Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by to303 through our website at to303.cam, mobile applications (if applicable), customer support channels, and any other platforms or services we operate. This policy covers personal data provided directly by you during registration, through your use of our services, and information we automatically collect through technology such as cookies and server logs.

to303 operates internationally and serves customers in multiple jurisdictions, including Indonesia. We are committed to complying with applicable data protection laws and regulations in the territories where we operate. This policy is designed to meet the requirements of international data protection standards while addressing specific considerations for our Indonesian user base.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a to303 account, we collect the following personal information:

• Identity Information: Full legal name, date of birth, gender, and nationality as shown on your government-issued identification documents
• Contact Information: Residential address, email address, and mobile phone number
• Identification Documents: Copies of your Indonesian Identity Card (KTP), passport, driver's license, or other government-issued photo identification for KYC (Know Your Customer) verification purposes
• Financial Information: Bank account details for Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, etc.) or e-wallet accounts (OVO, DANA, GoPay, ShopeePay, LinkAja) used for deposits and withdrawals
• Account Credentials: Username, password (stored in encrypted format), and security questions/answers
• Communication Records: Content of your communications with our customer support team via live chat, email, WhatsApp, or in-app messaging

2.2 Information We Collect Automatically

When you access and use to303 services, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, and unique device identifiers
• Connection Information: IP address, internet service provider, connection type (WiFi/mobile data), and approximate geographic location based on IP address
• Usage Data: Pages viewed, features used, time spent on platform, games played, bet history, deposit and withdrawal history, and click patterns
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to recognize you, remember your preferences, and analyze platform usage (see Section 8 for detailed cookie information)
• Transaction Records: Complete records of all financial transactions including deposits, withdrawals, bets placed, wins, losses, and bonus claims

2.3 Information from Third Parties

We may receive limited information about you from third-party service providers, including payment processors, identity verification services, fraud prevention companies, and regulatory authorities. This information is used solely to verify your identity, prevent fraud, and comply with legal obligations.

3. How We Use Your Information

to303 uses your personal information for the following legitimate business purposes:

Purpose	Description	Legal Basis
Account Management	Creating, maintaining, and managing your to303 account; processing registrations; and verifying your identity	Contract performance; Legal obligation
Service Delivery	Providing access to sports betting, casino games, slots, togel, and other gambling services; processing bets and payouts	Contract performance
Payment Processing	Processing deposits and withdrawals through Indonesian banks and e-wallets; maintaining transaction records; preventing payment fraud	Contract performance; Legal obligation
Customer Support	Responding to inquiries, resolving disputes, providing technical assistance, and improving service quality	Contract performance; Legitimate interest
Security & Fraud Prevention	Detecting and preventing fraud, abuse, unauthorized access, money laundering, and other illegal activities	Legal obligation; Legitimate interest
Regulatory Compliance	Meeting KYC/AML requirements, age verification, reporting to regulatory authorities, and complying with legal obligations	Legal obligation
Responsible Gaming	Implementing deposit limits, self-exclusion, and other responsible gaming tools; monitoring for problem gambling behaviors	Legal obligation; Legitimate interest
Marketing & Promotions	Sending promotional offers, bonuses, newsletters, and personalized recommendations (with your consent where required)	Consent; Legitimate interest
Platform Improvement	Analyzing usage patterns, conducting research, testing new features, and improving user experience	Legitimate interest

4. Data Sharing and Disclosure

to303 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information in the following circumstances:

4.1 Service Providers

We share personal information with trusted third-party service providers who perform services on our behalf, including payment processors (to facilitate Indonesian bank and e-wallet transactions), identity verification providers (for KYC compliance), cloud hosting services (for data storage), customer support platforms, and fraud prevention services. These providers are contractually obligated to protect your data and use it only for the specific purposes we authorize.

4.2 Legal Requirements

We may disclose your information when required by law, legal process, or government request; to enforce our Terms & Conditions; to protect the rights, property, or safety of to303, our users, or the public; or in connection with legal proceedings, investigations, or regulatory inquiries.

4.3 Business Transfers

If to303 undergoes a business transition such as a merger, acquisition, or sale of assets, your personal information may be transferred to the successor organization. You will be notified of any such change via email or prominent notice on our website.

4.4 With Your Consent

We may share your information with third parties when you have given explicit consent for such sharing.

5. Data Security Measures

to303 employs industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL (Secure Socket Layer) technology, the same standard used by banks and financial institutions
• Secure Storage: Personal information is stored on secure servers with restricted access, protected by firewalls and intrusion detection systems
• Password Protection: User passwords are hashed and encrypted; to303 staff cannot view your actual password
• Access Controls: Access to personal data is restricted to authorized employees who need it to perform their job functions, subject to strict confidentiality obligations
• Regular Security Audits: We conduct regular security assessments and vulnerability testing to identify and address potential weaknesses
• Payment Security: Financial transactions are processed through PCI DSS compliant payment gateways; we do not store complete credit card numbers or CVV codes

While we implement robust security measures, no system is completely secure. We cannot guarantee absolute security of data transmitted over the internet. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us if you suspect unauthorized access to your account.

6. Data Retention

to303 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Active Account Data: Retained for the duration of your account's active status plus any period required to resolve disputes or comply with legal obligations
• Transaction Records: Retained for a minimum of 7 years from the date of transaction to comply with financial record-keeping regulations and anti-money laundering laws
• KYC Documentation: Retained for 7 years after account closure to meet regulatory requirements
• Communication Records: Customer support communications retained for 3 years for quality assurance and dispute resolution purposes
• Marketing Consent Records: Retained for as long as necessary to demonstrate compliance with consent requirements

After the applicable retention period expires, personal information is securely deleted or anonymized so that it can no longer identify you. Anonymized data may be retained indefinitely for statistical and analytical purposes.

7. Your Privacy Rights

As a to303 user, you have the following rights regarding your personal information:

• Right to Access: You may request a copy of the personal information we hold about you. We will provide this information in a structured, commonly used format within 30 days of your request.
• Right to Rectification: You may request correction of inaccurate or incomplete personal information. You can update most information directly through your account settings.
• Right to Erasure: You may request deletion of your personal information, subject to legal retention requirements and legitimate business needs (such as ongoing transaction processing or dispute resolution).
• Right to Restrict Processing: You may request that we limit how we use your personal information in certain circumstances, such as while we verify data accuracy or assess whether we have legitimate grounds to continue processing.
• Right to Data Portability: You may request a copy of your personal information in a machine-readable format to transfer to another service provider.
• Right to Object: You may object to processing of your personal information for direct marketing purposes or when we rely on legitimate interests as the legal basis for processing.
• Right to Withdraw Consent: Where we process your data based on consent (such as marketing communications), you may withdraw that consent at any time.

To exercise any of these rights, please contact our Data Protection team via email at [email protected] with the subject line "Privacy Rights Request" or through our customer support channels. We will respond to your request within 30 days. We may require verification of your identity before processing requests to ensure security.

8. Cookies and Tracking Technologies

to303 uses cookies and similar tracking technologies to enhance your browsing experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device by your web browser. We use the following types of cookies:

• Essential Cookies: Necessary for platform functionality, including user authentication, session management, and security features. These cookies cannot be disabled without affecting site functionality.
• Performance Cookies: Collect information about how you use our platform, such as pages visited and errors encountered. This helps us improve platform performance and user experience.
• Functional Cookies: Remember your preferences (such as language settings, currency selection, and display options) to provide a more personalized experience.
• Marketing Cookies: Track your browsing activity to deliver relevant promotional offers and measure advertising effectiveness.

You can control cookie settings through your browser preferences. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may prevent you from accessing certain features or services on to303. For more information about managing cookies, visit your browser's help documentation.

9. International Data Transfers

to303 operates internationally and may transfer your personal information to servers located outside of Indonesia for processing and storage. When we transfer data internationally, we ensure appropriate safeguards are in place through contractual protections, data processing agreements, and compliance with applicable data protection regulations. Your personal information will always receive an adequate level of protection regardless of where it is processed.

10. Children's Privacy

to303 services are strictly intended for individuals aged 21 and above, in accordance with Indonesian legal requirements for online gambling. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have collected information from a person under 21, we will immediately delete that information and close the associated account. Parents and guardians should monitor their children's internet usage and prevent access to gambling websites.

11. Third-Party Links

The to303 platform may contain links to third-party websites, including payment processors, game providers, and social media platforms. This Privacy Policy applies only to information collected by to303. We are not responsible for the privacy practices of third-party websites. We recommend reviewing the privacy policies of any external sites you visit.

12. Changes to This Privacy Policy

to303 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other operational needs. When we make material changes, we will notify you by email (to the address registered in your account) or by prominent notice on our website at least 30 days before the changes take effect. The "Last Updated" date at the top of this policy indicates when it was most recently revised. Your continued use of to303 services after changes become effective constitutes acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how to303 handles your personal information, please contact us through the following channels:

• Email: [email protected] (Privacy inquiries will receive priority response within 24-48 hours)
• Live Chat: Available 24/7 on our website for immediate assistance
• WhatsApp: +62 812 3456 7890 (Monday-Sunday, 08:00-23:00 WIB)

For formal data protection inquiries or to exercise your privacy rights, please clearly indicate "Privacy Rights Request" or "Data Protection Inquiry" in your communication subject line to ensure proper routing to our Data Protection team.