Privacy Policy

1. Introduction

This Privacy Policy applies to all users of totopg's online gaming platform, accessible at https://totopg.cam and all associated mobile applications, subdomains, and services. This policy describes our practices concerning personal data collected from residents of Indonesia and other jurisdictions where our services are available.

totopg respects your privacy rights and is committed to transparency regarding our data handling practices. We collect only the personal information necessary to provide our gaming services, process transactions, comply with legal and regulatory obligations, and improve your user experience.

This Privacy Policy should be read in conjunction with our Terms & Conditions and other policies referenced throughout this document. If you have any questions or concerns about how we handle your personal data, please contact our Data Protection Officer using the contact information provided at the end of this policy.

2. Data Controller

For the purposes of applicable data protection laws, totopg acts as the data controller for all personal information collected through our platform. As data controller, we determine the purposes and means of processing your personal data and are responsible for ensuring that such processing complies with applicable privacy laws and regulations.

Our registered business address and data protection contact information are provided in the "Contact Us" section at the end of this Privacy Policy.

3. Information We Collect

totopg collects various categories of personal information to provide our gaming services, verify your identity, process transactions, and ensure compliance with legal and regulatory requirements. The information we collect includes:

Information You Provide Directly

When you register an account with totopg, you provide the following information:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (KTP number for Indonesian residents)
• Contact Information: Email address, mobile phone number, physical address (street address, city, province, postal code)
• Account Credentials: Username, password, and security questions/answers
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history
• Verification Documents: Copies of government-issued ID (KTP or passport), proof of address documents (utility bills, bank statements), and payment method verification documents
• Communication Content: Messages sent to customer support, live chat transcripts, emails, and other correspondence with totopg

Information We Collect Automatically

When you access and use totopg, we automatically collect certain technical and usage information:

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, device identifiers
• Usage Data: Pages visited, features used, time spent on pages, referral sources, search queries, clickstream data
• Gaming Activity: Bets placed, games played, wagering history, win/loss records, bonus claims, tournament participation
• Location Data: Geographic location derived from IP address and GPS data (if you enable location services on mobile devices)
• Cookies and Tracking Technologies: Cookie identifiers, session IDs, and other tracking data (see the "Cookies & Tracking" section below)

Information from Third Parties

We may receive information about you from third parties, including:

• Payment Processors: Transaction confirmation, payment status, and fraud detection data from banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay)
• Identity Verification Services: Age verification, identity authentication, and fraud prevention data from third-party KYC providers
• Marketing Partners: Anonymized demographic and interest data from advertising platforms (only if you interact with our ads)

4. How We Use Your Information

totopg uses your personal information for the following legitimate business purposes:

Account Management and Service Provision

• Creating and maintaining your user account
• Processing deposits, withdrawals, and other financial transactions
• Enabling gameplay across sports betting, casino, slots, togel, sabung ayam, and other gaming categories
• Managing bonuses, promotions, and loyalty rewards
• Providing customer support and responding to inquiries
• Sending transactional communications (account confirmations, password resets, transaction receipts, withdrawal notifications)

Identity Verification and Compliance

• Verifying your age (21+ requirement) and identity through KYC procedures
• Preventing fraud, money laundering, and other illegal activities
• Complying with anti-money laundering (AML) regulations and responsible gaming requirements
• Detecting and preventing multiple account registrations and bonus abuse
• Cooperating with law enforcement and regulatory authorities as legally required

Platform Improvement and Analytics

• Analyzing user behavior to improve website functionality and user experience
• Identifying technical issues, bugs, and performance bottlenecks
• Conducting internal research and analytics to optimize game selection, odds, and features
• Developing new products, services, and features based on user preferences

Marketing and Communications

• Sending promotional emails about new games, bonuses, and special offers (with your consent)
• Delivering personalized gaming recommendations based on your activity
• Conducting customer satisfaction surveys and feedback requests
• Retargeting advertisements on third-party websites (only if you have not opted out)

Legal Obligations and Dispute Resolution

• Responding to legal requests, court orders, and government inquiries
• Resolving disputes between totopg and users
• Enforcing our Terms & Conditions and other policies
• Protecting the rights, property, and safety of totopg, our users, and the public

5. Legal Basis for Data Processing

Under applicable data protection laws, totopg processes your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (providing gaming services, processing transactions, managing your account)
• Legal Obligation: Processing is required to comply with laws and regulations (KYC verification, AML compliance, age verification, tax reporting, responding to law enforcement requests)
• Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, security, internal analytics, customer support) provided such interests are not overridden by your privacy rights
• Consent: Processing is based on your explicit consent (marketing communications, optional features, cookies and tracking technologies beyond those strictly necessary for service provision)

6. How We Share Your Information

totopg does not sell your personal information to third parties. However, we may share your data with the following categories of recipients for the purposes described below:

Service Providers and Business Partners

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) process your financial transactions
• Identity Verification Providers: Third-party KYC services verify your identity, age, and address
• Game Providers: Software providers that power our casino games, slots, live dealer games, and other gaming content may receive limited usage data
• Customer Support Tools: Live chat and helpdesk platforms used to manage customer inquiries
• Cloud Hosting Providers: Secure servers and databases that store your personal information
• Analytics Providers: Services that help us understand user behavior and improve platform performance (using anonymized or pseudonymized data where possible)

Legal and Regulatory Authorities

We may disclose your personal information to government agencies, law enforcement, regulatory bodies, and courts when required by law or when we believe in good faith that such disclosure is necessary to:

• Comply with legal obligations, court orders, or government requests
• Prevent fraud, illegal activity, or violations of our Terms & Conditions
• Protect the rights, property, or safety of totopg, our users, or the public
• Respond to claims or investigations

Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you of such transfer and any changes to this Privacy Policy.

Data Sharing Restrictions

All third-party service providers with whom we share data are contractually obligated to:

• Process data only for the specific purposes we authorize
• Implement appropriate technical and organizational security measures
• Not use your data for their own purposes or share it with other parties without our authorization
• Comply with applicable data protection laws

7. Data Security Measures

totopg implements comprehensive technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

Technical Security Measures

• Encryption: SSL/TLS encryption for all data transmitted between your device and our servers; AES-256 encryption for data stored in our databases
• Firewalls and Intrusion Detection: Advanced firewall configurations and intrusion detection systems monitor and block unauthorized access attempts
• Secure Authentication: Password hashing using industry-standard algorithms; optional two-factor authentication (2FA) for enhanced account security
• Regular Security Audits: Third-party penetration testing and vulnerability assessments conducted regularly
• DDoS Protection: Distributed denial-of-service mitigation systems to ensure platform availability

Organizational Security Measures

• Access Controls: Role-based access controls ensure that only authorized personnel can access personal data based on job function
• Employee Training: Mandatory data protection and security training for all employees with access to personal information
• Confidentiality Agreements: All employees and contractors sign confidentiality agreements prohibiting unauthorized disclosure of user data
• Incident Response Plan: Documented procedures for detecting, responding to, and reporting data breaches
• Data Minimization: We collect and retain only the personal information necessary for specified purposes

Data Breach Notification

In the event of a data breach that compromises your personal information, totopg will:

• Notify affected users within 72 hours of becoming aware of the breach
• Provide details about the nature of the breach, the data affected, and potential consequences
• Inform you of the measures we are taking to mitigate the breach and prevent future incidents
• Provide guidance on steps you can take to protect yourself
• Notify relevant regulatory authorities as required by law

8. Data Retention

totopg retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

Upon expiration of the applicable retention period, personal data will be securely deleted or anonymized such that it can no longer be attributed to you.

9. Your Privacy Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

Right to Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of such data. You can access most of your account information by logging into your totopg account. For a comprehensive data export, contact our Data Protection Officer.

Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You can update most information directly through your account settings or by contacting customer support.

Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data when:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw consent (where processing is based on consent)
• You object to processing and there are no overriding legitimate grounds for continued processing
• The data has been unlawfully processed

Note: This right is not absolute. We may be required to retain certain data to comply with legal obligations (e.g., transaction records for AML compliance must be retained for 7 years).

Right to Restriction of Processing

You may request that we restrict processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible.

Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes. If you object to marketing communications, you can unsubscribe using the link in any promotional email or by updating your communication preferences in your account settings.

Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided at the end of this policy. We will respond to your request within 30 days. In some cases, we may require additional information to verify your identity before processing your request.

10. Cookies and Tracking Technologies

totopg uses cookies and similar tracking technologies to enhance your user experience, analyze platform performance, and deliver personalized content and advertisements.

What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They allow websites to recognize your device and remember information about your visit, such as your preferred language and other settings.

Types of Cookies We Use

• Essential Cookies: Necessary for the platform to function properly (e.g., session management, security, load balancing). These cookies cannot be disabled.
• Functional Cookies: Remember your preferences and settings (e.g., language selection, currency preference).
• Analytics Cookies: Help us understand how users interact with our platform (e.g., pages visited, time spent, clickstream data) using tools like Google Analytics.
• Marketing Cookies: Track your activity across websites to deliver targeted advertisements and measure advertising campaign effectiveness.

Managing Cookie Preferences

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, and receive notifications when new cookies are set. However, disabling cookies may affect the functionality of the platform and prevent you from accessing certain features.

For more information about managing cookies, visit your browser's help documentation.

11. Children's Privacy

totopg strictly prohibits use of our platform by individuals under the age of 21. We do not knowingly collect personal information from anyone under the age of 21. Our age verification processes are designed to prevent underage registration.

If we discover that we have inadvertently collected personal information from someone under the age of 21, we will immediately delete such information from our systems and terminate the associated account.

If you believe that we have collected information from an underage individual, please contact us immediately at the contact information provided below.

12. Changes to This Privacy Policy

totopg reserves the right to modify 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 Privacy Policy, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you via email (to the address registered on your account)
• Display a prominent notice on the platform
• For significant changes, we may require you to review and accept the updated Privacy Policy before continuing to use our services

Your continued use of totopg after the effective date of any Privacy Policy changes constitutes your acceptance of those changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Contact Information

If you have any questions, concerns, or complaints about this Privacy Policy or our data handling practices, or if you wish to exercise your privacy rights, please contact us: