Your privacy is a core operational commitment at tot12. This Privacy Policy explains precisely what personal data we collect, how we use it, who we share it with, and what rights you hold over your own information as a Member of our platform.
Key principles that shape how tot12 handles your personal data — before you read the full policy below.
tot12 collects only the personal data that is strictly necessary for account management, identity verification, transaction processing, and legal compliance. We do not collect data speculatively.
tot12 does not sell, rent, or lease your personal data to third parties for their own marketing or commercial purposes. Data sharing is limited to the specific purposes described in this policy.
All data transmitted between your device and tot12's servers is protected by industry-standard 256-bit SSL encryption. Sensitive data at rest is encrypted using AES-256.
Members have the right to access, correct, and request deletion of their personal data. tot12 provides a clear process for exercising these rights, detailed in Section 10 of this policy.
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law, including anti-money laundering record-keeping obligations.
If you have consented to marketing communications from tot12, you may withdraw that consent at any time by contacting our support team. Opt-out requests are processed within five business days.
This Privacy Policy ("Policy") describes how tot12 ("we", "us", "the Platform", "tot12") collects, uses, stores, and discloses personal data relating to individuals ("you", "Member", "User") who access or use the tot12 platform at https://tot12.cam, including all associated services, products, and communications.
This Policy applies to all personal data processed by tot12 in connection with the operation of the Platform, regardless of the device or method used to access it. It should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.
tot12 primarily serves players in Indonesia. By registering an account or using the Platform, you confirm that you are at least 21 years of age and that you have read and understood this Policy.
| Term | Meaning |
|---|---|
| "Personal Data" | Any information that directly or indirectly identifies a living individual, including name, email address, date of birth, bank account number, IP address, and device identifiers. |
| "Processing" | Any operation performed on personal data — collection, storage, use, disclosure, deletion, or any combination thereof. |
| "Data Controller" | tot12, the entity that determines the purposes and means of processing personal data collected through the Platform. |
| "Data Processor" | A third party engaged by tot12 to process personal data on tot12's behalf and under tot12's documented instructions (e.g., payment processors, KYC verification providers). |
| "KYC" | Know Your Customer — the regulatory process by which tot12 verifies the identity, age, and address of Members. |
| "Consent" | A freely given, specific, informed, and unambiguous indication of a Member's agreement to the processing of their personal data for a stated purpose. |
The categories of personal data tot12 collects depend on your relationship with the Platform. The principal categories are described below.
| Data Category | Examples | Why Collected |
|---|---|---|
| Identity Data | Full name, date of birth, nationality, KTP (Indonesian national ID) or passport number | Account creation, KYC verification, age verification (21+ requirement) |
| Contact Data | Email address, phone number, residential address | Account communication, KYC address verification, customer support |
| Financial Data | Bank account name and number (BCA, BRI, BNI, Mandiri, etc.), e-wallet identifiers (OVO, DANA, GoPay), transaction history | Processing deposits and withdrawals, fraud prevention, AML compliance |
| Transaction Data | Bet records, game sessions, deposit and withdrawal history, bonus usage, wallet balance history | Account management, dispute resolution, regulatory reporting, responsible gaming monitoring |
| Technical Data | IP address, browser type, device identifiers, operating system, session timestamps, referral URL | Platform security, fraud detection, user experience optimization |
| KYC Document Data | Photographs of identity documents, selfie images, address proof documents | Mandatory identity and age verification per platform policy |
| Communications Data | Content of emails, live chat transcripts, support tickets submitted to tot12 | Customer support, dispute resolution, quality assurance |
| Marketing Preferences | Opt-in/opt-out status for promotional email and push notifications | Managing consent for marketing communications |
tot12 collects personal data through the following means:
tot12 processes personal data only where a valid lawful basis exists. The primary lawful bases relied upon are:
tot12 uses personal data collected from Members for the following specific purposes:
tot12 does not sell personal data. Data is shared only in the following circumstances and only to the extent necessary for the stated purpose:
tot12 engages third-party service providers who process personal data on our behalf under binding data processing agreements. These include KYC verification platforms, payment processors (for BCA, BRI, BNI, Mandiri, OVO, DANA, and other integrated methods), game content providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, PGSoft), fraud detection services, and cloud infrastructure providers. All processors are contractually required to implement appropriate security measures and are prohibited from using Member data for their own purposes.
tot12 may disclose personal data to regulatory authorities, law enforcement agencies, courts, or other public bodies where required to do so by applicable law — for example, in response to a lawful court order, a regulatory inspection, or an AML/CTF reporting obligation. In such cases, tot12 will disclose only what is strictly required and, where legally permitted, will notify the affected Member.
In the event of a merger, acquisition, or sale of all or substantially all of tot12's assets, personal data held by tot12 may be transferred to the acquiring entity. Members will be notified in advance of any such transfer and of any material change in how their data will be processed.
tot12 may share personal data with third parties in any other circumstance where you have provided explicit, informed consent.
As an international platform serving Indonesian players, tot12 may transfer personal data to servers or processors located outside Indonesia. Where such transfers occur, tot12 ensures that adequate safeguards are in place — including contractual clauses that impose data protection obligations equivalent to those applicable under recognized international data protection frameworks.
Specifically, KYC document data processed by our third-party verification provider may be temporarily transferred to secure servers in jurisdictions with recognized data protection standards. In all cases, transfers are conducted under data processing agreements that prohibit secondary use of the data.
tot12 retains personal data for as long as necessary to fulfill the purpose for which it was collected, subject to any longer retention period required by law. Specific retention periods by data category are as follows:
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized. Anonymized data (from which all identifying information has been removed) may be retained indefinitely for analytics purposes.
As a Member of tot12, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with your registered account email address and a description of your request. We will respond within 30 calendar days.
Request a copy of the personal data tot12 holds about you, along with information on how it is being used.
Request correction of any inaccurate or incomplete personal data held about you.
Request deletion of your personal data where it is no longer needed for the purpose it was collected, subject to legal retention obligations.
Request that tot12 limit the processing of your personal data in certain circumstances, such as while a rectification request is being assessed.
Request a machine-readable copy of your personal data in a structured, commonly used format for transfer to another service provider.
Object to the processing of your personal data for direct marketing purposes or on the basis of legitimate interests. Objections to marketing are always honored without qualification.
tot12 implements a multi-layered security framework to protect Member personal data against unauthorized access, disclosure, alteration, and destruction. Key measures include:
In the event of a data breach that is likely to result in a risk to the rights and freedoms of affected Members, tot12 will notify affected Members and relevant authorities within a reasonable timeframe as required by applicable data protection regulations.
tot12 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device that allow tot12 to recognize your browser across sessions.
You can control and delete cookies through your browser settings. Disabling strictly necessary cookies may impair your ability to use the Platform. Analytics cookies may be disabled without affecting core functionality. tot12 does not use cookies to collect personal data for sale to third parties.
tot12 is strictly for adults aged 21 and over. The Platform does not knowingly collect personal data from individuals under the age of 21. If we discover that personal data has been collected from a minor, that data will be deleted immediately, the relevant account suspended, and any funds processed returned net of any fraudulently obtained bonuses.
If you believe that a minor has registered on tot12 using your payment details or personal information, contact us immediately at [email protected].
The tot12 Platform integrates third-party services — including game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, PGSoft), payment processors, and identity verification providers. These third parties operate under their own privacy policies and data practices. tot12 is not responsible for the privacy practices of third-party services accessed through the Platform.
tot12 ensures that all third-party processors who handle Member personal data are bound by contractual data processing agreements that prohibit secondary use and require appropriate security standards. Members are encouraged to review the privacy policies of any third-party service they interact with independently.
tot12 reserves the right to update this Privacy Policy at any time. When material changes are made, we will notify registered Members via the email address on their account with a minimum of seven (7) calendar days' notice before the revised policy takes effect. The "Last Reviewed" date at the top of this page will be updated accordingly.
Continued use of tot12 after the effective date of any revision constitutes acceptance of the updated Privacy Policy. If you do not accept the revised policy, you must cease using the Platform and may request account closure by contacting support.
For any questions, requests, or complaints relating to this Privacy Policy or the processing of your personal data by tot12, please contact our Data & Privacy team through the following channel:
If you are not satisfied with tot12's response to a privacy complaint, you have the right to escalate the matter to the relevant data protection authority in your jurisdiction. Indonesian residents may contact the Kementerian Komunikasi dan Informatika (KOMINFO) or the relevant supervisory authority for matters concerning personal data protection under Indonesian law.
Our FAQ covers common questions about account security and data handling. You can also review our full Terms & Conditions or Responsible Gaming policy for related information.