Privacy Policy

This Privacy Policy ("Policy") describes how m3toto ("we", "us", "our", "Company") collects, uses, stores, and protects the personal information of users ("you", "your") who access or use our online betting platform ("Platform", "Service", "Site"). By using the m3toto Platform, you consent to the data practices described in this Policy. If you do not agree with this Policy, you must immediately cease using the Platform.

1. Information We Collect

1.1 Personal Information You Provide

When you register an account with m3toto, we collect personal information that you voluntarily provide, including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification number (KTP number for Indonesian residents)
• Contact Information: Email address, phone number, residential address, city, and postal code
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet details (OVO, DANA, GoPay, ShopeePay, LinkAja account information), and payment transaction history
• Account Credentials: Username, password (stored in encrypted form), and security questions/answers
• Verification Documents: Copies of identity documents (KTP, passport, driver's license), proof of address documents (utility bills, bank statements), and selfie photographs for identity verification purposes

1.2 Information Collected Automatically

When you access the m3toto Platform, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information
• Connection Information: IP address, internet service provider (ISP), connection type, and geographic location (city and country level based on IP address)
• Usage Data: Pages visited, features used, time spent on pages, click patterns, search queries, bet history, game preferences, login timestamps, and session duration
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, and similar tracking technologies (see Section 7 for detailed cookie information)

1.3 Information from Third Parties

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

• Payment Processors: Transaction verification data from Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI) and e-wallet providers
• Identity Verification Services: Age verification, address verification, and fraud prevention data from specialized KYC service providers
• Game Providers: Game play data, RTP statistics, and win/loss records from third-party game studios such as Pragmatic Play, Evolution Gaming, and others

2. How We Use Your Information

m3toto uses your personal information for the following legitimate business purposes:

2.1 Account Management and Service Provision

• Creating and maintaining your user account
• Verifying your identity, age (21+ requirement), and eligibility to use the Platform
• Processing deposits, withdrawals, and other financial transactions
• Providing customer support and responding to your inquiries
• Enabling you to place bets and play games on the Platform

2.2 Security and Fraud Prevention

• Detecting, preventing, and investigating fraudulent activity, money laundering, and other illegal activities
• Monitoring Account activity for suspicious patterns or unauthorized access
• Enforcing our Terms & Conditions and preventing abuse of the Platform
• Complying with legal obligations including anti-money laundering (AML) and counter-terrorist financing (CTF) regulations

2.3 Marketing and Communications

• Sending you promotional offers, bonuses, and updates about new features (only if you have opted in to marketing communications)
• Notifying you about changes to our Terms & Conditions, Privacy Policy, or other important service updates
• Conducting surveys and gathering feedback to improve our services
• Personalizing your experience based on your betting preferences and game history

2.4 Platform Improvement and Analytics

• Analyzing user behavior and usage patterns to improve Platform functionality and user experience
• Testing new features and optimizing existing features
• Generating aggregated, anonymized statistics for internal business intelligence
• Troubleshooting technical issues and improving Platform performance

2.5 Responsible Gaming

• Implementing responsible gaming tools such as deposit limits, session limits, and self-exclusion
• Identifying players who may be experiencing gambling-related problems
• Providing access to responsible gaming resources and support services

3. Legal Basis for Processing (GDPR Compliance)

For users in jurisdictions covered by the General Data Protection Regulation (GDPR) or similar privacy laws, we process your personal data based on the following legal grounds:

• Contractual Necessity: Processing necessary to fulfill our contract with you (providing gambling services as per our Terms & Conditions)
• Legal Obligation: Processing required to comply with legal requirements such as KYC verification, AML regulations, and tax reporting
• Legitimate Interests: Processing necessary for our legitimate business interests in fraud prevention, security, and platform improvement, provided these interests do not override your fundamental rights
• Consent: Processing based on your explicit consent, such as marketing communications (which you may withdraw at any time)

4. How We Share Your Information

m3toto does not sell your personal information to third parties. We only share your data in the following limited circumstances:

4.1 Service Providers

We share your information with trusted third-party service providers who assist us in operating the Platform, including:

• Payment Processors: Indonesian banks and e-wallet providers to process deposits and withdrawals
• KYC Verification Services: Identity verification providers to confirm your age, identity, and address
• Game Providers: Third-party game studios (Pragmatic Play, Evolution Gaming, Microgaming, etc.) to deliver casino games and sports betting products
• Customer Support Tools: Live chat and helpdesk software providers to deliver customer support services
• Cloud Hosting: Secure cloud infrastructure providers to store data

All service providers are contractually obligated to protect your data and use it only for the purposes we specify.

4.2 Legal Requirements

We may disclose your information if required by law, court order, or regulatory authority, or if we believe disclosure is necessary to:

• Comply with legal obligations or respond to lawful requests from government authorities
• Enforce our Terms & Conditions or investigate potential violations
• Protect the rights, property, or safety of m3toto, our users, or the public
• Detect, prevent, or address fraud, security, or technical issues

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email or prominent notice on the Platform before your data is transferred and becomes subject to a different privacy policy.

4.4 With Your Consent

We may share your information with third parties for purposes not described in this Policy, but only with your explicit consent.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.

Data Type	Retention Period	Reason
Account Information	Duration of account + 5 years after closure	Legal compliance, dispute resolution
Transaction Records	7 years	Tax reporting, AML compliance
KYC Documents	5 years after account closure	Regulatory requirements
Betting History	Duration of account + 3 years	Dispute resolution, audits
Marketing Preferences	Until you opt out	Consent-based processing
Support Chat Logs	2 years	Quality assurance, dispute resolution

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

6. Data Security

m3toto employs industry-standard technical and organizational security 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 encryption. Sensitive data stored in our databases is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorized personnel on a need-to-know basis. All employees sign confidentiality agreements.
• Secure Infrastructure: Our Platform is hosted on secure cloud infrastructure with redundant backups, firewalls, intrusion detection systems, and regular security audits.
• Password Security: User passwords are hashed using industry-standard cryptographic algorithms and are never stored in plain text.
• Regular Audits: We conduct regular security assessments and penetration testing to identify and address vulnerabilities.
• Incident Response: We maintain an incident response plan to quickly address any data breaches or security incidents.

While we implement robust security measures, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

7. Cookies and Tracking Technologies

m3toto uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform and analyze usage patterns.

7.1 Types of Cookies We Use

• Essential Cookies: Required for basic Platform functionality such as account login, session management, and secure transactions. These cannot be disabled.
• Performance Cookies: Collect anonymous information about how users interact with the Platform to help us improve performance and user experience.
• Functional Cookies: Remember your preferences (language, region, display settings) to provide a personalized experience.
• Advertising Cookies: Used to deliver relevant promotional content based on your interests and betting preferences (only if you have consented to marketing).

7.2 Managing Cookies

You can control cookie preferences through your browser settings. Note that disabling certain cookies may impact Platform functionality. Most browsers allow you to:

• View and delete cookies stored on your device
• Block third-party cookies
• Block all cookies (not recommended as this may prevent you from using the Platform)
• Receive notifications before cookies are stored

8. Your Privacy Rights

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

• Right to Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data (subject to legal retention requirements)
• Right to Restrict Processing: Request temporary restriction on how we process your data
• Right to Data Portability: Request your data in a structured, machine-readable format for transfer to another service
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Withdraw your consent for processing activities that require consent (e.g., marketing emails)
• Right to Lodge a Complaint: File a complaint with a data protection authority if you believe your rights have been violated

To exercise any of these rights, contact our Data Protection Officer at [email protected] or use the contact information in Section 11. We will respond to your request within 30 days.

9. International Data Transfers

m3toto operates internationally and may transfer your personal data to countries outside Indonesia for processing and storage. These countries may have different data protection laws than Indonesia. When we transfer data internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by relevant data protection authorities
• Transfer to countries deemed to provide adequate data protection
• Binding corporate rules and privacy frameworks

10. Children's Privacy

The m3toto Platform is strictly intended for adults aged 21 years or older. We do not knowingly collect personal information from individuals under 21. If we become aware that we have inadvertently collected data from a minor, we will immediately delete such information and permanently close the associated account. If you believe a minor has provided us with personal information, please contact us immediately at [email protected].

11. Changes to This Privacy Policy

m3toto 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 to you via email or prominent notice on the Platform. The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the Platform after such notice constitutes acceptance of the updated Policy. We recommend reviewing this Policy periodically to stay informed about how we protect your data.

12. Contact Information

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

• General Inquiries: [email protected]
• Data Protection Officer: [email protected]
• Live Chat: Available 24/7 on the Platform
• Mailing Address: m3toto Privacy Department, Customer Support Team