tito12 Privacy Policy

1 Introduction

tito12 ("the Company", "we", "us", or "our") operates the online betting and live casino platform accessible at https://tito12.cam. We are committed to protecting and respecting the privacy of every individual who visits our website or holds a tito12 member account.

This Privacy Policy sets out the basis on which any personal data we collect from you — or that you provide to us — will be processed by tito12. It applies to all users of the Platform, including prospective members who browse without registering, registered members based in Indonesia, and any individual who contacts our customer support team.

Please read this policy carefully to understand our views and practices regarding your personal data and how we treat it. This Privacy Policy forms part of, and should be read alongside, our Terms and Conditions. By accessing the tito12 Platform, you acknowledge that you have read and understood the practices described in this policy.

2 Personal Data We Collect

tito12 collects and processes the following categories of personal data, depending on your relationship with the Platform:

We do not intentionally collect sensitive personal data such as racial or ethnic origin, religious beliefs, health information, or political opinions. If any such information is inadvertently provided (e.g., in a support message), it will not be stored or processed beyond what is necessary to respond to your query.

3 How We Collect Your Data

tito12 collects personal data through the following channels:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, submitting a support ticket, or communicating with our team via live chat or email;
• Automated technologies: Technical and usage data collected automatically as you navigate the Platform, including through cookies, server logs, and similar tracking technologies (see Section 8 — Cookies);
• Payment processors: Transaction confirmation data shared with us by our payment processing partners when you use bank transfer or e-wallet services;
• Identity verification providers: Results and data returned by third-party KYC and identity verification services we engage to validate the documents you submit;
• Fraud prevention services: Risk signals and device fingerprinting data provided by fraud-detection partners to help us identify suspicious activity;
• Referral partners: If you registered via an affiliate or referral link, we may receive basic registration metadata from the referring party.

4 How We Use Your Personal Data

tito12 uses the personal data we collect for the following specific purposes:

• Account management: Creating, maintaining, and administering your tito12 member account, including processing login requests, updating account details, and managing membership tier status;
• Identity verification (KYC): Verifying your identity and age (21+) in compliance with our anti-money laundering and responsible gaming obligations before approving withdrawals or unlocking certain account features;
• Payment processing: Facilitating deposits and withdrawals via your nominated Indonesian bank account (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) or e-wallet (OVO, DANA, GoPay, ShopeePay, LinkAja), and maintaining accurate transaction records;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, unauthorized account access, bonus abuse, multi-accounting, and other prohibited conduct described in our Terms and Conditions;
• Customer support: Responding to your queries, complaints, and support requests, and maintaining records of communications for quality assurance and dispute resolution purposes;
• Platform improvement: Analyzing aggregated and anonymized usage data to understand how members interact with the Platform, identify technical issues, and develop new features and game content;
• Personalization: Tailoring the Platform experience to your preferences, including displaying relevant sports markets (e.g., BRI Liga 1, EPL, badminton), recommended games, and localized content based on your activity history;
• Marketing communications: Sending promotional offers, bonus announcements, and platform updates to members who have opted in to receive such communications. You may withdraw consent at any time via your account settings or by contacting our support team;
• Legal and regulatory compliance: Meeting obligations imposed by applicable law, including record-keeping, responding to lawful requests from authorities, and enforcing our Terms and Conditions;
• Responsible gaming: Monitoring account activity to identify indicators of problem gambling behavior and applying responsible gaming measures where appropriate, including deposit limits, time-out periods, and self-exclusion.

5 Legal Basis for Processing

tito12 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

6 Data Sharing & Third Parties

6.1 Who We Share Data With. tito12 does not sell your personal data. We may share your data with carefully selected third parties in the following circumstances:

• Payment service providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the transaction and account data necessary to process your deposits and withdrawals;
• Identity verification providers: Third-party KYC and document verification services that process the identity documents you submit during account verification, operating under strict data processing agreements with tito12;
• Fraud and security vendors: Providers of device fingerprinting, IP intelligence, and fraud risk-scoring services that help us protect members and the integrity of the Platform;
• Game content providers: Software studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive session tokens and anonymized player identifiers to deliver their games. They do not receive your full personal profile;
• Cloud and hosting infrastructure: Managed hosting, database, and content delivery network (CDN) providers who process data on our behalf under binding data processing agreements;
• Analytics providers: Aggregated and anonymized usage data may be shared with analytics platforms to help us understand Platform performance. No individually identifiable data is shared for this purpose;
• Legal and regulatory authorities: We may disclose personal data to law enforcement agencies, regulators, or courts where we are legally required to do so, or where disclosure is necessary to protect the rights, property, or safety of tito12, its members, or the public.

6.2 Third-Party Contracts. All third-party service providers with whom tito12 shares personal data are required to maintain appropriate technical and organizational security measures and to process the data only for the purposes specified in their agreements with us. We do not permit our third-party service providers to use your personal data for their own commercial purposes.

6.3 International Transfers. Some of tito12's service providers operate outside Indonesia. Where personal data is transferred internationally, we take steps to ensure that adequate safeguards are in place, including contractual protections equivalent to internationally recognized data transfer mechanisms.

7 Data Retention

7.1 Retention Periods. tito12 retains personal data for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, accounting, and reporting requirements. Our standard retention periods are as follows:

7.2 Deletion. When your personal data is no longer required to meet the applicable retention period, tito12 will securely delete or anonymize it in a manner that prevents reconstruction of the original data. Where full deletion is not immediately possible (e.g., data held in backup archives), we will isolate the data from further active processing until deletion is possible.

8 Cookies & Tracking Technologies

8.1 What Are Cookies. Cookies are small text files placed on your device by the tito12 Platform when you visit. They allow us to recognize your device across sessions, remember your preferences, and analyze how the Platform is used.

8.2 Types of Cookies We Use. tito12 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. They cannot be disabled without breaking core Platform functionality;
• Functional cookies: Remember your preferences such as language selection, timezone (WIB default), and last-visited game category to enhance your experience on return visits;
• Analytics cookies: Collect anonymized data about how visitors use the Platform — pages viewed, time on site, error pages encountered — to help us improve the user experience. No personally identifiable information is transmitted;
• Marketing cookies: Used to deliver relevant promotional messages and to measure the effectiveness of our marketing campaigns. These are only placed with your explicit consent.

8.3 Managing Cookies. You can control and delete cookies through your browser settings. Please note that disabling certain cookies may impair your ability to log in, place bets, or access live casino games. Instructions for managing cookies are available in the help documentation of your specific browser. Withdrawing consent for marketing cookies does not affect your ability to use the core Platform services.

8.4 Do Not Track. Some browsers transmit a "Do Not Track" (DNT) signal. tito12 currently does not alter its data collection practices in response to DNT signals, as no universally accepted standard for responding to such signals has been established. We will review this position as industry standards evolve.

9 Your Data Protection Rights

As a tito12 member, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact us using the details in Section 13. We will respond to all verified requests within 30 days:

Please note that certain rights are subject to limitations. For example, we cannot delete data that we are legally required to retain for AML or regulatory purposes, even if you request erasure. We will always explain clearly if a limitation applies to your specific request.

10 Data Security

10.1 Technical Measures. tito12 implements a comprehensive set of technical security controls to protect your personal data against unauthorized access, loss, destruction, or disclosure. These include:

• TLS 1.2 / TLS 1.3 encryption for all data transmitted between your browser and our servers;
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records;
• Multi-factor authentication (MFA) available for member accounts and mandatory for internal administrative access;
• Web Application Firewall (WAF) and DDoS mitigation services to protect Platform availability and prevent injection attacks;
• Intrusion detection and prevention systems (IDS/IPS) monitoring all network traffic in real time;
• Regular independent penetration testing and vulnerability scanning of Platform infrastructure;
• Isolated, access-controlled storage environments for KYC documents with full audit trails on every access event.

10.2 Organizational Measures. Access to personal data within tito12 is restricted on a strict need-to-know basis. Staff who handle personal data receive regular data protection training. All employees and contractors with access to personal data are bound by confidentiality obligations.

10.3 Your Responsibility. The security of your account also depends on you. Please use a strong, unique password for your tito12 account, do not share your login credentials with anyone, and contact us immediately via live chat if you suspect unauthorized access. tito12 will never ask for your password through any communication channel.

11 Minors & Age Restriction

The tito12 Platform is strictly intended for adults aged 21 years or older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected data from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor in your care has registered an account on tito12 or submitted personal data to us without your knowledge, please contact our support team immediately at the contact details provided in Section 13. We treat all such reports as a priority and will act promptly to investigate and remedy the situation.

tito12 employs age verification measures during the registration and KYC process, including verification of Indonesian national identity documents, to ensure compliance with the 21+ age requirement.

12 Changes to This Privacy Policy

tito12 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform services. When we make material changes, we will:

• Update the "Last updated" date at the top of this page;
• Send a notification to your registered email address at least 14 days before the changes take effect, where the changes materially affect how we use your personal data;
• Display a prominent notice on the Platform for a minimum of 14 days following publication of the updated policy.

Your continued use of the tito12 Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you should discontinue use of the Platform and may request account closure in accordance with our Terms and Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how tito12 protects your personal data. Previous versions of this policy are available upon request by contacting our support team.

13 Contact & Data Requests

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data tito12 holds about you, please reach out to us through the following channels. All data-related requests will be acknowledged within 24 hours and resolved within 30 days:

To protect your privacy, tito12 may need to verify your identity before processing a data access, rectification, or erasure request. You may be asked to provide a copy of your registered identity document and confirm your registered email address as part of this verification process.