we will not use it for any purpose beyond identity verification.

3. How We Collect Your Data

3.1 Data You Provide Directly

We collect Personal Data that you actively provide when you:

• Register an Account on tot131 (name, email, phone, date of birth, address)
• Complete KYC verification by submitting identity and address documents
• Make deposits or request withdrawals using Indonesian bank accounts or e-wallets
• Contact our customer support team via live chat or email
• Respond to surveys, promotions, or loyalty program communications

3.2 Data Collected Automatically

When you access and use the Platform, our systems automatically collect certain Technical and Behavioral Data, including:

• Your IP address and approximate geographic location (city/region level)
• Device information (model, operating system, screen resolution)
• Browser type, version, and language settings
• Pages viewed, features used, and time spent on the Platform
• Cookies and similar tracking technologies (see Section 9)

3.3 Data from Third Parties

We may receive Personal Data about you from third-party sources, including:

• Identity verification service providers who assist with KYC screening
• Payment processors and partner banks when verifying transaction authenticity
• Fraud detection and anti-money laundering (AML) screening services
• Public databases, sanctions lists, and regulatory authority registers

4. Legal Basis for Processing

tot131 processes your Personal Data on the following legal grounds:

• Contractual Necessity: Processing is necessary to provide you with the Services described in our Terms & Conditions — including account management, transaction processing, and customer support.
• Legal Obligation: We are required to process certain data to comply with AML regulations, age verification requirements, fraud prevention obligations, and applicable Indonesian laws.
• Legitimate Interests: We process Technical and Behavioral Data to improve Platform security, detect fraud, personalize your gaming experience, and conduct business analytics — provided these interests are not overridden by your privacy rights.
• Consent: Where required by law, we obtain your consent before processing data for specific purposes such as marketing communications. You may withdraw consent at any time by contacting our support team.

5. How We Use Your Personal Data

We use the Personal Data we collect for the following purposes:

• Account Management: Creating, maintaining, and securing your tot131 Account, including password recovery and session management.
• Service Delivery: Processing deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, and LinkAja; awarding bonuses; and delivering games and sports betting services.
• Identity Verification: Confirming that you are at least 21 years old and a resident of Indonesia, and verifying that payment methods are registered in your own name.
• Fraud Prevention & Security: Detecting and preventing unauthorized access, money laundering, multi-accounting, bonus abuse, and other forms of fraud or misconduct.
• Responsible Gaming: Monitoring gameplay patterns for signs of problem gambling, enforcing self-exclusion requests, and applying deposit or loss limits as requested by Users or required by policy.
• Customer Support: Responding to your inquiries, resolving disputes, processing complaints, and providing platform assistance through our Indonesian-speaking support team.
• Communications: Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts) and, where you have consented, promotional communications about bonuses and offers.
• Analytics & Improvement: Analyzing usage patterns to improve Platform functionality, game offerings, payment options, and overall user experience.
• Legal Compliance: Meeting our obligations under applicable Indonesian law, responding to lawful requests from regulatory authorities, and enforcing our Terms & Conditions.

6. Sharing and Disclosure of Personal Data

tot131 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We may share your data in the following limited circumstances:

6.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process Personal Data on our behalf under strict contractual obligations. These include:

• Payment processing p artners and banking integration services (to process deposits and withdrawals via local Indonesian banks and e-wallets)
• Identity verification and KYC service providers (to authenticate identity documents and screen against sanctions lists)
• Fraud detection and AML compliance platforms (to identify suspicious transaction patterns)
• Cloud hosting and infrastructure providers (to store and serve Platform data securely)
• Customer support software providers (to manage live chat and ticketing systems)
• Analytics platforms (to process aggregated behavioral data for Platform improvement)

All service providers are contractually required to process your Personal Data only as instructed by tot131, to maintain appropriate technical and organizational security measures, and to refrain from using your data for their own independent purposes.

6.2 Legal and Regulatory Disclosure

We may disclose Personal Data to government authorities, law enforcement agencies, or regulatory bodies when we are legally compelled to do so, or when we reasonably believe disclosure is necessary to:

• Comply with applicable Indonesian laws, court orders, or legal processes
• Respond to verified requests from law enforcement or regulatory authorities
• Protect the rights, property, or safety of tot131, our Users, or the public
• Investigate suspected fraud, money laundering, or other criminal activity

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of tot131's business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will notify affected Users of any such transfer and the applicable privacy terms via email or a prominent notice on the Platform.

6.4 Aggregated and Anonymized Data

We may share aggregated, de-identified, or anonymized data — which cannot reasonably be used to identify any individual — with business partners, researchers, or the public for analytical, marketing, or industry-reporting purposes. Such data is not considered Personal Data under this Policy.

7. Data Retention

We retain your Personal Data for as long as your Account remains active and for such additional periods as are necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, in compliance with AML record-keeping requirements.
• Financial Transaction Data: Retained for a minimum of five (5) years from the date of each transaction.
• KYC Documents: Retained for five (5) years after the end of the business relationship, or longer if required by applicable law or regulatory guidance.
• Behavioral and Technical Data: Retained for up to two (2) years from the date of collection, after which it is anonymized or deleted.
• Customer Support Communications: Retained for up to three (3) years from the date of the last interaction.
• Self-Exclusion Records: Retained indefinitely to prevent re-registration by Users who have requested permanent self-exclusion.

Upon expiry of the applicable retention period, we will securely delete or anonymize your Personal Data in accordance with our internal data disposal procedures.

8. Security Measures

tot131 implements a comprehensive set of technical and organizational security measures designed to protect your Personal Data against unauthorized access, accidental loss, alteration, or disclosure:

• SSL/TLS Encryption: All data transmitted between your device and the tot131 Platform is encrypted using industry-standard Secure Sockets Layer (SSL) / Transport Layer Security (TLS) protocols.
• Data Encryption at Rest: Sensitive data stored in our systems — including financial information and identity documents — is encrypted using AES-256 encryption.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. Staff who access Personal Data are subject to confidentiality obligations and receive regular data protection training.
• Two-Factor Authentication (2FA): We offer 2FA on User Accounts and enforce it for all internal administrative access to systems containing Personal Data.
• Regular Security Audits: Our Platform undergoes regular penetration testing, vulnerability assessments, and third-party security audits to identify and remediate potential risks.
• Incident Response: We maintain a documented data breach response plan. In the event of a breach affecting your Personal Data, we will notify you and, where required by law, the relevant authorities within the timeframes prescribed by applicable regulations.

While we employ robust security practices, no method of electronic transmission or storage is completely impenetrable. You also play an important role in protecting your Account — please use a strong, unique password, enable 2FA, and notify us immediately at [email protected] if you suspect any unauthorized access.

9. Cookies and Tracking Technologies

tot131 uses cookies and similar tracking technologies (such as pixel tags and local storage objects) to enhance your experience on the Platform, maintain session continuity, and gather analytics data. The categories of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that authenticate your login state and security cookies that prevent cross-site request forgery. These cannot be disabled.
• Performance and Analytics Cookies: Collect anonymized data about how visitors use the Platform — such as pages visited, time on page, and error encounters — to help us improve Platform performance and usability.
• Functional Cookies: Remember your preferences such as language settings, preferred payment methods, and responsible gaming tool configurations to deliver a more personalized experience.
• Fraud Prevention Cookies: Assist our fraud detection systems in identifying unusual access patterns, multiple account creation attempts, and other suspicious behaviors that may indicate abuse of the Platform.

You may manage your cookie preferences through your browser settings. Note that disabling certain categories of cookies may affect Platform functionality. For most browsers, instructions for managing cookies can be found in the browser's "Help" menu or official documentation.

10. Your Privacy Rights

As a User of tot131, you hold the following rights in relation to your Personal Data. To exercise any of these rights, please contact our support team at [email protected]. We will respond to verified requests within 30 days.

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is used and with whom it has been shared.
• Right to Rectification: If any of your Personal Data is inaccurate or incomplete, you have the right to request that we correct or update it.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where we no longer have a lawful basis to retain it. Note that we may be required by law to retain certain data (e.g., AML records) even after Account closure.
• Right to Restriction of Processing: You may request that we limit the way we use your Personal Data in certain circumstances — for example, while a dispute is being resolved.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, you may request a copy of your Personal Data in a structured, machine-readable format.
• Right to Object: You may object to processing of your Personal Data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though we may be able to demonstrate compelling grounds that override your objection.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

We will never discriminate against you for exercising your privacy rights. Your Account status and access to Services will not be adversely affected solely because you submit a privacy rights request.

11. Minors and Age Restriction

tot131 is strictly an adults-only platform. We do not knowingly collect Personal Data from individuals under the age of 21. Our registration process includes age verification steps, and all Users are required to confirm that they are at least 21 years old at the time of registration.

If we discover or are notified that a User is under 21, we will immediately suspend their Account, void any bets or transactions, and delete their Personal Data as quickly as practicable. If you believe a minor has created an Account on tot131, please contact us immediately at [email protected].

Parents and guardians are encouraged to use parental control software to prevent underage access to online gaming platforms.

12. International Data Transfers

tot131 primarily stores and processes Personal Data within server infrastructure serving the Southeast Asian region. In some cases, data may be transferred to service providers located outside Indonesia — for example, for cloud hosting, fraud analytics, or identity verification services.

Whenever we transfer Personal Data internationally, we take appropriate steps to ensure an adequate level of protection is maintained. These steps may include:

• Selecting service providers that operate under privacy frameworks recognized as providing adequate protection
• Entering into standard contractual clauses or data processing agreements that impose equivalent protections
• Conducting transfer impact assessments where required

By using the Platform and submitting your Personal Data, you acknowledge and consent to potential cross-border transfers of your data in accordance with this section.

13. Changes to This Privacy Policy

We reserve the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or business operations. When we make material changes, we will:

• Update the "Effective Date" and "Last Reviewed" dates at the top of this Policy
• Post a prominent notice on the Platform for a reasonable period following the change
• Send an email notification to all registered Users at their Account email address

Your continued use of the Platform after the revised Policy takes effect constitutes your acceptance of the updated terms. If you do not agree with the changes, you should discontinue use of the Platform and close your Account.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way tot131 handles your Personal Data, please reach out to our dedicated support team:

Email: [email protected]

Response Time: Within 24–48 hours, 7 days a week

Language: English and Indonesian (Bahasa Indonesia) supported

We are committed to addressing your privacy concerns promptly and transparently. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.