Privacy Policy

1. Introduction and Scope

This Privacy Policy describes how toboli ("we," "us," "our") collects, uses, discloses, and protects personal information from users ("you," "your") of our online betting platform located at https://toboli.cam. By creating an account or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

This policy applies to all users of toboli's services, regardless of how you access our platform (website, mobile browser, or any future applications). If you do not agree with the terms of this Privacy Policy, you must discontinue use of our services immediately.

toboli is committed to compliance with applicable data protection laws and regulations, including international standards for online service providers. We process personal data in accordance with these regulations and industry best practices to ensure your information remains secure and confidential.

2. Information We Collect

2.1 Information You Provide Directly

When you register an account with toboli, you provide us with personal information necessary to verify your identity, comply with legal requirements, and deliver our services. This information includes:

• Personal Identification: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (Indonesian KTP number, passport number, or driver's license number)
• Contact Information: Email address, mobile phone number, residential address, and postal code
• Account Credentials: Username, password (stored in encrypted form), and security questions/answers
• Financial Information: Bank account details (bank name, account holder name, account number), e-wallet information (OVO, DANA, GoPay, ShopeePay, LinkAja 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
• Communication Records: Records of your communications with our customer support team via live chat, email, WhatsApp, or Telegram

2.2 Information Collected Automatically

When you access or use toboli's platform, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifier, and mobile network information
• Log Data: IP address, access times, pages viewed, time spent on pages, links clicked, referring website addresses, and other diagnostic data
• Gaming Activity: Bets placed, games played, stakes wagered, winnings, losses, bonus usage, and gaming session duration
• Location Data: General geographic location derived from your IP address (country and city level, not precise GPS coordinates)
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies (see Section 9 for detailed information)

2.3 Information from Third Parties

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

• Payment Providers: Transaction confirmation, payment method verification, and fraud prevention data from banks and e-wallet providers
• Identity Verification Services: Age verification, identity authentication, and document validation results from KYC service providers
• Game Providers: Gaming activity data from third-party software providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, etc.)
• Fraud Prevention Services: Risk assessment data and fraud detection alerts from specialized security vendors

3. How We Use Your Information

toboli uses your personal information for the following legitimate business purposes:

3.1 Account Management and Service Delivery

• Create, maintain, and secure your toboli account
• Process deposits and withdrawals to and from your account
• Enable you to place bets and play games on our platform
• Track your transaction history and account balance
• Provide customer support and respond to your inquiries
• Send transactional notifications (deposit confirmations, withdrawal updates, account security alerts)

3.2 Legal and Regulatory Compliance

• Verify your age (21+ requirement) and identity to comply with Indonesian legal standards
• Conduct Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
• Detect and prevent fraud, money laundering, underage gambling, and other illegal activities
• Comply with legal obligations, court orders, or requests from regulatory authorities
• Maintain records required by our gaming license and applicable regulations
• Enforce our Terms & Conditions and resolve disputes

3.3 Security and Fraud Prevention

• Monitor account activity for suspicious patterns or unauthorized access
• Detect and prevent fraud, collusion, match fixing, and bonus abuse
• Protect the integrity of our platform and other users
• Investigate and respond to security incidents
• Implement risk management and responsible gaming measures

3.4 Marketing and Communications (With Your Consent)

• Send promotional offers, bonus announcements, and special event notifications
• Provide personalized gaming recommendations based on your preferences
• Conduct surveys and request feedback to improve our services
• Communicate updates about new games, features, or platform improvements

Note: You can opt out of marketing communications at any time by adjusting your account preferences or contacting customer support. You cannot opt out of essential transactional communications related to your account.

3.5 Platform Improvement and Analytics

• Analyze user behavior and gaming patterns to improve our services
• Develop new features and optimize user experience
• Test and troubleshoot technical issues
• Generate aggregated statistics and reports (anonymized data only)
• Conduct research and development for product enhancement

4. How We Share Your Information

toboli does not sell, rent, or trade your personal information to third parties for their marketing purposes. We only share your data in the following limited circumstances:

4.1 Service Providers and Business Partners

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

• Payment Processors: Banks and e-wallet providers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals
• Game Providers: Software suppliers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, etc.) who provide gaming content
• Identity Verification Services: KYC/AML compliance providers who verify user identities and detect fraud
• Customer Support Tools: Live chat, email, and communication platform providers
• Hosting and Infrastructure: Cloud service providers who host our platform and data
• Analytics Services: Tools that help us understand user behavior and improve our platform

All third-party service providers are contractually obligated to protect your data and use it only for the specific purposes we authorize.

4.2 Legal and Regulatory Obligations

We may disclose your information to comply with legal requirements, including:

• Responding to court orders, subpoenas, or legal processes
• Complying with requests from law enforcement or regulatory authorities
• Reporting suspicious activities to anti-money laundering authorities
• Cooperating with gaming license audits and compliance reviews
• Enforcing our Terms & Conditions or protecting our legal rights

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. We will notify you via email and/or prominent notice on our platform of any such change in ownership and provide you with choices regarding your information.

4.4 With Your Consent

We may share your information with third parties for purposes not described in this policy if we obtain your explicit consent to do so.

5. Data Security Measures

toboli implements industry-leading security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Technical Security

• Encryption: All data transmission between your device and our servers uses 256-bit SSL/TLS encryption, the same standard used by banks and financial institutions
• Secure Storage: Personal data is stored on secure servers in certified data centers with physical security controls, redundant backups, and disaster recovery procedures
• Password Protection: User passwords are encrypted using advanced hashing algorithms (bcrypt or stronger) and are never stored in plain text
• Firewall Protection: Multiple layers of firewalls protect our infrastructure from unauthorized access
• Intrusion Detection: Real-time monitoring systems detect and alert us to suspicious activity

5.2 Organizational Security

• Access Controls: Only authorized personnel with legitimate business needs can access user data, and all access is logged and audited
• Employee Training: Staff members receive regular training on data protection and security best practices
• Confidentiality Agreements: All employees and contractors sign strict confidentiality agreements
• Security Audits: Regular third-party security audits and penetration testing to identify and address vulnerabilities
• Incident Response: Established procedures to respond to and mitigate security incidents

5.3 Your Role in Security

While we implement robust security measures, you also play a crucial role in protecting your account:

• Use a strong, unique password that you don't use on other websites
• Never share your login credentials with anyone
• Log out of your account when using shared or public devices
• Keep your contact information up to date so we can reach you about security matters
• Report any suspicious activity or unauthorized access immediately
• Be cautious of phishing attempts—toboli will never ask for your password via email

6. Data Retention

toboli retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Data Category	Retention Period	Reason
Account Information	Duration of account + 7 years	Legal compliance, tax records, dispute resolution
Transaction Records	Duration of account + 7 years	Financial audits, AML compliance, tax reporting
KYC/Verification Documents	Duration of account + 7 years	Regulatory requirements, identity verification
Gaming Activity Logs	Duration of account + 5 years	Dispute resolution, fraud prevention, licensing audits
Communication Records	Duration of account + 3 years	Customer service quality, dispute resolution
Marketing Preferences	Until you opt out or close account	Respecting your communication choices
Technical Logs	90 days to 2 years	Security monitoring, technical troubleshooting

After the applicable retention period expires, we securely delete or anonymize your personal information. Anonymized data (data that can no longer identify you) may be retained indefinitely for statistical analysis and business intelligence purposes.

7. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. At toboli, we respect these rights and provide mechanisms for you to exercise them:

7.1 Right to Access

You have the right to request a copy of the personal information we hold about you. To request access, contact our customer support team with your account details. We will provide the information in a commonly used electronic format within 30 days.

7.2 Right to Rectification

If you believe any information we hold about you is inaccurate or incomplete, you can update most information directly through your account settings or by contacting customer support.

7.3 Right to Erasure ("Right to Be Forgotten")

You may request deletion of your personal information by closing your account. However, we may retain certain information as required by law or for legitimate business purposes (e.g., preventing fraud, resolving disputes, enforcing agreements). See Section 6 for data retention periods.

7.4 Right to Restrict Processing

You may request that we limit how we use your personal information in certain circumstances, such as while we verify the accuracy of disputed data or when we no longer need the data but you require it for legal claims.

7.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, machine-readable format and to transmit it to another service provider where technically feasible.

7.6 Right to Object

You can object to our processing of your personal information for direct marketing purposes at any time by adjusting your account preferences or contacting customer support. You will stop receiving marketing communications, but essential transactional emails will continue.

7.7 Right to Withdraw Consent

Where we rely on your consent to process personal information, you may withdraw that consent at any time. However, this will not affect the lawfulness of processing based on consent before withdrawal.

7.8 Right to Lodge a Complaint

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

8. International Data Transfers

toboli operates internationally and may transfer your personal information to servers located outside of Indonesia. When we transfer data across borders, we ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable laws. These safeguards may include:

• Standard contractual clauses approved by data protection authorities
• Ensuring the recipient country provides adequate data protection
• Obtaining your explicit consent for the transfer
• Implementing technical and organizational security measures

If you have questions about international data transfers, please contact our customer support team.

9. Cookies and Tracking Technologies

toboli uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content.

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us recognize your device, remember your preferences, and provide a better user experience.

9.2 Types of Cookies We Use

• Essential Cookies: Necessary for the platform to function (e.g., keeping you logged in, processing transactions). These cannot be disabled without affecting functionality.
• Performance Cookies: Collect information about how you use our platform (e.g., pages visited, time spent) to help us improve performance.
• Functional Cookies: Remember your preferences (e.g., language, region) to provide a personalized experience.
• Marketing Cookies: Track your activity across websites to deliver relevant advertisements and measure campaign effectiveness.

9.3 Managing Cookies

Most web browsers allow you to control cookies through settings. You can choose to block or delete cookies, but this may affect your ability to use certain features of our platform. Refer to your browser's help documentation for instructions on managing cookies.

10. Third-Party Links and Services

Our platform may contain links to third-party websites, services, or applications (e.g., social media platforms, payment providers). toboli is not responsible for the privacy practices of these external sites. We encourage you to read the privacy policies of any third-party services you access through our platform.

11. Children's Privacy

toboli's services are strictly intended for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21. If you believe we have inadvertently collected information from a minor, please contact us immediately at [email protected], and we will take prompt action to delete such information and close any associated accounts.

12. Changes to This Privacy Policy

toboli reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending an email notification to your registered email address
• Displaying a prominent notice on our platform

Your continued use of toboli's services after the effective date of the revised policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Team:

• Email: [email protected] (Subject: Privacy Inquiry)
• Live Chat: Available 24/7 on our website
• WhatsApp: Available 24/7 (Indonesian and English support)
• Telegram: Available 24/7

We aim to respond to all privacy-related inquiries within 48 hours during business days (Monday-Friday, WIB). For urgent security matters, please indicate "URGENT" in your message subject line.

14. Your Consent

By creating a toboli account and using our services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. You consent to the collection, use, disclosure, and storage of your personal information as described herein.