Privacy Policy

1. Introduction

tor138 ("we," "us," "our") operates an online betting and casino platform at https://tor138.cam (the "Platform"). We collect and process personal information from users ("you," "your") who register accounts and use our services. This Privacy Policy applies to all users accessing the Platform from Indonesia and explains our data handling practices in accordance with international privacy standards and applicable Indonesian regulations.

We recognize the importance of safeguarding your personal data and maintaining your trust. This policy outlines the types of information we collect, the purposes for which we process it, the security measures we implement, and your rights as a data subject. By creating an account or using tor138 services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information as described herein.

2. Information We Collect

2.1 Information You Provide Directly

When you register an account with tor138, we collect the following personal information:

• Identity Information: Full legal name, date of birth, gender, nationality, and Indonesian national ID number (KTP) as required for Know Your Customer (KYC) verification.
• Contact Information: Email address, mobile phone number, residential address (street, city, postal code, province).
• Account Credentials: Username, password (stored in encrypted form), and security questions/answers.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account information (OVO, DANA, GoPay, ShopeePay), and payment card details if applicable.
• Verification Documents: Copies of your Indonesian national ID (KTP), proof of address documents (utility bills, bank statements), and selfie photographs holding your ID for identity verification purposes.
• Communication Data: Records of your interactions with our customer support team via Live Chat, email, WhatsApp, including message content, timestamps, and support ticket details.

2.2 Information Collected Automatically

When you access and use the tor138 Platform, we automatically collect certain technical and usage information:

• Device Information: Device type (desktop, mobile, tablet), operating system, browser type and version, screen resolution, and device identifiers.
• Connection Information: IP address, internet service provider (ISP), referring/exit pages, and time zone setting.
• Usage Data: Pages viewed, features used, time spent on pages, navigation paths, click patterns, game play history, betting activity, deposit and withdrawal transactions, bonus claims, and session duration.
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar tracking technologies to enhance user experience, analyze site traffic, personalize content, and prevent fraud. See Section 8 for detailed cookie information.

2.3 Information from Third Parties

We may receive personal information about you from third-party sources, including:

• Payment Processors: Transaction status, payment method verification, and fraud detection signals from banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay).
• Identity Verification Services: Confirmation of identity document authenticity, age verification, address validation, and sanctions screening from third-party KYC service providers.
• Marketing Partners: Referral source data, affiliate tracking information, and campaign performance metrics (if you arrived via an affiliate link).
• Public Databases: Information from publicly available sources to verify identity and prevent fraud, including government databases and sanctions lists.

3. How We Use Your Information

tor138 collects and processes your personal data for the following legitimate business purposes:

3.1 Account Management and Service Delivery

• Create, maintain, and manage your user account.
• Authenticate your identity and verify you meet eligibility requirements (21+ years of age, Indonesian residency).
• Process deposits, withdrawals, and other financial transactions securely.
• Provide access to games, sports betting markets, togel draws, live casino tables, and other Platform features.
• Record and settle bets, calculate winnings, and update account balances in real-time.
• Manage bonuses, promotions, and loyalty rewards according to stated terms and conditions.

3.2 Legal and Regulatory Compliance

• Comply with KYC (Know Your Customer) and AML (Anti-Money Laundering) regulations mandated by our gaming license and international law.
• Verify that users are of legal gambling age (21+) and not located in restricted jurisdictions.
• Detect and prevent fraud, money laundering, terrorist financing, and other illegal activities.
• Respond to law enforcement requests, court orders, legal processes, and regulatory audits.
• Maintain records as required by gaming authorities and financial regulators.
• Report suspicious transactions to relevant authorities when legally obligated to do so.

3.3 Security and Fraud Prevention

• Protect the Platform and users from fraud, hacking, account takeovers, and unauthorized access.
• Monitor betting patterns to detect collusion, bonus abuse, arbitrage betting, and other prohibited activities.
• Implement risk scoring and fraud detection systems using machine learning algorithms.
• Block or restrict accounts engaged in suspicious, fraudulent, or terms-violating behavior.
• Investigate disputes, chargebacks, and payment discrepancies.

3.4 Customer Support and Communication

• Respond to your inquiries, support requests, and complaints via Live Chat, email, WhatsApp, and in-app messaging.
• Send transactional notifications including deposit confirmations, withdrawal status updates, bonus activations, and account security alerts.
• Provide customer service in both English and Indonesian languages through our 24/7 support team.
• Conduct customer satisfaction surveys to improve service quality.

3.5 Marketing and Personalization (With Consent)

• Send promotional emails, SMS messages, and in-app notifications about new games, bonus offers, tournaments, and special events (only if you have opted in to marketing communications).
• Personalize your gaming experience by recommending games based on your play history and preferences.
• Display targeted advertisements and promotional banners relevant to your interests.
• Analyze user behavior to improve marketing campaigns and promotional strategies.
• Award VIP perks, exclusive bonuses, and loyalty rewards based on your activity level.

3.6 Platform Improvement and Analytics

• Analyze site usage patterns, user flows, and engagement metrics to enhance Platform functionality and user experience.
• Conduct A/B testing to optimize page layouts, game offerings, and promotional effectiveness.
• Identify technical issues, bugs, and performance bottlenecks to maintain Platform stability.
• Develop new features, games, and services based on user feedback and behavior analysis.
• Generate aggregate statistical reports for business intelligence purposes (always anonymized and non-identifiable).

4. Legal Basis for Processing

Under international data protection laws, tor138 processes your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our Terms & Conditions agreement with you, including account creation, transaction processing, game delivery, and customer support.
• Legal Obligation: Processing is required to comply with legal and regulatory requirements, including KYC/AML laws, age verification mandates, and gaming license obligations.
• Legitimate Interests: Processing serves our legitimate business interests in fraud prevention, security, platform optimization, and business analytics, balanced against your privacy rights.
• Consent: For marketing communications and non-essential cookies, we obtain your explicit consent, which you can withdraw at any time.

5. How We Share Your Information

tor138 does not sell your personal data to third parties for marketing purposes. However, we may share your information with the following categories of recipients for legitimate business reasons:

5.1 Service Providers and Business Partners

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP), e-wallet providers (OVO, DANA, GoPay, ShopeePay), and payment gateway services that process deposits and withdrawals on our behalf.
• Identity Verification Services: Third-party KYC providers that verify your identity documents, age, and address to ensure compliance with regulations.
• Game Providers: Software developers (Pragmatic Play, Evolution Gaming, NetEft, Microgaming, Spribe, Pocket Games Soft) who supply games to the Platform and may process gameplay data to detect fraud and ensure fair play.
• Cloud Hosting Providers: Secure data centers that store Platform infrastructure, databases, and backups.
• Customer Support Tools: Live chat software, ticketing systems, and CRM platforms used to manage customer inquiries.
• Analytics Providers: Services that help us understand site usage, user behavior, and marketing campaign performance (data is anonymized where possible).

All third-party service providers are contractually bound to protect your data, use it only for specified purposes, and comply with applicable privacy laws.

5.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies, law enforcement, courts, or regulatory bodies when:

• Required by law, legal process, court order, subpoena, or regulatory request.
• Necessary to investigate, prevent, or take action regarding suspected illegal activities, fraud, money laundering, or threats to public safety.
• Mandated by our gaming license or applicable gambling regulations.
• Needed to protect the rights, property, or safety of tor138, our users, or the public.

5.3 Business Transfers

If tor138 undergoes a merger, acquisition, sale of assets, bankruptcy, or similar corporate event, your personal data may be transferred to the acquiring entity as part of the business assets. You will be notified of any such change via email and/or prominent notice on the Platform.

6. Data Security

tor138 takes data security seriously and implements industry-standard measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using SSL/TLS protocols (minimum 256-bit encryption). Sensitive data such as passwords and financial information is encrypted at rest using advanced cryptographic algorithms.
• Access Controls: Personal data is accessible only to authorized employees, contractors, and service providers who require it to perform their duties. Access is granted on a need-to-know basis and protected by strong authentication mechanisms.
• Secure Infrastructure: Our servers are hosted in secure, certified data centers with physical security measures including 24/7 surveillance, biometric access controls, and fire suppression systems.
• Regular Security Audits: We conduct periodic vulnerability assessments, penetration testing, and code reviews to identify and remediate security weaknesses.
• Incident Response: We maintain a data breach response plan and commit to notifying affected users and relevant authorities within 72 hours of discovering a breach involving personal data.
• Employee Training: All staff members receive regular training on data protection best practices and confidentiality obligations.

While we implement robust security measures, no internet transmission or electronic storage system is 100% secure. Users also have a responsibility to protect their account credentials and notify us immediately of any suspected unauthorized access.

7. Data Retention

tor138 retains your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy and comply with legal obligations:

• Active Accounts: Personal data is retained for the duration of your account's active status and as long as you continue using our services.
• Closed Accounts: After account closure (voluntary or involuntary), we retain identity information, transaction records, and bet history for a minimum of 7 years to comply with financial regulations, AML laws, and gaming license requirements.
• Marketing Data: If you opt out of marketing communications, we retain a record of your opt-out preference indefinitely to ensure we do not contact you again.
• Legal Holds: Data related to disputes, investigations, litigation, or regulatory inquiries is retained until the matter is fully resolved and any applicable statute of limitations has expired.
• Anonymized Data: We may retain aggregated, anonymized data indefinitely for statistical analysis and business intelligence purposes, as this data cannot identify you personally.

8. Cookies and Tracking Technologies

tor138 uses cookies (small text files stored on your device) and similar tracking technologies to enhance your experience and analyze Platform usage. Types of cookies we use include:

• Essential Cookies: Required for core Platform functionality such as login authentication, session management, and security. These cannot be disabled without impairing site usability.
• Performance Cookies: Collect anonymous data about how you use the site (pages visited, time spent, errors encountered) to help us improve performance and user experience.
• Functional Cookies: Remember your preferences (language, currency, game favorites) to provide a more personalized experience.
• Marketing Cookies: Track your browsing across sites to deliver targeted advertisements and measure campaign effectiveness (used only with your consent).

You can manage cookie preferences through your browser settings. However, disabling essential cookies may prevent you from accessing certain Platform features. Most browsers allow you to block third-party cookies while still accepting first-party cookies from tor138.

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right to Access: Request a copy of the personal information we hold about you, including details on how we process it.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data, subject to legal retention obligations (e.g., we cannot delete data required for AML compliance).
• Right to Restrict Processing: Request that we limit how we use your data in certain circumstances.
• Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format for transfer to another service.
• Right to Object: Object to processing of your data for direct marketing purposes or based on legitimate interests.
• Right to Withdraw Consent: Withdraw consent for marketing communications or optional data processing at any time (does not affect prior processing).
• Right to Complain: Lodge a complaint with a data protection authority if you believe we have violated your privacy rights.

To exercise any of these rights, please contact us at [email protected] with your account details and specific request. We will respond within 30 days. Note that we may require identity verification to prevent unauthorized data access.

10. International Data Transfers

tor138 operates internationally, and your personal data may be transferred to and processed in countries outside Indonesia where our servers, service providers, or business partners are located. These countries may have data protection laws that differ from Indonesian regulations. When we transfer your data internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by data protection authorities.
• Privacy Shield certifications (where applicable).
• Transfers to countries recognized as having adequate data protection standards.

11. Children's Privacy

tor138 services are strictly intended for individuals aged 21 and above. We do not knowingly collect personal information from anyone under 21 years of age. If we discover that we have inadvertently collected data from a minor, we will delete it immediately and close the associated account. Parents or guardians who believe their child has provided information to tor138 should contact us at [email protected] immediately.

12. Changes to This Privacy Policy

tor138 reserves the right to update this Privacy Policy periodically to reflect changes in our practices, technologies, legal requirements, or business operations. Material changes will be communicated via:

• Email notification to your registered email address.
• Prominent banner notification on the Platform.
• Updated "Last Updated" date at the top of this page.

Your continued use of tor138 services after changes take effect constitutes acceptance of the revised policy. We encourage you to review this page periodically to stay informed about how we protect your data.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: [email protected] (Data Protection Inquiries)
• WhatsApp: +62 812 3456 7890
• Live Chat: Available 24/7 through the Platform
• Postal Address: tor138 Data Protection Officer, [Full company address to be inserted]

We are committed to addressing your privacy concerns promptly and transparently. Our customer support team is available 24/7 in both English and Indonesian to assist you.