Privacy Policy

1. Introduction

togeup ("we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard personal data when you access or use our online betting platform at togeup.cam, create an account, place bets, or interact with our services.

This Privacy Policy applies to all users of togeup services, including residents of Indonesia who access our platform for sports betting, togel (lottery), casino games, slots, and other betting products. We recognize the importance of data privacy in the digital age and have implemented comprehensive measures to ensure your information is handled responsibly and in compliance with applicable Indonesian data protection laws and international best practices.

By creating an account on togeup, depositing funds, placing bets, or otherwise using our services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with our data practices, you should not use togeup services.

2. Data Controller

togeup operates as the data controller responsible for the collection, processing, and protection of your personal information. As the data controller, we determine the purposes and means of processing your personal data in accordance with this Privacy Policy and applicable Indonesian data protection regulations.

For all privacy-related inquiries, data subject requests, or concerns regarding how togeup handles your personal information, please contact our Data Protection Officer through the contact details provided in Section 14 of this Privacy Policy.

3. Information We Collect

To provide togeup services, process transactions, verify your identity, and comply with legal obligations, we collect several categories of personal information:

3.1 Information You Provide Directly

• Account Registration Data: When you create a togeup account, we collect your full legal name, date of birth, residential address in Indonesia, email address, mobile phone number, and chosen username and password.
• Identity Verification Documents: To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, we require submission of government-issued identification, typically your KTP (Kartu Tanda Penduduk) or passport. We collect document images, identification numbers, and biometric data embedded in these documents.
• Financial Information: Bank account details (account number, bank name, account holder name) and e-wallet information (OVO, DANA, GoPay, ShopeePay, LinkAja account IDs) for processing deposits and withdrawals. We also collect transaction history, deposit amounts, withdrawal requests, and betting activity.
• Communications: Content of messages you send to our customer support team via live chat, email, WhatsApp, or in-app messaging, including any attachments, screenshots, or documentation you provide.
• Survey and Feedback Data: Responses to voluntary surveys, reviews, testimonials, or feedback forms you choose to complete.

3.2 Information Collected Automatically

• Device and Browser Information: IP address, device type (desktop, mobile, tablet), operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, features accessed, time spent on pages, navigation paths through the site, referring URLs, clickstream data, and interaction patterns with games and betting markets.
• Transaction Logs: Detailed records of all bets placed, games played, deposits made, withdrawals requested, bonuses claimed, and promotional activity, including timestamps, amounts, game types, and outcomes.
• Geolocation Data: Approximate geographic location derived from IP address to verify you are accessing togeup from within Indonesia and to comply with geo-restriction requirements.
• Cookies and Similar Technologies: Information collected through cookies, web beacons, local storage, and similar tracking technologies (see Section 10 for details).

3.3 Information from Third Parties

• Payment Processors: Confirmation of successful deposits and withdrawals, payment method verification, and fraud screening data from Indonesian banks (BCA, BRI, BNI, Mandiri, etc.) and e-wallet providers.
• Game Providers: Game outcomes, RTP (Return to Player) statistics, session data, and technical performance metrics from third-party game studios like Pragmatic Play, Evolution Gaming, Microgaming, and others.
• Identity Verification Services: Results of automated document verification, facial recognition matching, and fraud risk scores from third-party KYC service providers.
• Marketing Partners: Referral source data and campaign tracking information if you accessed togeup through an affiliate link or marketing campaign (we do not purchase personal data from third-party data brokers).

4. How We Use Your Information

togeup uses the personal information we collect for the following purposes:

• Account Management: Creating and maintaining your togeup account, authenticating your identity when you log in, and managing your account settings and preferences.
• Transaction Processing: Processing deposits, withdrawals, bet placements, game play, bonus crediting, and all financial transactions associated with your account.
• Identity Verification and KYC Compliance: Verifying your age (21+ requirement), confirming your identity matches the payment methods you use, and complying with Indonesian Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations.
• Customer Support: Responding to your inquiries, resolving disputes, investigating complaints, and providing technical assistance through our 24/7 Indonesian-speaking support team.
• Security and Fraud Prevention: Detecting and preventing fraudulent activity, unauthorized account access, bonus abuse, multi-accounting, collusion, match-fixing, and other prohibited activities outlined in our Terms & Conditions.
• Responsible Gaming: Monitoring betting behavior for signs of problem gambling, enforcing deposit limits and self-exclusion settings, and providing intervention when concerning patterns are detected.
• Product Improvement: Analyzing usage patterns, user preferences, and platform performance to improve game offerings, betting markets, payment options, and user experience.
• Marketing and Promotions: Sending promotional emails, bonus offers, VIP program updates, and personalized recommendations based on your betting preferences (you may opt out of marketing communications at any time).
• Legal Compliance: Complying with Indonesian laws and regulations, responding to legal requests from government authorities, and maintaining records required for regulatory audits.
• Business Operations: Conducting internal analytics, generating reports for management and regulators, performing accounting and tax compliance, and managing business risk.

5. Legal Basis for Processing

Under Indonesian data protection principles and international privacy standards, togeup processes your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions you agreed to when registering). This includes account creation, transaction processing, game provision, and customer support.
• Legal Obligation: Processing is required to comply with Indonesian laws and regulations, including KYC/AML requirements, tax reporting obligations, age verification mandates, and regulatory record-keeping requirements.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, platform improvement, and direct marketing, provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: For certain processing activities (such as optional marketing communications or non-essential cookies), we obtain your explicit consent, which you may withdraw at any time through your account settings.

6. Data Sharing and Third Parties

togeup does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we share your data with the following categories of third parties as necessary to operate our services:

6.1 Service Providers

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals.
• Identity Verification Services: Third-party KYC/AML compliance providers that verify your identity documents and screen for fraud risk.
• Game Providers: Software studios such as Pragmatic Play, Evolution Gaming, Microgaming, Pocket Games Soft, and others that power our casino games, slots, and live dealer tables. These providers receive limited data necessary to operate games (username, bet amounts, game sessions).
• Cloud Hosting and Infrastructure: Secure data centers and cloud service providers that host our servers, databases, and application infrastructure.
• Customer Support Tools: Live chat platforms, email systems, and ticketing software used by our support team to assist users.

6.2 Legal and Regulatory Authorities

We disclose personal data to Indonesian government authorities, law enforcement agencies, tax authorities, and financial regulators when required by law, court order, subpoena, or regulatory investigation. This includes reports of suspicious transactions for AML compliance and responses to legitimate legal requests.

6.3 Business Transfers

In the event togeup undergoes a merger, acquisition, corporate reorganization, or sale of assets, your personal information may be transferred to the acquiring entity as part of the transaction, subject to the same privacy protections outlined in this policy.

6.4 Data Processing Agreements

All third-party service providers with access to your personal data are bound by written data processing agreements requiring them to protect your information, use it only for specified purposes, and comply with applicable data protection laws. We conduct due diligence on service providers' security practices before engagement.

7. Data Security Measures

togeup employs industry-standard technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and togeup servers is encrypted using TLS (Transport Layer Security) protocols. Sensitive data stored in our databases, including passwords and financial information, is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized togeup employees and contractors who require access to perform their duties. Access is granted on a need-to-know basis and protected by role-based permissions, multi-factor authentication, and regular access reviews.
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, DDoS mitigation, and regular security monitoring to prevent unauthorized access and cyberattacks.
• Security Audits: We conduct regular internal security audits, vulnerability assessments, and penetration testing to identify and remediate potential security weaknesses. Third-party security firms periodically review our systems.
• Employee Training: All togeup staff with access to personal data receive mandatory privacy and security training, including protocols for handling sensitive information and responding to data breaches.
• Incident Response: We maintain a documented incident response plan for detecting, investigating, and responding to data breaches or security incidents, including timely notification to affected users and authorities as required by law.

While we implement robust security measures, no system is entirely impervious to attack. You also play a role in security by keeping your password confidential, logging out after sessions on shared devices, and promptly reporting suspicious account activity to our support team.

8. Data Retention

togeup retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods:

• Active Account Data: Retained for the duration of your active account plus seven years following account closure to comply with Indonesian financial record-keeping requirements and potential legal claims.
• Transaction Records: Retained for a minimum of seven years as required by Indonesian tax and AML regulations.
• Identity Verification Documents: KTP and other identification documents are retained for seven years following account closure for regulatory compliance and potential dispute resolution.
• Communications: Customer support communications are retained for three years to facilitate ongoing support and training.
• Marketing Data: If you opt out of marketing communications, your contact information is retained on our suppression list indefinitely to ensure we honor your opt-out preference.

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

9. Your Privacy Rights

Under Indonesian data protection principles and international privacy standards, you have the following rights regarding your personal data:

• Right of Access: You may request a copy of the personal data togeup holds about you, including details on how it is used, with whom it is shared, and how long it will be retained.
• Right of Rectification: You may request correction of inaccurate or incomplete personal data. For most account information, you can update details directly through your account settings.
• Right of Erasure: You may request deletion of your personal data under certain circumstances, such as when data is no longer necessary for the purposes collected, you withdraw consent, or you object to processing. Note that legal obligations may prevent immediate deletion of some data (e.g., transaction records).
• Right to Restrict Processing: You may request that we limit how we use your data while verifying its accuracy or assessing whether legitimate grounds exist for processing.
• Right to Data Portability: You may request a machine-readable copy of your personal data to transfer to another service provider, where technically feasible.
• Right to Object: You may object to processing of your personal data for direct marketing purposes (opt-out) or processing based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time, without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 14. We will respond to your request within 30 days and may require identity verification before processing requests to protect your data from unauthorized access.

10. Cookies and Tracking Technologies

togeup uses cookies, web beacons, and similar technologies to enhance user experience, analyze platform usage, remember preferences, and deliver personalized content. Key categories of cookies we use:

• Essential Cookies: Strictly necessary for platform functionality, including login sessions, security features, and transaction processing. These cannot be disabled without affecting core functionality.
• Performance Cookies: Collect anonymous data on how users interact with togeup, including page views, navigation paths, and feature usage, helping us improve platform design and performance.
• Functionality Cookies: Remember your preferences such as language settings, display options, and previously viewed games to personalize your experience.
• Marketing Cookies: Track your activity across the platform to deliver relevant promotional offers, bonus recommendations, and targeted marketing communications. You may opt out through cookie settings.

You can manage cookie preferences through your browser settings. Note that blocking essential cookies will prevent you from accessing certain togeup features. For more granular control, adjust settings in your togeup account dashboard.

11. International Data Transfers

While togeup primarily serves Indonesian users and stores data within Indonesia or the Asia-Pacific region, some service providers (such as cloud hosting infrastructure or game studios) may be located outside Indonesia. When personal data is transferred internationally, we ensure adequate safeguards are in place, including:

• Execution of Standard Contractual Clauses (SCCs) approved for international data transfers.
• Verification that receiving countries provide adequate data protection standards equivalent to Indonesian requirements.
• Implementation of supplementary security measures such as encryption in transit and at rest.

We do not transfer personal data to jurisdictions with inadequate data protection frameworks unless legally required and with appropriate safeguards in place.

12. Children's Privacy

togeup services are strictly for adults aged 21 and older. We do not knowingly collect personal information from individuals under the age of 21. Our registration process includes mandatory date of birth verification and KTP document checks to enforce this age restriction.

If we discover that we have inadvertently collected personal data from a minor, we will immediately delete such information and close the associated account. Parents or guardians who believe their child has provided information to togeup should contact us immediately at the details provided in Section 14.

13. Changes to This Privacy Policy

togeup reserves the right to update, modify, or amend this Privacy Policy at any time to reflect changes in our data practices, services offered, legal requirements, or technological developments. Material changes will be communicated to users via email to the registered email address and through prominent notification on the togeup platform.

The "Last Updated" date at the top of this document indicates the most recent revision. We encourage you to review this Privacy Policy periodically. Continued use of togeup services following policy updates constitutes your acceptance of the revised terms.

14. Contact Information

For questions, complaints, or requests regarding this Privacy Policy or how togeup handles your personal data, please contact us through the following channels:

• Data Protection Officer Email: Available in your togeup account dashboard under "Privacy Settings"
• General Support Email: [email protected] (plain text display only)
• 24/7 Live Chat: Accessible from your account dashboard and togeup homepage
• In-App Secure Messaging: Contact privacy team directly through your account's secure messaging system

Our Data Protection Officer and privacy team are committed to addressing your concerns promptly and transparently. We aim to respond to all privacy inquiries within 72 hours and resolve data subject requests within 30 days.