Privacy Policy

Introduction

tito76 is committed to protecting the privacy and security of your personal information. This Privacy Policy applies to all data collected through our website (https://tito76.cam), mobile applications (if applicable), and any related services, communications, or interactions with tito76 representatives.

We operate in accordance with applicable Indonesian data protection laws and international best practices for online gambling platforms. This policy should be read in conjunction with our Terms & Conditions, which govern the overall use of the tito76 platform.

Data Controller

The data controller responsible for your personal information is tito76. For all data protection inquiries, requests to exercise your privacy rights, or concerns about how your data is handled, please contact us at:

• Email: [email protected] (plain text only — not a clickable link)
• Response Time: We aim to respond to all privacy-related inquiries within 48 hours during business days (WIB).

Information We Collect

tito76 collects several categories of personal data to provide our services, comply with legal obligations, and improve user experience. The information we collect includes:

Account Registration Data

• Full legal name (as it appears on your KTP)
• Date of birth
• Email address
• Indonesian mobile phone number
• Username and encrypted password
• Residential address (city and province)

KYC Verification Documents

• Photographs or scans of your Indonesian KTP (National Identity Card)
• Selfie photograph holding your KTP (identity verification)
• Proof of payment method (bank statement, mobile banking screenshot)
• NIK (National Identification Number) extracted from KTP

Payment & Transaction Data

• Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, etc.)
• E-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Deposit amounts, dates, and times
• Withdrawal amounts, dates, and processing status
• Transaction history and account balance records

Betting Activity & Usage Data

• Wagers placed (sport, event, market, odds, stake amount, outcome)
• Casino game sessions (game type, duration, bet history, RTP)
• Account login timestamps and IP addresses
• Device information (browser type, operating system, screen resolution)
• Bonus claims, wagering progress, and promotions engaged with

Communications & Support Interactions

• Live chat transcripts and support ticket history
• Email correspondence with tito76 support or marketing teams
• Feedback, survey responses, and reviews submitted by you

How We Use Your Data

tito76 processes your personal data for the following purposes:

Legal Basis for Processing

Under Indonesian data protection principles, tito76 relies on the following legal bases for processing your personal data:

• Contractual Necessity: Processing is necessary to fulfill our Terms & Conditions and deliver betting services to you (account management, deposits, withdrawals, bet settlement).
• Legal Obligation: Processing is required to comply with Indonesian anti-money laundering (AML) laws, Know Your Customer (KYC) regulations, and responsible gaming obligations.
• Legitimate Interests: Processing is necessary for fraud prevention, security monitoring, platform improvement, and customer support — interests that do not override your fundamental privacy rights.
• Consent: For marketing communications and non-essential cookies, we rely on your explicit opt-in consent, which you may withdraw at any time.

Data Sharing & Third-Party Partners

tito76 does not sell, rent, or trade your personal data to third parties for marketing purposes. However, we do share your data with trusted service providers who assist us in delivering our platform services:

• Payment Processors: We share your payment details with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, etc.) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals. These partners operate under their own privacy policies.
• KYC Verification Services: Your KTP documents and selfie photos may be processed by third-party identity verification platforms that use optical character recognition (OCR) and facial recognition to confirm your identity. All partners are bound by strict confidentiality agreements.
• Game Providers: When you play casino games or live dealer games, your betting data (stake amounts, game outcomes) is shared with game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, and Spribe to deliver game sessions and calculate RTP.
• Cloud Hosting & Infrastructure: tito76 uses secure cloud servers to store encrypted data. Our hosting partners do not have access to unencrypted personal information.
• Customer Support Tools: Live chat and support ticket platforms may process your communications. These tools are configured to respect Indonesian data residency requirements where applicable.
• Law Enforcement & Regulators: We may disclose your data to Indonesian authorities if required by law, court order, or regulatory investigation.

KYC Verification Process

Know Your Customer (KYC) verification is a mandatory process required by Indonesian anti-money laundering regulations and international gambling compliance standards. tito76 requires all members to complete KYC verification before processing withdrawals.

What Documents We Require:

• A clear photograph or scan of the front of your Indonesian KTP (National Identity Card). The document must be valid, unaltered, and display your full name, date of birth, NIK, photograph, and issuing authority.
• A selfie photograph of you holding your KTP next to your face, ensuring both your face and the KTP details are clearly visible in a single image.
• Proof of payment method: a bank statement, mobile banking screenshot, or e-wallet account summary showing your name and the last four digits of the account number used for deposits.

How We Handle Your Documents:

• All KYC documents are encrypted immediately upon upload using AES-256 encryption.
• Documents are reviewed by trained tito76 compliance staff within 24–48 hours (WIB business days).
• Once your identity is verified, original document images are retained in our secure archive for the legally required retention period (see Section 9).
• We never share your KYC documents with unauthorized third parties, advertisers, or data brokers.

Cookies & Tracking Technologies

tito76 uses cookies and similar tracking technologies to enhance your browsing experience, analyze platform usage, and deliver personalized services.

What Are Cookies? Cookies are small text files stored on your device by your web browser when you visit a website. They allow the site to remember your preferences, keep you logged in, and understand how you use the platform.

Types of Cookies We Use

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies will prevent you from using key features of the tito76 platform, such as logging in or placing wagers.

Data Retention

tito76 retains your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

• Active Account Data: Retained for the duration of your account's active status, plus any legally required period following account closure.
• KYC Documents: Retained for a minimum of 5 years after your last transaction, as required by Indonesian anti-money laundering regulations.
• Transaction Records: Retained for 7 years to comply with tax and financial audit requirements.
• Betting History: Retained for 5 years to support dispute resolution and responsible gaming monitoring.
• Marketing Communications: If you opt out of marketing emails, your email address is retained in our suppression list to ensure we do not contact you again, but all other marketing data is deleted within 30 days.
• Inactive Accounts: If your account remains inactive (no login, no balance) for 24 consecutive months, we may archive or anonymize your data, retaining only what is necessary for legal compliance.

Data Security Measures

tito76 employs industry-standard technical and organizational measures to protect your personal data from unauthorized access, loss, misuse, alteration, or destruction.

• SSL Encryption: All data transmitted between your device and tito76 servers is encrypted using 256-bit SSL/TLS protocols.
• Database Encryption: Sensitive data (passwords, KYC documents, payment details) is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized tito76 staff who require it to perform their duties. All access is logged and monitored.
• Two-Factor Authentication (2FA): We strongly encourage all members to enable 2FA on their accounts for an additional layer of security.
• Regular Security Audits: tito76 conducts quarterly security assessments, penetration testing, and vulnerability scans to identify and remediate potential risks.
• Employee Training: All tito76 staff undergo mandatory data protection and cybersecurity training annually.

Your Privacy Rights

Under Indonesian data protection principles and international best practices, you have the following rights regarding your personal data held by tito76:

• Right to Access: You may request a copy of all personal data we hold about you, including account information, transaction history, betting records, and KYC documents.
• Right to Rectification: If any of your personal information is inaccurate or incomplete, you may request that we correct or update it.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data, subject to our legal retention obligations (e.g., AML and tax regulations require us to retain certain records for 5–7 years).
• Right to Restrict Processing: You may request that we temporarily suspend processing of your data while we verify its accuracy or resolve a dispute.
• Right to Data Portability: You may request a machine-readable export of your personal data for transfer to another service provider.
• Right to Object: You may object to processing based on legitimate interests (e.g., marketing communications). We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: If processing is based on your consent (e.g., marketing emails), you may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

How to Exercise Your Rights: To exercise any of these rights, please email [email protected] with the subject line "Privacy Rights Request". Include your full name, registered email address, and a description of your request. We will respond within 14 business days (WIB).

Children's Privacy & Age Verification

tito76 is strictly for users who are at least 21 years of age. We do not knowingly collect, process, or store personal data from individuals under 21.

If we discover that a user is under 21, we will immediately suspend the account, refund any deposited funds to the registered payment method, and delete all associated personal data (except what is required to be retained for legal compliance and to prevent re-registration).

Parents and guardians: if you believe your child has provided personal information to tito76, please contact us immediately at [email protected] so we can take appropriate action.

International Data Transfers

While tito76 primarily serves Indonesian players and stores data within Indonesia or ASEAN-region data centers, certain third-party service providers (game studios, payment processors, cloud infrastructure) may process your data on servers located outside Indonesia.

When we transfer your data internationally, we ensure that appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs) approved by data protection authorities
• Service providers located in jurisdictions with adequate data protection laws
• Encryption of data in transit and at rest

By using tito76, you consent to the transfer of your data to these jurisdictions as necessary to deliver our services.

Changes to This Privacy Policy

tito76 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features.

When we make material changes to this policy, we will notify you by:

• Updating the "Last Updated" date at the top of this page
• Sending an email notification to your registered email address (for significant changes)
• Displaying a prominent notice on the tito76 homepage or login screen

Your continued use of the platform after the updated Privacy Policy takes effect constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how we protect your data.

Contact & Data Protection Inquiries

If you have any questions, concerns, or requests regarding this Privacy Policy or how tito76 handles your personal data, please contact us:

• Email: [email protected] (plain text only — not a clickable link)
• Subject Line for Privacy Requests: "Privacy Rights Request" or "Data Protection Inquiry"
• Response Time: We aim to respond to all privacy inquiries within 48 hours during business days (WIB). For formal data subject access requests, we will respond within 14 business days as required by law.

Our customer support team is available 24/7 via live chat on the tito76 website, and all staff are trained to handle privacy-related questions with confidentiality and care.