Privacy Policy

1. Introduction

toge88 ("we", "us", "our", "the Platform") is an online betting platform serving players across Indonesia. We are committed to protecting the personal information of every individual who uses our platform, and to being transparent about how that information is collected and used.

This Privacy Policy sets out, in clear and accessible language, the categories of personal data we collect, the purposes for which we process it, the parties with whom we may share it, and the rights available to you as a data subject. We have structured this document to be as practical and readable as possible while meeting the obligations expected of a responsible international gaming operator serving the Indonesian market.

This policy should be read alongside our Terms & Conditions, which govern the overall contractual relationship between you and toge88. If you have questions about any aspect of this policy, you are welcome to contact us using the details in Section 17.

2. Definitions

The following definitions apply throughout this Privacy Policy:

• "Personal Data" — Any information that identifies or could reasonably identify a living individual, including name, email address, phone number, device identifiers, and financial account details.
• "Processing" — Any operation performed on personal data, including collection, storage, use, disclosure, transmission, and deletion.
• "Member" — Any registered toge88 account holder who has completed the registration process.
• "Visitor" — Any individual who accesses the toge88 website without completing registration.
• "Third-Party Processor" — An external company engaged by toge88 to process personal data on our behalf, under strict data processing agreements.
• "KYC" — Know Your Customer: the identity verification process applied to members before withdrawals are authorised.
• "Cookie" — A small text file placed on your device by the toge88 website to support functionality, session management, and analytics.

3. Data We Collect

toge88 collects personal data across several categories. The table below summarises the types of data we process, with examples:

We do not intentionally collect special-category data (such as health information, religious beliefs, or political opinions) and request that members refrain from including such information in any communications with our support team.

4. How We Collect Data

4.1 Directly From You

The majority of the personal data we hold is provided directly by you during the following interactions:

• Completing the toge88 registration form (name, date of birth, email, phone number, residential address);
• Submitting KYC documents in connection with your first withdrawal request;
• Making a deposit or requesting a withdrawal (bank account details, e-wallet identifiers);
• Contacting our customer support team via email or live chat;
• Responding to surveys, promotions, or feedback requests.

4.2 Automatically Through Platform Use

When you visit or interact with the toge88 platform, certain technical and behavioural data is collected automatically through server logs, cookies, and similar tracking technologies. This includes your IP address, the pages you visit, the games you launch, your session duration, and the device and browser you use. This data is collected to ensure platform security, detect fraud, and improve the member experience.

4.3 From Third-Party Service Providers

In limited circumstances, toge88 may receive personal data about you from third-party sources, including:

• Payment processors and Indonesian banking partners (BCA, BRI, BNI, Mandiri) for transaction verification purposes;
• Identity verification agencies engaged to assist with KYC compliance;
• Fraud prevention and anti-money-laundering (AML) screening services.

Data received from third parties is handled under the same standards as data collected directly and is not used for any purpose beyond those disclosed in this policy.

5. Purpose of Processing

toge88 processes your personal data for the following clearly defined purposes:

• Account Creation and Management: To establish, maintain, and administer your toge88 member account, including username/password authentication and profile management.
• Identity Verification (KYC): To verify your age (21+), identity, and residential status in Indonesia before authorising withdrawals, in compliance with our anti-fraud obligations.
• Payment Processing: To facilitate deposits and withdrawals through Indonesian banking channels (BCA, BRI, BNI, Mandiri) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Service Delivery: To provide access to all toge88 betting products, including sports markets, live casino, lottery draws, and slot games supplied by our licensed studio partners.
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance through our 24/7 Indonesian-speaking support team.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, multi-accounting, and other prohibited conduct.
• Legal Compliance: To meet our obligations under applicable international gaming regulations, anti-money-laundering requirements, and data protection standards.
• Platform Improvement: To analyse aggregate usage patterns, diagnose technical issues, conduct A/B testing, and enhance the overall quality and reliability of the toge88 platform.
• Marketing Communications: To send promotional offers, bonus notifications, and seasonal campaigns to members who have opted in to receive such communications (see Section 13).
• Responsible Gaming: To monitor betting patterns for signs of problem gambling and to apply any self-exclusion or deposit-limit restrictions activated by the member or imposed by our Responsible Gaming team.

6. Legal Basis for Processing

toge88 processes personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you accepted at registration — including account management, payment processing, and service delivery.
• Legal Obligation: Processing necessary to comply with applicable anti-money-laundering, fraud prevention, and identity verification requirements to which toge88 is subject as an internationally licensed operator.
• Legitimate Interests: Processing for fraud detection, platform security, abuse prevention, and analytics, where our interests in operating a safe and commercially viable platform do not override your fundamental privacy rights.
• Consent: Processing for optional purposes — primarily direct marketing communications — where we have obtained your explicit opt-in consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7. Data Sharing

7.1 Categories of Recipients

toge88 does not sell your personal data. We may share it with the following categories of recipients, solely to the extent necessary for the stated purpose:

• Payment Partners: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) — to process deposits and withdrawals in your name;
• KYC and Fraud Prevention Providers: Third-party identity verification and AML screening services engaged under strict data processing agreements;
• Game Content Providers: Licensed studio partners such as Pragmatic Play, Evolution Gaming, and Microgaming — limited to the data required to authenticate your session and record game outcomes;
• Cloud Infrastructure and Hosting Providers: Secure server and database providers engaged to host the toge88 platform, who process data solely on our instructions;
• Customer Support Tools: Third-party helpdesk and live-chat platforms used to manage member support tickets, operating under confidentiality obligations;
• Legal and Regulatory Authorities: Law enforcement agencies or regulatory bodies where disclosure is required by applicable law or court order.

7.2 No Unauthorised Third-Party Sharing

Beyond the categories listed above, toge88 will not disclose your personal data to any third party without your explicit prior consent, except where required by a binding legal obligation. All third-party processors engaged by toge88 are bound by written data processing agreements that prohibit them from using your data for their own purposes.

8. International Data Transfers

As an international platform, some of the third-party processors engaged by toge88 may be located outside Indonesia. Where personal data is transferred to processors in other countries, toge88 ensures that appropriate safeguards are in place, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those observed by toge88;
• Transfers only to processors operating in jurisdictions with recognised data protection frameworks;
• Regular review of third-party security certifications and compliance posture.

Where you have consented to this Privacy Policy, you also acknowledge and agree to the transfer of your personal data to third-party processors in other jurisdictions as described above, subject always to the safeguards set out in this section.

9. Data Retention

toge88 retains personal data only for as long as it is necessary for the purposes described in this policy, or as required by applicable legal and regulatory obligations. The following retention periods apply as general guidelines:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to an identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

10. Security Measures

toge88 implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Key measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted in transit using TLS 1.2 or higher;
• Encryption at Rest: Sensitive personal data — including KYC documents and financial account details — is encrypted in our databases using AES-256;
• Access Controls: Access to personal data is restricted to authorised toge88 personnel on a strict need-to-know basis, enforced through role-based access controls;
• Multi-Factor Authentication: Administrative access to systems holding personal data requires multi-factor authentication;
• Intrusion Detection: Automated monitoring systems scan for anomalous activity, brute-force attempts, and suspicious login patterns in real time;
• Regular Security Audits: toge88 conducts periodic internal security reviews and engages external specialists for penetration testing of critical infrastructure;
• Staff Training: All personnel with access to personal data receive regular training on data protection obligations and security best practices.

11. Your Privacy Rights

As a toge88 member and data subject, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at the email address in Section 17. We will respond within 14 business days.

12. Cookies & Tracking Technologies

12.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the site to remember information about your visit — such as your preferred language, session status, and recently viewed pages — to improve your experience on subsequent visits.

12.2 Cookies Used by toge88

The toge88 platform uses the following categories of cookies:

• Essential Cookies: Required for core platform functionality, including session authentication, security token management, and load balancing. These cannot be disabled without impairing your ability to use the platform.
• Functional Cookies: Remember your account preferences (such as language setting and notification preferences) to personalise your experience.
• Analytics Cookies: Collect aggregate, anonymised data on how members use the platform — such as which game categories are most popular and where users encounter errors — to inform platform improvements.
• Security Cookies: Support our fraud detection and session integrity systems by tracking suspicious patterns such as rapid location changes or simultaneous logins from different devices.

12.3 Managing Cookies

You may configure your browser to block or delete cookies at any time. However, disabling essential cookies will prevent you from logging in and using the toge88 platform. Analytics and functional cookies may be disabled without affecting core platform access. Browser-level cookie controls vary by browser — consult your browser's help documentation for specific instructions.

13. Marketing Communications

toge88 may send you promotional emails, SMS notifications, and in-platform messages about bonuses, seasonal offers, new game launches, and VIP programme updates. We will only send these communications where you have opted in to receive them during registration or at any subsequent point through your account settings.

13.1 Opt-Out

You may unsubscribe from marketing communications at any time by:

• Clicking the "Unsubscribe" link in any marketing email;
• Updating your notification preferences in your toge88 account settings;
• Contacting our support team at the email address in Section 17.

Opting out of marketing communications will not affect transactional communications — such as deposit confirmations, withdrawal notifications, KYC status updates, and security alerts — which are necessary for the operation of your account.

13.2 Personalised Offers

toge88 may use your betting history and platform usage data to tailor promotional offers to your interests. This personalisation is carried out on the basis of legitimate interests and is subject to your right to object as described in Section 11. Personalised marketing never involves sharing your individual data with external advertisers.

14. Minors & Age Restriction

The toge88 platform is strictly for adults aged 21 and over. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that a member is under the minimum age, we will immediately suspend their account, freeze any associated funds, and delete the personal data collected in connection with that account as soon as our legal obligations permit.

If you are a parent or guardian and believe that a minor in your care has registered a toge88 account, please contact us immediately at the address in Section 17 so that we can take prompt action. We also recommend the use of parental control software and internet filtering tools to prevent minors from accessing online gambling platforms.

15. Third-Party Services & Linked Content

The toge88 platform integrates with third-party game content providers — including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft — to deliver our full range of casino and betting products. When you launch a game supplied by a third-party studio, limited technical data (such as your session token and game history for that session) may be processed by that provider's servers.

toge88 selects game providers who maintain high standards of data security and who are bound by contractual obligations regarding the handling of member data. However, toge88 cannot accept responsibility for the independent privacy practices of third-party studios beyond the terms of our data processing agreements with them.

This Privacy Policy does not extend to any third-party websites or services. toge88 does not host external links to third-party websites, but if you independently navigate to other platforms, those sites' own privacy policies will apply.

16. Policy Updates

toge88 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable regulations, or platform functionality. When material changes are made, we will notify active members via email and/or a prominent in-platform notification at least 7 calendar days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was published. We encourage you to review this policy periodically. Your continued use of the toge88 platform after the effective date of any revision constitutes acceptance of the updated policy.

Where a proposed change materially reduces your privacy rights and we are required to obtain fresh consent, we will do so before applying the change to your account.

17. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or would like to raise a privacy-related concern or complaint, please contact our Data Protection team using the details below. All privacy inquiries are handled by our dedicated support team, which includes Indonesian-speaking agents available around the clock.

17.1 Complaints Process

If you are not satisfied with our response to a privacy concern, you may escalate your complaint to our senior Data Protection Officer by including "Escalation — Privacy Complaint" in the subject line of your follow-up email. We are committed to resolving all complaints fairly and promptly.

For broader concerns about your rights as a data subject, you may also consult applicable data protection guidance or seek independent legal advice regarding your rights under internationally recognised privacy standards.