Privacy Policy

1.1 totod5 ("we", "us", "the Company") operates the online betting and gaming platform accessible at totod5.cam. We are committed to safeguarding the personal information of every individual who interacts with our platform, whether as a registered member, a visitor, or a prospective member.

1.2 This Privacy Policy sets out the types of personal data we collect, the purposes for which we process it, the grounds on which processing is lawful, and the rights available to you in relation to your data. It should be read alongside our Terms & Conditions, which govern the overall use of the totod5 platform.

1.3 totod5 serves members primarily based in Indonesia. When we reference applicable law in this policy, we refer to internationally recognized data-protection principles as well as relevant Indonesian legal frameworks governing the handling of personal data.

1.4 This policy was last reviewed and updated on January 1, 2026. We encourage you to revisit this page periodically to stay informed of any changes.

2.1 For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, identification number, address, email address, payment-account details, and IP address.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, or deletion.
• "Data Controller" — the Company, which determines the purposes and means of processing Personal Data collected through the totod5 platform.
• "Data Processor" — any third-party entity that processes Personal Data on behalf of the Company under a written data-processing agreement.
• "Member" — an individual who has completed registration on the totod5 platform and whose account is active or has been active.
• "KYC" — Know Your Customer: the mandatory identity and age-verification process applied to all members before withdrawal processing or access to certain account features.
• "Cookies" — small text files placed on a Member's device by the totod5 platform for session management, analytics, and preference storage.

3.1 totod5 collects the following categories of personal data:

3.2 We do not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data beyond what is strictly required for KYC document verification.

4.1 totod5 collects Personal Data through the following means:

• Direct submission: Data you provide when registering an account, completing the KYC process, making a deposit or withdrawal, or contacting our support team.
• Automated collection: Technical and behavioral data collected automatically as you use the platform, including through cookies, web beacons, server logs, and similar tracking technologies.<
• Third-party sources: In limited circumstances, we may receive data from payment processors, identity-verification service providers, or fraud-detection partners to supplement the information you have provided directly.
• Public sources: Publicly available information may be used to verify details provided during registration or KYC, or to investigate suspected fraudulent activity.

4.2 You are under no obligation to provide Personal Data to totod5. However, certain categories of data — particularly Identity Data, Contact Data, and Financial Data — are mandatory for account creation and operation. Without this information, we are unable to provide our services to you.

5.1 totod5 processes your Personal Data for the following purposes:

• Account management: Creating, maintaining, and administering your member account on the totod5 platform.
• Identity verification (KYC): Verifying that you meet the minimum age requirement of 21 years and confirming your identity before processing withdrawals.
• Transaction processing: Facilitating deposits and withdrawals in Indonesian Rupiah (IDR) through supported local banks and e-wallets, and maintaining an accurate record of your account balance.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible gaming: Monitoring wagering patterns to identify members who may be at risk of problem gambling, and administering self-exclusion, deposit limit, and time-out tools.
• Customer support: Responding to your queries, resolving disputes, and maintaining records of communications for quality and training purposes.
• Legal and regulatory compliance: Meeting obligations under applicable law, including anti-money-laundering (AML) requirements, and responding to lawful requests from authorities.
• Platform improvement: Analyzing aggregated, anonymized behavioral data to improve the performance, functionality, and user experience of the totod5 platform.
• Marketing communications (optional): Sending you promotional offers, bonus notifications, and platform updates — only where you have provided explicit consent or where we have a legitimate interest that does not override your privacy rights.

5.2 totod5 will not use your Personal Data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing a separate lawful basis.

6.1 totod5 processes your Personal Data on the following legal grounds:

• Contractual necessity: Processing that is required to fulfill our obligations to you under the Terms & Conditions — including account creation, transaction processing, and KYC verification — is carried out on the basis of contractual necessity.
• Legal obligation: Certain processing activities — such as retaining financial transaction records and cooperating with law-enforcement authorities — are required by applicable law and are carried out on the basis of legal obligation.
• Legitimate interests: We process Technical Data and Behavioral Data on the basis of our legitimate interests in maintaining platform security, preventing fraud, and improving our services. We conduct a balancing test to ensure that our legitimate interests do not override your fundamental privacy rights.
• Consent: Where we rely on your consent — for example, to send marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent may be exercised by contacting [email protected].

7.1 totod5 does not sell, rent, or trade your Personal Data to third parties for commercial gain. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors and banking partners: Banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, and e-wallet providers including OVO, DANA, GoPay, ShopeePay, and LinkAja — to the extent required to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers that assist us in verifying member identities and screening for financial crime risk. These providers are contractually bound to process data only on our instructions and in accordance with applicable law.
• Game content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive limited technical data (such as a pseudonymous player ID) to deliver game content. These providers do not receive your full name, contact details, or financial account information.
• Analytics and security providers: Service providers that help us monitor platform performance, detect fraud, and analyze aggregated usage data. All such providers are engaged under data-processing agreements that restrict their use of your data.
• Regulatory and law-enforcement authorities: We may disclose Personal Data to government bodies, courts, or law-enforcement agencies where required by law or in response to a valid legal process. Where legally permitted, we will notify you of such a disclosure.
• Group companies: Where totod5 is part of a corporate group, Personal Data may be shared with affiliated entities for internal administrative purposes, subject to the same privacy protections described in this policy.

8.1 totod5 uses cookies and similar tracking technologies to operate and improve the platform. The main categories of cookies we use are:

• Essential cookies: Required for the platform to function. These include session cookies that keep you logged in during your visit and security cookies that help prevent cross-site request forgery. These cookies cannot be disabled without impairing your ability to use the platform.
• Functional cookies: Store your preferences — such as preferred language, display settings, and last-used payment method — so you do not need to re-enter them on each visit.
• Analytics cookies: Collect anonymized data about how members navigate the platform (pages visited, session duration, error messages encountered). This data is used in aggregate form to improve platform performance and user experience.
• Security and fraud-detection cookies: Help us identify unusual access patterns, detect automated bots, and protect member accounts from unauthorized access.

8.2 Most modern browsers allow you to manage cookie preferences through your browser settings. Blocking essential cookies will impair platform functionality. Blocking analytics or functional cookies will not prevent you from using the platform but may reduce the quality of your experience.

8.3 totod5 does not use third-party advertising cookies or behavioral retargeting cookies that track your activity across external websites.

9.1 totod5 retains Personal Data for as long as necessary to fulfill the purposes for which it was collected, and in any event for no longer than required by applicable law. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your membership and for a minimum of 5 years after account closure, to meet anti-money-laundering record-keeping obligations.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, in line with financial record-keeping requirements.
• KYC documents: Retained for a minimum of 5 years after the conclusion of the business relationship, or longer where required by a specific regulatory authority.
• Support and communication records: Retained for 2 years from the date of the last communication, unless the record is relevant to an ongoing dispute, in which case it is retained until resolution.
• Technical and log data: Typically retained for 12 months from collection, after which it is anonymized or deleted.
• Marketing consent records: Retained for the duration of your consent, and for 3 years after consent is withdrawn, to demonstrate compliance.

9.2 When Personal Data is no longer required, it is securely deleted or anonymized in a manner that ensures it cannot be re-identified.

10.1 totod5 applies industry-standard technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data fields (including KYC document files and financial account details) at rest on our servers.
• Role-based access controls ensuring that only authorized personnel can access personally identifiable information, and only to the extent required for their role.
• Regular penetration testing and security audits conducted by independent third-party specialists.
• Multi-factor authentication requirements for internal staff accessing member data systems.
• Documented data-breach response procedures, including notification protocols for affected members where required by law.

10.2 While we take all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials. If you suspect unauthorized access to your account, contact [email protected] immediately.

11.1 As a member of totod5, you hold the following rights in relation to your Personal Data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We will respond within 30 days.

12.1 The totod5 platform is strictly intended for adults aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21.

12.2 Age verification is a mandatory step in the KYC process. Every member is required to provide documentary proof of age (KTP or passport) before withdrawals are enabled. Where our verification processes identify that a member is under 21, their account will be closed immediately, all associated data will be retained only as required by law, and any balance — including winnings — will be voided.

12.3 If you are a parent or guardian and have reason to believe that a minor in your care has registered an account on totod5, please contact [email protected] immediately. We will investigate and take appropriate action without delay.

13.1 As an internationally operated platform, totod5 may transfer your Personal Data to servers or service providers located outside Indonesia. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this policy.

13.2 Safeguards for international transfers may include:

• Standard contractual clauses approved by a recognized data-protection authority, incorporated into agreements with overseas Data Processors.
• Transfer to countries or territories that provide an adequate level of data protection as recognized by international standards.
• Binding corporate rules where data is transferred within a corporate group.

13.3 You may request further information about the specific safeguards applicable to international transfers of your data by contacting [email protected].

14.1 totod5 reserves the right to update this Privacy Policy at any time to reflect changes in our data-processing practices, applicable law, or platform features. When material changes are made, we will notify active members by email or via an in-platform notification at least 14 days before the revised policy takes effect.

14.2 The "Last updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this policy periodically.

14.3 Your continued use of the totod5 platform after the effective date of a revised Privacy Policy constitutes your acknowledgment of the changes. If you object to any amendment, you should contact our support team or close your account prior to the effective date.

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the way totod5 handles your Personal Data, please contact us through the following channels:

• Email: [email protected] (plain text — not a clickable link). Use the subject line "Privacy Inquiry" for faster routing.
• WhatsApp: +62 811 9999 0000 (plain text — not a clickable link). Available during support hours (08:00–24:00 WIB).
• Live Chat: Available through the platform interface, 24 hours a day, 7 days a week, staffed by Indonesian-speaking support agents.

15.2 For formal data-rights requests (access, erasure, portability, objection), please email [email protected] with the subject line "Data Rights Request" and include your registered email address and a description of the right you wish to exercise. We will respond within 30 calendar days.

15.3 If you are not satisfied with our response to a data-rights request or a privacy complaint, you may have the right to escalate the matter to a relevant data-protection authority in your jurisdiction.