5toto Privacy Policy

1. Introduction and Scope

5toto ("we," "us," or "our") operates the online betting and gaming platform at https://5toto.cam. This Privacy Policy describes how 5toto collects, processes, stores, and protects the personal data of individuals ("you," "your," or "Member") who access or use our platform — including the website, mobile-optimized interface, customer support channels, and any associated services.

This policy applies to all Members registered on the 5toto platform, including residents of Jakarta, Surabaya, Bandung, Bali, Medan, Yogyakarta, and all other regions of Indonesia. It covers personal data collected through account registration, gameplay activity, financial transactions, customer support interactions, and browsing behavior on the platform.

5toto takes its responsibilities under applicable international data protection standards seriously. We process your data only for the purposes described in this policy and only to the extent necessary to provide you with a secure, functional, and compliant gaming experience.

2. Personal Data We Collect

2.1 Data You Provide Directly

When you register an account, complete KYC verification, make deposits or withdrawals, or contact our support team, you provide us with personal data that may include:

• Identity Data: Full legal name, date of birth, nationality, and copies of government-issued identification (KTP, Passport, or Driver's License).
• Contact Data: Email address, Indonesian mobile phone number, and residential address.
• Financial Data: Bank account details for Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja) used for deposits and withdrawals.
• KYC Documentation: Scanned or photographed identity documents and proof of address submitted during account verification.
• Communications Data: Content of emails, live chat transcripts, and support tickets you submit to 5toto.

2.2 Data Collected Automatically

When you access the 5toto platform, we automatically collect certain technical and behavioral data, including:

• Device and Technical Data: IP address, browser type and version, operating system, device model, screen resolution, and time zone (typically WIB, UTC+7 for Jakarta-based users).
• Usage Data: Pages visited, features used, session duration, betting history, game selections (including sports bets on BRI Liga 1, EPL, and Champions League fixtures, togel lottery numbers, and live casino sessions), login timestamps, and navigation patterns.
• Transaction Data: Deposit and withdrawal history, bet amounts in IDR, wagering activity, bonus usage, and account balance changes.
• Cookie Data: Data stored via cookies and similar tracking technologies as described in Section 6 of this policy.

2.3 Data from Third Parties

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

• Identity verification and KYC service providers who validate your documents against government databases.
• Payment processors and financial institutions that confirm the validity of your bank account or e-wallet.
• Fraud prevention and anti-money laundering (AML) screening services.
• Marketing analytics partners (in aggregated, non-personally identifiable form).

3. How We Use Your Data

5toto uses your personal data for the following purposes:

Purpose	Data Used	Legal Basis
Account registration and management	Identity, Contact	Contract performance
Identity verification (KYC)	Identity, KYC Documentation	Legal obligation
Processing deposits and withdrawals	Financial, Transaction	Contract performance
Fraud prevention and AML compliance	Identity, Financial, Usage	Legal obligation / Legitimate interest
Responsible gaming monitoring	Usage, Transaction	Legal obligation / Legitimate interest
Customer support	Contact, Communications	Contract performance
Platform improvement and analytics	Usage, Device/Technical	Legitimate interest
Promotional communications (opt-in)	Contact, Usage	Consent
Legal compliance and record-keeping	All categories	Legal obligation

We do not use your personal data for any purpose not listed above without first informing you and, where required, obtaining your consent.

4. Legal Basis for Processing

5toto processes your personal data on one or more of the following legal grounds:

• Contract Performance: Processing is necessary to provide the services you have contracted for — including account management, game access, and financial transactions.
• Legal Obligation: 5toto is required to process certain data to comply with international AML regulations, KYC obligations, and responsible gaming requirements imposed by our licensing jurisdiction.
• Legitimate Interest: We process certain data where we have a legitimate business interest, such as fraud prevention, platform security, and improving service quality — provided these interests do not override your fundamental rights and freedoms.
• Consent: For optional activities such as marketing emails or push notifications, we rely on your explicit consent. You may withdraw consent at any time without affecting your ability to use the platform.

5. Data Sharing and Third Parties

5.1 Service Providers

5toto shares your personal data with carefully selected third-party service providers who assist in operating the platform. These include:

• KYC and identity verification providers.
• Payment processing partners facilitating transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Game software providers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and Pocket Games Soft — who may process anonymized session data to deliver game content.
• Customer support platform providers and live chat software vendors.
• Cybersecurity and DDoS protection providers.
• Cloud hosting and data storage providers.

All third-party service providers are contractually required to process your data solely on 5toto's instructions and in accordance with applicable data protection standards.

5.2 Legal Disclosures

5toto may disclose your personal data to law enforcement agencies, regulatory authorities, or government bodies when required by applicable law, court order, or regulatory directive. We will notify you of such disclosures wherever legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the privacy protections applicable to your data.

5.4 No Sale of Personal Data

5toto does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. Your data is used solely to operate the platform and deliver the services described in this policy.

6. Cookies and Tracking Technologies

6.1 Types of Cookies Used

5toto uses cookies and similar technologies to improve your experience on the platform. The categories of cookies we use are:

• Essential Cookies: Required for the platform to function correctly. These include session authentication cookies that keep you logged in and security tokens that protect against CSRF attacks. These cookies cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings, preferred deposit method, and game lobby filters.
• Analytics Cookies: Collect anonymized data about how you interact with the platform — pages visited, time spent, and features used — to help us improve the product.
• Marketing Cookies: Used only with your consent to measure the effectiveness of promotional campaigns.

6.2 Managing Cookies

You can control cookie preferences through your browser settings. Please be aware that disabling essential cookies will prevent you from logging in or using certain platform features. Detailed instructions for managing cookies are available in your browser's help documentation.

7. Data Retention

5toto retains your personal data for as long as necessary to fulfil the purposes described in this policy, subject to the following minimum retention periods:

• Account Data: Retained for the duration of your account plus 5 years following account closure, to comply with AML record-keeping obligations.
• Transaction Data: Retained for a minimum of 5 years from the date of each transaction.
• KYC Documentation: Retained for a minimum of 5 years from the date of submission.
• Customer Support Records: Retained for 2 years from the date of the final interaction.
• Marketing Preferences: Retained until you withdraw consent or request deletion.

Following the applicable retention period, personal data is securely deleted or anonymized in accordance with industry best practices.

8. Data Security

5toto implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security infrastructure includes:

• SSL/TLS Encryption: All data transmitted between your device and the 5toto platform is encrypted using industry-standard SSL/TLS protocols.
• At-Rest Encryption: Sensitive personal data stored on our servers — including financial data and KYC documents — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 5toto personnel on a need-to-know basis. All staff with access to personal data undergo data protection training.
• Two-Factor Authentication: 5toto's internal systems require multi-factor authentication for all staff accessing production databases.
• Penetration Testing: The platform undergoes regular third-party security audits and penetration testing.
• Incident Response: 5toto maintains a data breach response plan. In the event of a breach affecting your personal data, we will notify you and relevant authorities within the timeframe required by applicable law.

While 5toto takes all reasonable precautions to secure your data, no internet-based platform can guarantee absolute security. You are encouraged to use a strong, unique password for your 5toto account and to enable two-factor authentication.

9. Your Rights as a Data Subject

As a Member of the 5toto platform, you have the following rights with respect to your personal data:

• Right of Access: You may request a copy of the personal data 5toto holds about you.
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected.
• Right to Erasure: You may request deletion of your personal data where there is no legitimate reason for 5toto to continue processing it. Note that certain data must be retained for legal compliance purposes and cannot be deleted.
• Right to Restrict Processing: You may request that 5toto restrict the processing of your data in certain circumstances.
• Right to Data Portability: You may request a machine-readable copy of the personal data you have provided to 5toto.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the legality of prior processing.

To exercise any of the above rights, please contact 5toto's data protection team via email at [email protected]. We will respond to your request within 30 days. We may need to verify your identity before processing your request.

10. Cross-Border Data Transfers

As an internationally operated platform serving Indonesian players, 5toto may transfer certain personal data to servers or service providers located outside Indonesia. When such transfers occur, 5toto ensures that adequate safeguards are in place, including contractual data protection clauses equivalent to internationally recognized standards (such as Standard Contractual Clauses), to protect your personal data to the same level as required within Indonesia.

5toto's primary data processing infrastructure is hosted on servers with redundant geographic locations to ensure platform availability and resilience for users across the Indonesian archipelago, from Sumatra and Java to Bali, Kalimantan, Sulawesi, and beyond.

11. Protection of Minors

The 5toto platform is strictly for adults aged 21 years and older. We do not knowingly c ollect or process personal data from individuals under the age of 21. During account registration, all Members are required to confirm their date of birth, and identity verification procedures are in place to detect and prevent underage registration.

If 5toto becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, any funds will be returned to the depositing payment method following verification, and all associated personal data will be securely deleted. If you believe a minor has registered on our platform, please contact us immediately at [email protected].

12. Changes to This Policy

5toto reserves the right to update or revise this Privacy Policy at any time. When material changes are made, we will notify registered Members via email and post a prominent notice on the platform for a minimum of 14 days prior to the changes taking effect. The "Last Updated" date at the top of this policy reflects the most recent revision.

Your continued use of the 5toto platform following notification of changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with any changes, you may close your account by contacting our support team.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or 5toto's data protection practices, please reach out to our dedicated data protection team:

• Email: [email protected]
• Live Chat: Available 24/7 via the platform — Indonesian-speaking agents are on hand to assist.
• Response Time: We aim to acknowledge all privacy-related inquiries within 48 hours and provide a substantive response within 30 calendar days.

For additional information about your rights as a 5toto Member, please also review our Terms & Conditions and Responsible Gaming Policy.