Privacy Policy

totojp ("we", "us", "our") operates the online gaming platform accessible at https://totojp.cam. We are committed to protecting the privacy and personal data of every individual who accesses, registers on, or interacts with our Platform. This Privacy Policy describes our data practices in full and applies to all Users, visitors, and prospective members of the totojp Platform.

By accessing the Platform, creating an Account, or submitting any personal data to totojp, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your data as described herein. If you do not agree with any part of this Privacy Policy, you should discontinue use of the Platform immediately.

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming policy, which together form the complete legal framework governing your use of the totojp Platform.

The following terms carry specific meanings throughout this Privacy Policy:

• "Personal Data" — any information that identifies or can reasonably be used to identify a specific individual, either alone or in combination with other data.
• "Processing" — any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" — totojp, the entity that determines the purposes and means by which Personal Data is processed.
• "Data Processor" — a third party that processes Personal Data on behalf of totojp under a contractual data-processing agreement.
• "User" / "You" — any individual who accesses the Platform, whether registered or not.
• "KYC Data" — identity verification documents and biometric data submitted by a User as part of the Know Your Customer process.
• "Cookies" — small text files placed on your device by the Platform to store session, preference, and analytics data.
• "Platform" — the totojp website, mobile interface, and all associated digital services.

totojp collects several categories of Personal Data in order to operate the Platform, process transactions, verify identities, and comply with applicable legal obligations. The categories of data we collect are as follows:

We collect only the minimum data necessary for the stated purposes. We do not collect sensitive personal data categories (such as racial origin, political opinions, religious beliefs, or health data) unless specifically required by our responsible gaming obligations and only with your explicit consent.

totojp collects Personal Data through the following means:

• Direct Submission: Data you provide when registering an Account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or participating in promotions.
• Automated Technical Collection: Data gathered automatically when you access the Platform, including IP address, device identifiers, browser fingerprint, and behavioral interaction data collected via cookies and server logs.
• Payment Providers: Confirmation and reference data received from Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) when you initiate a financial transaction.
• Third-Party Verification Services: Identity and fraud screening data from licensed KYC and anti-money laundering service providers who verify the authenticity of your submitted documents.
• Game Software Providers: Session and outcome data transmitted from our licensed game studios (including Pragmatic Play, Evolution Gaming, Microgaming, and Pocket Games Soft) to facilitate gameplay and resolve disputes.

totojp uses the Personal Data it collects exclusively for the following purposes:

• Account Management: To create, maintain, and secure your Account, verify your identity, and process login authentication.
• Service Delivery: To make the Platform's gaming services — including casino games, live dealer tables, sports betting markets (BRI Liga 1, EPL, Champions League), and togel (Indonesia's traditional numbers lottery) draws — available to you.
• Financial Transactions: To process deposits and withdrawals securely, reconcile accounts, and maintain accurate financial records.
• Fraud Prevention & Security: To detect and prevent unauthorized access, fraudulent activity, money laundering, and platform abuse.
• Responsible Gaming: To monitor gaming behavior patterns, enforce self-exclusion requests, apply deposit limits, and identify Users who may be at risk of problem gambling.
• Legal Compliance: To meet our obligations under applicable anti-money laundering regulations, licensing requirements , and data protection laws.
• Customer Support: To respond to your inquiries, resolve disputes, and improve our support services based on interaction history.
• Platform Improvement: To analyze usage patterns, diagnose technical issues, and develop new features that enhance the User experience.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided explicit consent or where we have a legitimate interest in keeping you informed of relevant offers. You may opt out of marketing communications at any time by contacting our support team.

totojp will not use your Personal Data for any purpose that is incompatible with those listed above without first obtaining your explicit consent.

totojp processes your Personal Data on one or more of the following legal grounds:

• Contractual Necessity: Processing is required to perform the contract between you and totojp — specifically, to provide the gaming services you have registered to access and to execute financial transactions on your behalf.
• Legal Obligation: Processing is required to comply with applicable laws, including anti-money laundering regulations, age verification requirements, and regulatory reporting obligations imposed by our licensing authority.
• Legitimate Interests: Processing is necessary for totojp's legitimate business interests, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: For specific processing activities — such as optional marketing communications or the collection of sensitive data for responsible gaming purposes — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

totojp does not sell, rent, or trade your Personal Data. We share your data only in the following circumstances and strictly on a need-to-know basis:

• Payment Service Providers: Your financial data is shared with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) solely to process your deposit and withdrawal requests.
• KYC & Compliance Partners: Identity documents and verification data are shared with licensed third-party KYC and anti-money laundering screening providers to fulfill our regulatory obligations.
• Game Software Providers: Gameplay session data is shared with licensed game studios to facilitate game delivery, resolve technical disputes, and audit fairness outcomes.
• IT & Infrastructure Providers: Hosting, cloud storage, and cybersecurity vendors who process data on our behalf under strict contractual data-processing agreements and are prohibited from using your data for any purpose beyond the services they provide to us.
• Regulatory & Law Enforcement Authorities: We may disclose Personal Data where required by law, court order, or a valid request from a competent regulatory or law enforcement authority. We will notify you of any such disclosure where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all of totojp's assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

As an internationally operating platform, totojp may transfer your Personal Data to servers or service providers located outside of Indonesia. Such transfers occur when our hosting infrastructure, cloud services, or specialist third-party processors are based in jurisdictions other than Indonesia.

Where Personal Data is transferred internationally, totojp ensures that appropriate safeguards are in place, including:

• Contractual clauses with receiving parties that impose data protection obligations equivalent to those under this Privacy Policy.
• Transfers only to jurisdictions that maintain an adequate level of data protection as recognized by applicable international standards.
• Technical and organizational security measures that apply uniformly regardless of where the data is stored or processed.

If you have questions about the specific safeguards applied to any international transfer of your Personal Data, please contact our Data Protection contact at [email protected].

totojp retains your Personal Data only for as long as is necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law. The following general retention periods apply:

• Active Account Data: Retained for the full duration of your Account membership and for a minimum of five (5) years following Account closure, in compliance with anti-money laundering record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in line with standard financial regulatory requirements.
• KYC Verification Documents: Retained for a minimum of five (5) years from the date of verification or Account closure, whichever is later.
• Customer Support Correspondence: Retained for three (3) years from the date of the last interaction, for dispute resolution and service quality purposes.
• Marketing Consent Records: Retained for the duration of your consent and for two (2) years after withdrawal of consent, as evidence of compliance.
• Technical & Log Data: Server logs and technical session data are retained for up to twelve (12) months for security monitoring and fraud detection purposes.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized in accordance with our internal data destruction protocols.

As a User of the totojp Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please contact us at [email protected] with a clear description of your request. We will respond within 30 days of receipt.

Please note that certain rights may be limited where totojp has a legal obligation to retain data or where the exercise of a right would prejudice the prevention, detection, or investigation of fraud or other unlawful activity.

The totojp Platform uses cookies and similar tracking technologies to maintain session continuity, remember your preferences, detect fraud, and analyze how Users interact with the Platform. The following cookie categories are in use:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. They cannot be disabled without disrupting core Platform functionality.
• Functional Cookies: Store your language preferences, display settings, and last-visited game categories to provide a personalized experience across sessions.
• Analytics Cookies: Collect anonymized data about page visits, click paths, and session duration to help us understand how the Platform is used and identify areas for improvement. Data collected via analytics cookies does not personally identify you.
• Security & Fraud Detection Cookies: Used to identify suspicious behavioral patterns, detect bot activity, and flag potentially fraudulent login attempts.

You may manage cookie preferences through your browser settings. Blocking all cookies may impair certain Platform features, including the ability to log in and maintain a secure gaming session. totojp does not use third-party advertising or cross-site tracking cookies.

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

• 256-bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted in transit using industry-standard SSL/TLS protocols.
• Encrypted Data Storage: Personal Data and financial records are stored in encrypted form within access-controlled server environments.
• Multi-Factor Authentication: Account access can be secured with multi-factor authentication to provide an additional layer of protection beyond your password.
• Access Controls: Internal access to Personal Data is restricted to totojp personnel who have a verified operational need. Access is logged, audited, and reviewed regularly.
• Intrusion Detection Systems: Our infrastructure is monitored continuously for anomalous activity, unauthorized access attempts, and potential data breaches.
• Regular Security Audits: The Platform undergoes periodic third-party security assessments and penetration testing to identify and remediate vulnerabilities proactively.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, totojp will notify affected Users promptly in accordance with applicable data breach notification obligations.

Age verification is a mandatory step in the Account registration and KYC process. If totojp discovers that Personal Data has been collected from a User who is under 21 years of age, we will immediately suspend the Account, delete all associated Personal Data, and reverse any financial transactions where technically possible.

Parents and guardians who believe that a minor may have registered on the Platform without authorization are encouraged to contact us immediately at [email protected] so that we can take prompt remedial action.

The totojp Platform integrates with a number of third-party service providers to deliver its full range of features. While we select our partners carefully and require them to uphold data protection standards consistent with this Privacy Policy, totojp is not responsible for the privacy practices of third-party services accessed via external links or independent applications.

Third-party providers currently integrated with the Platform include licensed game studios (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft), payment infrastructure providers, and analytics platforms. Each of these providers operates under its own privacy policy and data protection obligations.

We encourage you to review the privacy policies of any third-party service you interact with directly through the Platform.

totojp reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. When material changes are made, we will update the "Last Updated" date at the top of this page and, where practicable, notify registered Users via email or an in-Platform notification.

Your continued use of the Platform following the publication of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any changes, you should stop using the Platform and may request Account closure by contacting our support team.

We recommend reviewing this Privacy Policy periodically to stay informed of how we protect and manage your Personal Data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the totojp data protection team through the following channel:

• Email: [email protected]
• Subject Line: Please mark privacy-related inquiries with "Privacy Request — [Your Full Name]" to ensure prompt handling.
• Response Time: We aim to acknowledge all privacy-related requests within 72 hours and to provide a substantive response within 30 days of receipt.
• Support Hours: 24 hours a day, 7 days a week (Western Indonesia Time, WIB / UTC+7).

If you are not satisfied with our response to a privacy concern, you have the right to escalate the matter to the relevant data protection authority in your jurisdiction or to pursue dispute resolution in accordance with our Terms & Conditions.