Privacy Policy

— Introduction

toko69 is an internationally operated online betting and gaming platform serving players across Indonesia, including major cities such as Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, Semarang, and Makassar. We are committed to protecting the privacy and security of every individual who interacts with our platform.

This Policy describes our data-handling practices in clear terms. It explains the categories of personal data we collect, the purposes for which that data is processed, the legal grounds on which we rely, and the rights you can exercise at any time. We encourage you to read this document in full alongside our Terms & Conditions.

1 Definitions

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, directly or in combination with other data.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
• "Data Controller" means toko69, which determines the purposes and means of processing personal data.
• "Data Processor" means any third party that processes personal data on behalf of toko69 under a written data-processing agreement.
• "Player" / "User" / "you" means any individual who registers an account, places a bet, or otherwise uses the toko69 platform.
• "KYC" means Know Your Customer — the identity verification process mandated for all withdrawal-eligible accounts.
• "Cookies" means small text files placed on your device by the platform to store session data, preferences, and analytics information.

2 Data We Collect

toko69 collects personal data across several categories depending on how you interact with the platform:

3 How We Collect Data

We collect personal data through the following channels:

• Direct Interaction: When you register an account, complete KYC, make a deposit or withdrawal, contact support, or respond to a promotion.
• Automated Technologies: As you browse and use the toko69 platform, we automatically collect technical and usage data via cookies, server logs, and analytics tools.
• Third-Party Sources: We may receive identity verification data from licensed KYC providers, fraud-screening services, and payment processors when you initiate a financial transaction.
• Publicly Available Sources: In limited circumstances related to fraud investigation or regulatory compliance, we may cross-reference publicly available information.

4 How We Use Your Data

toko69 uses your personal data for the following purposes:

• To create, verify, and maintain your Account in accordance with our Terms & Conditions.
• To process deposits and withdrawals via your nominated local bank (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OCBC NISP) or e-wallet (OVO, DANA, GoPay, ShopeePay, LinkAja), all denominated in Indonesian Rupiah (IDR).
• To conduct identity verification (KYC) and age confirmation to ensure compliance with the 21+ eligibility requirement.
• To detect, investigate, and prevent fraud, money laundering, collusion, and other prohibited activities as described in our Terms & Conditions.
• To monitor and support responsible gambling practices, including administering self-exclusion requests, deposit limits, and reality-check features.
• To send you transactional communications — account confirmations, withdrawal receipts, security alerts — which are non-optional service messages.
• To send promotional communications and personalized offers where you have provided explicit consent, and subject to your opt-out rights at any time.
• To analyze usage patterns and improve the platform's performance, user experience, and game offering.
• To comply with applicable legal, regulatory, and audit obligations.

5 Legal Basis for Processing

toko69 processes your personal data under the following legal grounds:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions — including account management, transaction processing, and KYC verification.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights.
• Legal Obligation: Processing required to comply with applicable laws, including anti-money-laundering (AML) requirements and data retention regulations.
• Consent: Processing for marketing communications an d personalized promotions, where you have actively opted in. You may withdraw this consent at any time.

6 Data Sharing & Disclosure

toko69 does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial purposes. We share personal data only in the following limited circumstances, and only to the extent necessary for the stated purpose:

• KYC & Identity Verification Providers: Licensed third-party services used to verify your identity, age, and document authenticity before withdrawals are processed.
• Payment Processors: Banks and e-wallet operators (including BCA, BRI, BNI, Mandiri, OVO, DANA, and GoPay) that facilitate your deposit and withdrawal transactions in IDR.
• Fraud Prevention & Security Services: Specialist providers that help us detect and prevent unauthorized access, collusion, bonus abuse, and financial crime.
• Game Studio Providers: Content providers such as Pragmatic Play, Evolution Gaming, Spribe, and Pocket Games Soft receive limited session and wagering data necessary to deliver their games and verify RTP accuracy.
• Legal & Regulatory Authorities: We may disclose personal data to law enforcement, regulatory bodies, or courts when required to do so by applicable law or a valid legal order.
• Professional Advisors: Lawyers, auditors, and compliance consultants acting under strict confidentiality obligations where disclosure is necessary for the provision of professional services.

7 International Data Transfers

As an internationally operated platform, toko69 may transfer your personal data to servers or service providers located outside of Indonesia. Where such transfers occur, we take appropriate safeguards to ensure that your data receives a level of protection consistent with this Policy and applicable data protection standards.

These safeguards may include the use of standard contractual clauses, data-processing agreements with security requirements, or transfers to jurisdictions that maintain recognized data protection frameworks. If you have questions about the specific safeguards applicable to a given transfer, please contact us using the details in Section 14.

8 Data Retention

toko69 retains personal data only for as long as is necessary to fulfill the purposes described in this Policy, or as required by applicable legal, regulatory, accounting, or audit obligations. The following general retention periods apply:

• Active Account Data: Retained for the full duration of your account membership plus a minimum of five (5) years following account closure, to satisfy anti-money-laundering record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification, in accordance with standard regulatory requirements applicable to online gaming operators.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, including all deposit and withdrawal records denominated in IDR.
• Technical & Usage Logs: Typically retained for up to thirteen (13) months for analytics and security purposes, after which they are deleted or anonymized.
• Marketing Consent Records: Retained for the duration of your account plus three (3) years, to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Anonymized aggregate data (from which no individual can be identified) may be retained indefinitely for statistical and business-improvement purposes.

9 Data Security

toko69 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• Encryption of sensitive data at rest, including financial records and identity documents.
• Multi-factor authentication (MFA) options for player accounts and mandatory MFA for all internal administrative access.
• Regular penetration testing and independent security audits by certified third-party specialists.
• Strict role-based access controls ensuring that only authorized personnel can access specific categories of personal data on a need-to-know basis.
• 24/7 automated monitoring for suspicious activity, brute-force attempts, and anomalous login behavior.

In the event of a personal data breach that is likely to result in a risk to your rights or freedoms, toko69 will notify affected players and relevant authorities within the timeframes required by applicable law.

10 Cookies & Tracking Technologies

toko69 uses cookies and similar tracking technologies to deliver a functional, personalized, and secure platform experience. The following categories of cookies are used:

You can manage or disable non-essential cookies through your browser's privacy settings. Note that disabling certain cookies may affect the functionality of the toko69 platform. Strictly necessary cookies cannot be disabled without preventing core platform features from operating correctly.

11 Your Rights

As a registered player on toko69, you hold the following rights with respect to your personal data. To exercise any of these rights, please contact us using the details provided in Section 14. We will respond to all verified requests within thirty (30) days.

• Right of Access: You may request a copy of the personal data we hold about you, including the categories of data, the purposes for which it is processed, and any third parties with whom it has been shared.
• Right to Rectification: You may request that we correct any inaccurate or incomplete personal data. For basic profile corrections, you may also update your details directly within your Account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal obligation to retain certain records for regulatory purposes.
• Right to Restriction: You may request that we limit the processing of your personal data in specific circumstances, such as while a rectification request is being investigated.
• Right to Data Portability: You may request a machine-readable copy of the personal data you have provided to us, where processing is based on consent or contractual necessity.
• Right to Object: You may object to processing based on legitimate interests, including profiling for marketing purposes. You may also opt out of all marketing communications at any time.
• 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.

12 Minors

The toko69 platform is strictly intended for adults aged 21 years and older. We do not knowingly collect personal data from individuals under the age of 21. If you are a parent or guardian and believe that a minor has registered an account or provided personal data to toko69, please contact us immediately at the email address listed in Section 14.

Upon receiving a verified report of a minor's registration, toko69 will promptly suspend the account, delete the associated personal data to the fullest extent permitted by law, and take appropriate steps to prevent future access by the same individual. Any balance held in a minor's account will be handled in accordance with our Terms & Conditions.

13 Policy Amendments

toko69 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or platform operations. When material changes are made, we will notify registered players by email or through a prominent notice on the platform prior to the change taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how we protect your personal data. Your continued use of the platform following the publication of any amendment constitutes acceptance of the revised Policy.

14 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a complaint about how toko69 has handled your personal data, please contact our Data Protection team. Our support team is available 24 hours a day, 7 days a week, with Indonesian-speaking agents available across all time zones — WIB (UTC+7), WITA (UTC+8), and WIT (UTC+9).

Email: [email protected]
Subject Line: Please include "Privacy Request" or "Data Complaint" in your subject line for faster routing.
Response Time: We aim to acknowledge all privacy-related requests within 48 hours and resolve them within 30 calendar days.

If you are dissatisfied with our response to a privacy complaint, you have the right to escalate your concern to the relevant data protection authority or regulatory body in your jurisdiction.