Privacy Policy

1. Information We Collect

amtoto collects various types of information to provide and improve our services, ensure compliance with legal obligations, and protect the security of our platform and members.

1.1 Personal Information You Provide

When you register an account with amtoto, we collect the following personal information directly from you:

• Identity Information: Full legal name, date of birth, nationality, and government-issued identification number (KTP, Passport, or Driver's License number)
• Contact Information: Email address, Indonesian mobile phone number (+62 format), residential address, and postal code
• Account Credentials: Username, password, and security questions/answers
• Financial Information: Bank account details (account number, bank name, account holder name), e-wallet account information (OVO, DANA, GoPay account details), and transaction history
• Verification Documents: Copies of government-issued ID, proof of address documents (utility bills, bank statements), and proof of payment method ownership

1.2 Information Collected Automatically

When you access or use the amtoto platform, we automatically collect certain information about your device and usage patterns:

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers
• Usage Data: Pages visited, time spent on pages, clickstream data, referral URLs, search queries, and navigation paths through the platform
• Transaction Data: Deposit amounts, withdrawal requests, bet history, game activity, win/loss records, and bonus claims
• Location Data: Approximate geographic location derived from your IP address to ensure compliance with jurisdiction restrictions
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to track user behavior and preferences (see Section 8 for details)

1.3 Information from Third Parties

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

• Payment processors (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay) to verify and process transactions
• Identity verification services to confirm your age, identity, and address
• Fraud prevention and risk assessment providers to detect and prevent fraudulent activity
• Marketing partners and affiliates who referred you to amtoto (with your consent)

2. How We Use Your Information

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

2.1 Account Management and Service Delivery

• Create, maintain, and authenticate your amtoto account
• Process deposits, withdrawals, and other financial transactions
• Enable you to place bets on sports events, casino games, and lottery draws
• Manage your VIP tier status and loyalty rewards
• Provide customer support and respond to your inquiries

2.2 Compliance and Security

• Verify your age (21+ requirement) and identity through KYC (Know Your Customer) procedures
• Comply with anti-money laundering (AML) regulations and responsible gaming laws
• Detect, prevent, and investigate fraud, abuse, security incidents, and other prohibited activities
• Enforce our Terms & Conditions and other legal agreements
• Respond to legal requests from law enforcement or regulatory authorities

2.3 Platform Improvement and Personalization

• Analyze usage patterns to improve platform performance, functionality, and user experience
• Personalize content, game recommendations, and promotional offers based on your preferences and activity
• Conduct market research and develop new products and services
• Test new features and optimize platform design

2.4 Marketing and Communications

• Send you promotional emails, SMS messages, and push notifications about bonuses, tournaments, and special offers (with your consent)
• Inform you of platform updates, new features, and policy changes
• Conduct customer satisfaction surveys and request feedback

3. Legal Basis for Processing (GDPR Compliance)

For members located in jurisdictions with data protection laws similar to the European Union's General Data Protection Regulation (GDPR), we process your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (Terms & Conditions) and deliver the betting services you requested
• Legal Obligation: Processing is required to comply with KYC, AML, age verification, and other legal requirements
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests do not override your fundamental rights
• Consent: You have explicitly consented to processing for specific purposes, such as marketing communications or optional data collection

4. How We Share Your Information

amtoto does not sell your personal information to third parties. However, we may share your information in the following circumstances:

4.1 Service Providers

We share information with trusted third-party service providers who perform functions on our behalf, including:

• Payment processors (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay) for deposit and withdrawal transactions
• Identity verification and KYC service providers
• Cloud hosting and data storage providers
• Customer support software platforms
• Email and SMS communication services
• Security and fraud prevention providers

These service providers are contractually obligated to protect your information and use it only for the specific purposes we authorize.

4.2 Legal and Regulatory Authorities

We may disclose your information to government agencies, law enforcement, or regulatory bodies when required by law or when we believe disclosure is necessary to:

• Comply with a legal obligation, court order, or subpoena
• Enforce our Terms & Conditions or other agreements
• Protect the rights, property, or safety of amtoto, our members, or the public
• Detect, prevent, or address fraud, security, or technical issues

4.3 Business Transfers

If amtoto is involved in a merger, acquisition, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. We will notify you of any such change via email or prominent notice on our platform.

4.4 With Your Consent

We may share your information with third parties when you have given explicit consent, such as sharing your username in leaderboards or tournaments (if you opt in).

5. Data Retention

amtoto retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Specific retention periods include:

• Active Accounts: We retain your account information and transaction history for the duration of your membership plus 5 years after account closure, as required by Indonesian AML and financial regulations
• KYC Documents: Identity verification documents are retained for 5 years after account closure to comply with regulatory requirements
• Transaction Records: Deposit, withdrawal, and bet history are retained for 7 years for tax and audit purposes
• Marketing Data: If you unsubscribe from marketing communications, we retain your email address on our suppression list to honor your opt-out request
• Security Logs: Access logs and security incident records are retained for 2 years

After the retention period expires, we securely delete or anonymize your personal information in accordance with data protection best practices.

6. Data Security

amtoto implements industry-standard technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS (Secure Sockets Layer/Transport Layer Security) technology
• Secure Storage: Personal information is stored on secure servers with restricted access, firewalls, and intrusion detection systems
• Access Controls: Only authorized amtoto personnel with a legitimate business need can access your personal information, and all access is logged and audited
• Two-Factor Authentication: We offer optional two-factor authentication (2FA) to add an extra layer of security to your account
• Regular Security Audits: We conduct periodic security assessments and vulnerability testing to identify and address potential risks
• Employee Training: All amtoto staff undergo data protection and security awareness training

Despite these measures, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

7. Your Rights and Choices

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

7.1 Access and Portability

You have the right to request a copy of the personal information we hold about you. You can download your account data and transaction history directly from your account dashboard, or contact our support team for assistance.

7.2 Correction and Update

You can update your contact information, address, and password at any time through your account settings. For changes to your legal name or date of birth, contact our support team with supporting documentation.

7.3 Deletion (Right to be Forgotten)

You may request deletion of your personal information by closing your account. Note that we may retain certain information as required by law (see Section 5). To close your account, contact our support team or use the self-closure option in your account settings.

7.4 Objection and Restriction

You can object to processing of your personal information for direct marketing purposes at any time by unsubscribing from emails or contacting support to opt out of SMS messages.

7.5 Withdraw Consent

If we process your information based on consent (e.g., optional marketing), you can withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

7.6 Lodge a Complaint

If you believe we have not handled your personal information appropriately, you have the right to lodge a complaint with the relevant data protection authority in Indonesia or your jurisdiction.

To exercise any of these rights, contact us at [email protected] with "Privacy Rights Request" in the subject line. We will respond within 30 days.

8. Cookies and Tracking Technologies

amtoto uses cookies and similar tracking technologies to enhance your experience on our platform:

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us recognize your device on subsequent visits and remember your preferences.

8.2 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for platform functionality, authentication, and security	Session or up to 1 year
Performance Cookies	Collect anonymous data on platform usage to improve performance	Up to 2 years
Functional Cookies	Remember your preferences, language settings, and customizations	Up to 1 year
Marketing Cookies	Track your activity to deliver personalized ads and promotions	Up to 1 year

8.3 Managing Cookies

You can control cookie settings through your browser preferences. Note that disabling essential cookies may affect platform functionality. Most browsers allow you to:

• View and delete existing cookies
• Block third-party cookies
• Block all cookies (not recommended for amtoto)
• Clear all cookies when you close your browser

9. International Data Transfers

amtoto primarily serves Indonesian residents, and your personal information is stored on servers located in secure data centers within Indonesia and Southeast Asia. If we transfer data to service providers located outside Indonesia, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by data protection authorities
• Adequacy decisions recognizing equivalent data protection standards
• Binding corporate rules for intra-group transfers

10. Children's Privacy

amtoto does not knowingly collect personal information from individuals under 21 years of age (or the legal gambling age in your jurisdiction, whichever is higher). Our platform is intended exclusively for adults. If we discover that we have inadvertently collected information from a minor, we will delete it immediately. If you believe a minor has provided information to amtoto, contact us at [email protected].

11. Changes to This Privacy Policy

amtoto reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or platform features. Material changes will be communicated via:

• Email notification to your registered email address
• Prominent notice on the amtoto homepage
• In-app notification when you log in

The "Last Updated" date at the top of this policy indicates when the most recent revisions were made. We encourage you to review this policy periodically. Your continued use of amtoto after changes are posted constitutes acceptance of the revised policy.

12. Contact Us

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

• Email: [email protected] (Subject line: Privacy Inquiry)
• Live Chat: Available 24/7 on the amtoto platform
• WhatsApp: +62 812-3456-7890 (Monday to Sunday, 09:00 – 01:00 WIB)

For data protection officer inquiries or formal privacy rights requests, please use the email address above with "DPO Request" or "Privacy Rights Request" in the subject line. We will respond within 30 days in accordance with applicable data protection laws.