Privacy Policy

At totoxl, your privacy is a fundamental right, not an afterthought. This Privacy Policy explains exactly what personal data we collect, why we collect it, how it is used and protected, and what rights you hold as a Member of our platform. We are committed to handling your information with transparency, care, and full accountability.

Last updated: January 2026  |  Version 2.4

Six Principles Guiding How We Handle Your Data

totoxl's data practices are built on six foundational commitments that govern every decision we make about your personal information.

Transparency

We tell you clearly what data we collect, why we collect it, and how it is used — before we collect it. No hidden clauses, no surprise data uses.

Purpose Limitation

Your data is collected for specific, explicit purposes. We do not repurpose data beyond those stated objectives without obtaining fresh consent from you.

Data Minimisation

We collect only the data we genuinely need to deliver and improve the totoxl service. We do not harvest unnecessary information or retain data longer than required.

Security by Design

All personal data is protected by 256-bit SSL encryption in transit and AES-256 encryption at rest. Access is restricted on a strict need-to-know basis across our team.

Your Rights First

You have the right to access, correct, export, and delete your personal data at any time. Our support team processes all data rights requests within 30 days.

No Data Selling

totoxl does not sell, rent, or trade your personal information to any third party for their marketing or commercial purposes — period.

This Privacy Policy applies to all Members and visitors of the totoxl Platform. By registering an account or continuing to use our services, you confirm that you have read and understood the practices described herein. This Policy should be read alongside our Terms & Conditions.
1

Scope & Application

This Privacy Policy applies to all personal data collected and processed by totoxl in connection with the operation of the totoxl Platform at totoxl.cam, including all associated mobile interfaces, customer support channels, email communications, and promotional activities.

This Policy covers data relating to:

  • Registered Members who hold an active or closed Account on the Platform.
  • Prospective Members who have begun but not completed the registration process.
  • Visitors who access the Platform without registering an Account.
  • Individuals who contact totoxl via live chat, email, or WhatsApp for any reason.

This Policy is specifically relevant to Indonesian players and is written to reflect the data practices applicable to Members primarily located in Indonesia, including those using Indonesian banking channels (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja).

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Definitions

In this Privacy Policy, the following terms carry the meanings defined below:

Term Meaning
"Personal Data" Any information relating to an identified or identifiable natural person, including name, email address, device identifiers, and financial transaction records.
"Processing" Any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
"Controller" totoxl, as the entity that determines the purposes and means of processing Personal Data.
"Processor" A third-party service provider that processes Personal Data on behalf of totoxl under a binding data processing agreement.
"Consent" A freely given, specific, informed, and unambiguous indication of the data subject's agreement to the processing of their Personal Data.
"Member" / "You" Any individual who registers or attempts to register an Account on the totoxl Platform.
3

Data We Collect

totoxl collects Personal Data through several distinct channels. The categories and specific data points collected in each context are set out below.

3.1 Registration Data. When you create an Account, we collect your full legal name, date of birth, residential address (including city — Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, or other Indonesian cities as applicable), email address, and mobile phone number. This data is required to create and maintain your Account and verify your eligibility.

3.2 KYC & Identity Verification Data. When you submit KYC documentation, we collect copies of government-issued identity documents (such as your Indonesian National Identity Card / KTP, passport, or SIM), proof-of-address documents, and selfie photographs taken for verification purposes. This data is processed to comply with our anti-money-laundering (AML) and know-your-customer (KYC) obligations.

3.3 Financial & Transaction Data. We collect details of all deposits and withdrawals made through your Account, including transaction amounts (in IDR), timestamps, payment method identifiers (e.g., the last four digits of a BCA or BRI account number, or the registered mobile number of an OVO or GoPay account), and transaction status records.

3.4 Betting & Gaming Activity Data. We maintain records of all bets, wagers, game sessions, and outcomes associated with your Account. This includes sportsbook activity (football markets, mix parlay accumulators, and other events), live casino sessions, togel (Indonesia's traditional numbers lottery) draw entries, slot game sessions, and any other gaming activity on the Platform.

3.5 Technical & Device Data. We automatically collect certain technical data when you access the Platform, including your IP address, browser type and version, operating system, device type, screen resolution, referring URL, and session duration. This data is used for security monitoring, fraud detection, and Platform performance optimisation.

3.6 Communications Data. When you contact our support team via live chat, email, or WhatsApp, we retain records of those communications — including the content of messages, timestamps, and agent responses — for quality assurance, training, and dispute resolution purposes.

3.7 Voluntarily Provided Data. Any additional information you choose to provide — for example, when completing a responsible gaming self-assessment or submitting a formal complaint — is also collected and stored in connection with your Account record.

5

How We Use Your Data

totoxl uses the Personal Data it collects for the following purposes:

  • Account Management: Creating, maintaining, and securing your Account; verifying your identity; and communicating with you about account-related matters.
  • Payment Processing: Facilitating deposits and withdrawals via your chosen payment method; detecting and preventing fraudulent transactions; complying with financial crime regulations.
  • Service Delivery: Enabling access to all betting and gaming products on the Platform, including sports betting, live casino, togel, slot games, and any other content we make available.
  • Responsible Gaming: Monitoring betting patterns to identify signs of problem gambling; implementing deposit limits, loss limits, and self-exclusion requests; and providing proactive support where required.
  • Security & Fraud Prevention: D etecting and investigating suspicious activity; preventing unauthorised access to your Account; and protecting the integrity of the Platform and its Members.
  • Legal Compliance: Meeting our obligations under applicable AML, KYC, and licensing regulations; responding to lawful requests from regulatory authorities; and maintaining records as required by law.
  • Customer Support: Responding to your enquiries, resolving disputes, and improving the quality of our support services through agent training and quality monitoring.
  • Platform Improvement: Analysing aggregated usage data to understand how Members interact with the Platform, identify areas for improvement, and develop new features and services.
  • Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates — only where you have opted in to receive such communications and subject to your right to unsubscribe at any time.
totoxl does not use your Personal Data for automated decision-making that produces legal or similarly significant effects on you, except where required by our AML/KYC compliance obligations, in which case you have the right to request human review of any automated determination.
6

Data Sharing & Third Parties

totoxl does not sell, rent, or trade your Personal Data to any third party for commercial or marketing purposes. We share your data only in the following strictly defined circumstances:

6.1 Service Providers (Processors). We engage trusted third-party service providers to assist in delivering the totoxl Platform. These include payment gateway operators (connecting to BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, and LinkAja), identity verification and KYC service providers, cloud infrastructure and data hosting providers, customer support software providers, and fraud detection and cybersecurity specialists. All such providers are bound by data processing agreements that prohibit them from using your data for any purpose beyond the specific service they deliver to totoxl.

6.2 Game Content Providers. Our platform integrates games from certified third-party studios including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Pocket Games Soft, and Spribe. These studios may receive session-level data (such as a pseudonymous player token and stake amounts) to enable gameplay. They do not receive your full identity or contact information.

6.3 Regulatory & Legal Disclosure. We may disclose your Personal Data to our licensing authority, law enforcement agencies, financial intelligence units, or other competent authorities where required to do so by law, court order, or our regulatory obligations. We will notify you of any such disclosure where legally permitted to do so.

6.4 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or part of totoxl's business, your Personal Data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

6.5 Aggregated Data. We may share aggregated, anonymised statistical data with partners, researchers, or the public for general analytical or reporting purposes. This data cannot be used to identify any individual Member.

7

Cookies & Tracking Technologies

totoxl uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are as follows:

Cookie Type Purpose Can Be Disabled?
Essential Cookies Required for core Platform functionality including login sessions, security tokens, and load balancing. Without these, the Platform cannot function. No — always active
Functional Cookies Remember your preferences such as language settings, display options, and game lobby filters to personalise your experience. Yes — via browser settings
Analytics Cookies Collect anonymised data on how Members navigate the Platform to help us understand usage patterns and improve the service. Yes — opt out available
Security Cookies Support our fraud detection systems by flagging unusual login patterns or session anomalies for review. No — required for security

You can manage or delete cookies at any time through your browser settings. Note that disabling functional or analytics cookies will not affect your ability to use the core Platform services, but may reduce the personalisation of your experience. For detailed browser-specific instructions on managing cookies, please refer to your browser's help documentation.

8

Data Retention

totoxl retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, to comply with applicable legal obligations, and to resolve any outstanding disputes. The following retention periods apply as a general guide:

  • Account & Registration Data: Retained for the duration of your Account's active status, plus a minimum of 5 years following Account closure to comply with AML record-keeping requirements.
  • KYC Documentation: Retained for a minimum of 5 years from the date of verification, in accordance with our licensing obligations. Copies of identity documents are stored in encrypted form and access-controlled.
  • Financial & Transaction Records: Retained for a minimum of 5 years from the date of each transaction to support regulatory audits and dispute resolution processes.
  • Betting & Gaming Activity: Retained for the duration of your Account plus 2 years, or longer where required for the investigation of a specific dispute or compliance matter.
  • Support Communications: Retained for 2 years from the date of the final message in each support thread, unless the communication relates to a formal dispute or complaint, in which case retention follows the outcome of that process.
  • Technical & Device Data: Retained for up to 12 months for security and fraud analysis purposes, after which it is aggregated or deleted.
  • Marketing Preferences: Retained until you withdraw your consent or unsubscribe. A record of your consent (and any subsequent withdrawal) is kept for compliance purposes.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised in accordance with our data destruction procedures.

9

Security Measures

totoxl implements a multi-layered security architecture to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Our technical and organisational measures include:

  • Encryption in Transit: All data transmitted between your device and the totoxl Platform is protected by TLS 1.3 / 256-bit SSL encryption.
  • Encryption at Rest: Stored Personal Data — including KYC documents and financial records — is encrypted using AES-256 encryption on secured servers.
  • Access Controls: Access to Personal Data is restricted to authorised personnel on a strict need-to-know basis. All staff with access to Member data undergo background verification and receive regular data protection training.
  • Multi-Factor Authentication: Internal systems handling Member data require multi-factor authentication for all staff access sessions.
  • Penetration Testing: The Platform undergoes regular third-party security audits and penetration testing to identify and remediate vulnerabilities before they can be exploited.
  • Incident Response: totoxl maintains a documented data breach response procedure. In the event of a breach affecting your Personal Data, we will notify you and the relevant regulatory authority within the timeframes required by applicable law.
Your responsibility: While totoxl takes every reasonable precaution to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your Account password confidential and for notifying us immediately if you suspect any unauthorised access to your Account.
10

Your Privacy Rights

As a Member of the totoxl Platform, you hold the following rights in respect of your Personal Data. To exercise any of these rights, please contact our support team using the details in Clause 14. We will respond to all valid requests within 30 calendar days.

Right of Access Request a copy of all Personal Data we hold about you, including the purposes for which it is processed.
Right to Rectification Request correction of any inaccurate or incomplete Personal Data held in your Account record.
Right to Erasure Request deletion of your Personal Data where it is no longer needed for the purpose it was collected, subject to legal retention obligations.
Right to Restriction Request that we restrict the processing of your data while a query or complaint is being resolved.
Right to Portability Request a machine-readable export of Personal Data you provided to us, for transfer to another service provider.
Right to Object Object to processing based on legitimate interests, including direct marketing. We will cease processing upon a valid objection unless compelling grounds override your interests.

Where you have provided consent for a specific processing activity (such as marketing emails), you may withdraw that consent at any time without affecting the lawfulness of any processing carried out prior to withdrawal.

Please note that certain data rights requests may be subject to identity verification before we can action them, to ensure that personal data is only disclosed or modified at the direction of the rightful owner. We may also need to retain certain data beyond a deletion request where required by law or for the defence of legal claims.
11

Minors & Age Restrictions

The totoxl Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect Personal Data from any individual under the age of 21. Our registration process includes explicit age declaration, and KYC verification requires documentary proof of date of birth.

If we become aware that an Account has been created by or on behalf of a person under 21 years of age, we will immediately suspend that Account, void any associated transactions, and securely delete all Personal Data collected in connection with that Account, except where retention is required by law.

If you believe that a minor has registered an Account on the totoxl Platform, please contact us immediately using the details in Clause 14 so that we can investigate and take appropriate action without delay.

21+ Only. totoxl strongly encourages parents and guardians to use parental control software to prevent minors from accessing online gambling platforms. Details of parental control tools are available on our Responsible Gaming page.
12

International Data Transfers

totoxl operates as a licensed international platform. As a result, your Personal Data may be processed by our staff or third-party service providers located in countries outside Indonesia. Where such international transfers occur, totoxl ensures that adequate data protection safeguards are in place, including:

  • Standard contractual clauses or equivalent data transfer mechanisms with all receiving entities.
  • Data processing agreements that impose data protection obligations equivalent to those described in this Privacy Policy.
  • Transfers only to jurisdictions that maintain an adequate level of data protection as assessed by our compliance team.

By using the totoxl Platform and providing us with your Personal Data, you acknowledge and consent to the transfer of your data to other countries for the purposes described in this Privacy Policy, subject to the safeguards described above.

13

Changes to This Policy

totoxl reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will notify registered Members via email or a prominent on-Platform notification at least 7 days before the updated Policy takes effect.

The version number and "Last updated" date displayed at the top of this page identify the currently applicable edition of this Policy. We encourage you to review this page periodically to stay informed of how we protect your data.

Your continued use of the totoxl Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must cease using the Platform and contact support to arrange Account closure and exercise any applicable data rights.

14

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by totoxl, please contact our Data Protection team through any of the following channels:

  • Live Chat: Available 24/7 directly on the Platform — the fastest way to reach our support team.
  • Email: support [at] totoxl.cam — data rights requests are acknowledged within 3 business days and fulfilled within 30 calendar days.
  • WhatsApp: +62 811 9999 0001 — available 00:00–24:00 WIB (UTC+7), every day.

When contacting us about a data rights request, please include your registered Account email address and a description of the right you wish to exercise. We may ask you to verify your identity before processing the request to ensure your data is protected throughout the process.

totoxl will never contact you to request your Account password, full bank account number, or sensitive KYC document details through any outbound communication. Any such request should be treated as fraudulent and reported to our security team immediately.

Questions About Your Data?

Our support team is available around the clock to assist with any privacy concern or data rights request. You can also explore our FAQ, review our Terms & Conditions, or return to the homepage.