1. Introduction

titi12 ("we", "us", "our", "the Company", "the Platform") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, share, and protect the personal data you provide when using our online betting services, including our website, mobile-optimized site, and all associated features (collectively, the "Service").

By registering an account, accessing the titi12 platform, or using any part of our Service, you acknowledge that you have read, understood, and agree to the data practices described in this Privacy Policy. This Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy, which together form the complete legal framework governing your use of titi12.

We are committed to complying with applicable data protection laws and regulations, including but not limited to the principles of the General Data Protection Regulation (GDPR) and other international privacy standards. We process your personal data lawfully, fairly, and transparently, and we take your privacy rights seriously.

2. Data Controller Information

For the purposes of data protection law, the data controller responsible for your personal information is titi12. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, you may contact us at:

  • Email: [email protected]
  • Live Chat: Available 24/7 via the chat widget on our website
  • Response Time: We aim to respond to all privacy-related inquiries within 72 hours

3. What Personal Data We Collect

To provide our betting services, process transactions, verify your identity, comply with legal obligations, and deliver a secure and personalized experience, titi12 collects several categories of personal information. The types of data we collect include:

3.1 Account Registration Information

When you create a titi12 account, we collect:

  • Full legal name (as it appears on your government-issued ID)
  • Date of birth (to verify that you are at least 21 years old)
  • Gender
  • Residential address (street address, city, province, postal code)
  • Email address
  • Mobile phone number
  • Username and password (password is stored in encrypted form)
  • Preferred currency (Indonesian Rupiah / IDR)

3.2 Identity Verification (KYC) Documents

To comply with anti-money-laundering (AML) regulations and prevent fraud, we require identity verification before processing withdrawals. KYC documents include:

  • Government-issued photo identification (Indonesian KTP, passport, or driver's license)
  • Proof of address (utility bill, bank statement, or government correspondence dated within the last 3 months)
  • Photographs or scans of the above documents
  • In some cases, a selfie photograph holding your ID for biometric verification

3.3 Financial and Transaction Data

When you deposit or withdraw funds, we collect and process:

  • Payment method details (bank account number, e-wallet account ID — note: we do not store full credit card numbers or CVV codes)
  • Transaction amounts, dates, and times
  • Transaction histories (deposits, withdrawals, wagers, winnings)
  • Bank or e-wallet transaction reference numbers
  • Payment provider records (shared by BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, etc.)

3.4 Betting and Gaming Activity

To provide the Service and comply with gaming regulations, we collect data about your use of the platform, including:

  • Bets placed (sport, market, selection, odds, stake, outcome)
  • Casino games played (game name, provider, session duration, wins/losses)
  • Account balance history
  • Bonuses claimed and wagering progress
  • Session timestamps and durations
  • Responsible Gaming tool usage (deposit limits, self-exclusion status)

3.5 Technical and Usage Data

When you access the titi12 platform, we automatically collect certain technical information:

  • IP address (used for geolocation verification and fraud prevention)
  • Device type and operating system (desktop, mobile, iOS, Android, Windows, etc.)
  • Browser type and version
  • Screen resolution and device identifiers
  • Pages visited, clickstream data, and navigation paths
  • Referral source (how you arrived at our site)
  • Cookies and similar tracking technologies (see Section 8 for details)

3.6 Communications and Customer Support

When you contact our Customer Support team, we may collect:

  • Chat transcripts and email correspondence
  • Voice recordings (if you contact us via phone — we will inform you if a call is being recorded)
  • Attachments or screenshots you send to us
  • Complaint records and resolution notes

4. How We Use Your Personal Data

titi12 processes your personal information for specific, legitimate purposes necessary to provide our services and comply with legal obligations. We use your data for the following purposes:

Purpose Legal Basis
Account Creation and Management — Setting up your account, authenticating your login, and maintaining your profile. Contractual Necessity
Identity Verification (KYC/AML) — Verifying your age, identity, and address to comply with anti-money-laundering regulations and prevent fraud. Legal Obligation
Processing Transactions — Handling deposits, withdrawals, and internal fund transfers. Communicating with payment providers. Contractual Necessity
Providing Betting Services — Accepting bets, settling wagers, managing bonuses, calculating odds, and delivering game content from third-party providers. Contractual Necessity
Customer Support — Responding to inquiries, resolving disputes, and providing technical assistance. Contractual Necessity / Legitimate Interest
Fraud Prevention and Security — Detecting suspicious activity, preventing multiple accounts, identifying collusion or chip dumping, and protecting the platform from cyber attacks. Legitimate Interest / Legal Obligation
Responsible Gaming — Enforcing deposit limits, monitoring play patterns for signs of problem gambling, and facilitating self-exclusion requests. Legal Obligation / Legitimate Interest
Marketing and Promotions — Sending you personalized offers, bonuses, and newsletters (only if you have opted in; you may opt out at any time). Consent / Legitimate Interest
Platform Improvement — Analyzing usage patterns, improving user experience, testing new features, and optimizing performance. Legitimate Interest
Legal Compliance and Reporting — Cooperating with regulators, law enforcement, tax authorities, and auditors as required by law. Legal Obligation

We Do Not Sell Your Personal Data

titi12 does not sell, rent, or lease your personal information to third parties for their own marketing purposes. We only share data with trusted service providers who assist us in operating the platform, and only under strict confidentiality agreements.

5. Who We Share Your Data With

In order to provide our services and comply with legal obligations, titi12 may share your personal information with the following categories of third parties:

5.1 Payment Service Providers

We share necessary transaction data with banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP) and e-wallet providers (OVO, DANA, GoPay, ShopeePay) to process deposits and withdrawals. These providers are bound by their own privacy policies and banking confidentiality rules.

5.2 Game Providers

When you play casino games or slots, certain data (user ID, bet amount, game session) is shared with third-party Game Providers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, and Pocket Games Soft. These providers operate under their own licenses and are required to maintain game fairness and data security.

5.3 Identity Verification and Fraud Prevention Services

We may use third-party KYC verification services and fraud detection tools to validate your identity, check for duplicate accounts, and detect suspicious activity. These services process limited personal data (name, date of birth, ID document) for verification purposes only.

5.4 Customer Support and Communication Tools

We use third-party live chat and email platforms to deliver customer support. These providers have access to your support conversations and are bound by data processing agreements to protect your information.

5.5 Regulators and Law Enforcement

We may be required to disclose your personal data to gaming regulators, tax authorities, law enforcement agencies, or courts if compelled by law, subpoena, or regulatory request. We will only share the minimum data necessary to comply with the legal obligation.

5.6 Auditors and Legal Advisors

Independent auditors, legal counsel, and compliance consultants may access your data as part of regulatory audits, financial reviews, or legal proceedings. These parties are bound by professional confidentiality obligations.

All third parties with whom we share data are contractually required to protect your information, use it only for the specified purpose, and comply with applicable data protection laws.

6. How Long We Keep Your Data

titi12 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal, regulatory, and contractual obligations. Specific retention periods include:

  • Account Data: Retained for the duration of your account's active status, plus 7 years after account closure to comply with financial record-keeping and anti-money-laundering regulations.
  • Transaction Records: Retained for 7 years after the transaction date to comply with tax and financial regulations.
  • KYC Documents: Retained for 7 years after account closure or last transaction, whichever is later.
  • Customer Support Records: Retained for 3 years after the date of the last interaction.
  • Marketing Consent Records: Retained until you withdraw consent, plus 2 years for audit purposes.
  • Responsible Gaming Data: Self-exclusion records are retained for the duration of the exclusion period plus 7 years.

After the applicable retention period expires, we will securely delete or anonymize your personal data so that it can no longer be linked to you.

7. How We Protect Your Data

titi12 employs industry-standard technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

  • SSL Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL encryption.
  • Password Security: Passwords are hashed and salted using strong cryptographic algorithms and are never stored in plain text.
  • Access Controls: Personal data is accessible only to authorized titi12 employees and contractors who need it to perform their job functions. Access is granted on a need-to-know basis and is logged for audit purposes.
  • Server Security: Our servers are hosted in secure data centers with physical access controls, firewalls, intrusion detection systems, and 24/7 monitoring.
  • Regular Security Audits: We conduct periodic security assessments and vulnerability testing to identify and remediate potential risks.
  • Data Backup: Regular backups are performed and stored in geographically separate locations to prevent data loss.

While we take every reasonable precaution to protect your data, no internet-based system can be 100% secure. If we become aware of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant authorities in accordance with applicable law.

8. Cookies and Tracking Technologies

titi12 uses cookies and similar tracking technologies to enhance your experience, analyze site usage, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize you when you return to our site.

8.1 Types of Cookies We Use

  • Essential Cookies: Required for the platform to function. These cookies enable account login, session management, and secure transactions. You cannot opt out of essential cookies.
  • Performance Cookies: Collect anonymous data about how you use the site (pages visited, time spent, etc.) to help us improve the user experience.
  • Functional Cookies: Remember your preferences (language, display settings) to provide a more personalized experience.
  • Marketing Cookies: Track your browsing activity to deliver relevant promotional offers. These cookies are only set if you opt in to marketing communications.

8.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies, though doing so may affect your ability to use certain features of the titi12 platform. For more information on managing cookies, consult your browser's help documentation.

9. Your Privacy Rights

Under applicable data protection laws, you have certain rights regarding your personal information. titi12 respects these rights and will respond to your requests in accordance with legal requirements.

9.1 Right of Access

You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format within 30 days of your request.

9.2 Right to Rectification

If you believe that any of your personal data is inaccurate or incomplete, you have the right to request that we correct or update it. You can update most of your account information directly via your account settings.

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

You may request that we delete your personal data in certain circumstances, such as when the data is no longer necessary for the purpose for which it was collected or if you withdraw consent. However, we may be legally required to retain certain data (e.g., transaction records, KYC documents) for regulatory compliance.

9.4 Right to Restrict Processing

You may request that we limit the processing of your personal data in certain situations, such as while we investigate a dispute or verify the accuracy of the data.

9.5 Right to Data Portability

You have the right to receive your personal data in a portable format and, where technically feasible, to have it transmitted directly to another service provider.

9.6 Right to Object

You may object to the processing of your personal data for direct marketing purposes at any time. You can opt out of marketing communications by clicking the "unsubscribe" link in any promotional email or by contacting Customer Support.

9.7 Right to Withdraw Consent

If we process your data based on your consent (e.g., for marketing), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.

9.8 How to Exercise Your Rights

To exercise any of these rights, please contact us at [email protected] with your request. We may require proof of identity to verify your request and ensure that we do not disclose your data to unauthorized parties.

10. International Data Transfers

titi12 primarily serves customers in Indonesia. However, some of our service providers (such as Game Providers and cloud hosting services) may be located outside Indonesia. When we transfer your personal data internationally, we ensure that appropriate safeguards are in place, such as:

  • Standard Contractual Clauses (SCCs) approved by data protection authorities
  • Adequacy decisions by relevant regulators
  • Binding Corporate Rules or equivalent protections

We ensure that all international transfers comply with applicable data protection laws and that your data receives the same level of protection as it would within Indonesia.

11. Children's Privacy

titi12 does not knowingly collect or process personal data from individuals under the age of 21. Our services are intended solely for adults who meet the legal age requirement for online gambling in their jurisdiction.

If we become aware that we have inadvertently collected personal information from a person under 21, we will take immediate steps to delete that information and close the associated account. If you believe that a minor has provided us with personal data, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

titi12 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Any changes will be effective immediately upon posting to this page, and the "Last Updated" date at the top of this document will be revised accordingly.

We encourage you to review this Privacy Policy periodically. If we make material changes that significantly affect your rights, we will notify you by email or through a prominent notice on our website. Continued use of the Service after any changes constitutes acceptance of the revised Privacy Policy.

13. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way titi12 processes your personal data, please contact our Data Protection team:

  • Email: [email protected] (mark subject line "Privacy Inquiry")
  • Live Chat: Available 24/7 via the chat widget on our website
  • Response Time: We aim to respond to all privacy-related inquiries within 72 hours

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

Our Data Protection Principles

titi12 is committed to handling your personal data responsibly and transparently.

Security First

Your data is protected with 256-bit SSL encryption, secure password hashing, and industry-standard security protocols.

No Data Selling

We never sell, rent, or lease your personal information to third parties for their marketing purposes.

Transparent Processing

We clearly explain what data we collect, why we collect it, and how it is used in plain, understandable language.

Your Rights Respected

We honor your rights to access, correct, delete, or restrict the processing of your personal data.

Data Minimization

We collect only the data necessary to provide our services and comply with legal obligations — nothing more.

Limited Retention

We retain your data only as long as required by law or for the purpose collected, then securely delete it.

Questions About Your Privacy?

Our Customer Support team is available 24/7 to answer any questions about how titi12 protects and manages your personal data. Contact us via live chat or email.