Privacy Policy

1. Introduction

Welcome to the toro12 Privacy Policy (hereinafter "Privacy Policy" or "Policy"). This document explains how toro12 (hereinafter "we," "us," "our," or "the Platform") collects, uses, stores, processes, discloses, and protects the personal information of users (hereinafter "you," "your," or "User") who access our online gaming platform at https://toro12.cam (hereinafter "the Website").

At toro12, we are committed to protecting your privacy and ensuring the security of your personal data. We recognize that when you provide us with personal information, you are placing trust in us to handle that data responsibly and transparently. This Privacy Policy has been designed to help you understand what information we collect, why we collect it, how we use it, and what choices you have regarding your personal data.

This Privacy Policy applies to all personal data processed by toro12 in connection with our gaming services, including but not limited to casino games, sports betting (bandar bola), live dealer experiences, and all related features. By creating an account, using our Website, or providing us with any personal information, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with our privacy practices, please do not use the Platform or provide us with any personal information.

This Privacy Policy should be read in conjunction with our Terms and Conditions, which govern your use of the toro12 Platform. In the event of any conflict between this Privacy Policy and the Terms and Conditions regarding data protection matters, the provisions of this Privacy Policy shall prevail.

2. Data Controller Identity

For the purposes of applicable data protection legislation, toro12 acts as the data controller responsible for the collection, processing, and protection of your personal information. As data controller, we determine the purposes for which and the manner in which your personal data is processed.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer using the contact details provided in Section 14 of this Policy. We are committed to responding to all privacy inquiries within 30 days of receipt.

3. Information We Collect

toro12 collects various categories of personal information to provide, maintain, improve, and protect our gaming services. The types of information we collect include:

3.1 Information You Provide Directly

When you register for an account on toro12, you voluntarily provide us with the following personal information:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification documents (e-KTP, passport, driver's license) for age verification and KYC (Know Your Customer) compliance.
• Contact Information: Residential address in Indonesia (street, city, postal code), email address, and mobile phone number.
• Account Credentials: Username, password (stored in encrypted format), and security questions/answers.
• Financial Information: Bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, or other supported banks; e-wallet information (OVO, DANA, GoPay account IDs); transaction history including deposits, withdrawals, stakes, and winnings.
• Communications: Any information you provide when contacting customer support via live chat, email, or phone, including the content of your messages, attachments, and support tickets.

3.2 Information We Collect Automatically

When you access and use the toro12 Platform, we automatically collect certain technical and usage information:

• Device Information: Device type (desktop, mobile, tablet), operating system (Windows, macOS, Android, iOS), browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information.
• Log Data: IP address, access timestamps, pages viewed, links clicked, time spent on pages, referring/exit pages, search queries, and error reports.
• Gaming Activity: Games played, bet amounts, game outcomes, session durations, game preferences, favorite games, and responsible gaming limit settings.
• Location Data: Geolocation information derived from your IP address to verify that you are accessing the Platform from within Indonesia and to prevent unauthorized access from restricted jurisdictions.
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixel tags, and similar technologies (see Section 10 for details).

3.3 Information from Third-Party Sources

We may receive information about you from third-party service providers, including:

• Payment Processors: Transaction verification data from banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) to confirm deposit and withdrawal processing.
• Identity Verification Services: Age verification, identity authentication, and fraud detection data from third-party KYC service providers.
• Game Providers: Game session data, game outcomes, and fairness verification data from certified providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, and Spribe.
• Marketing Partners: If you arrive at toro12 through a referral or affiliate link, we may receive limited information about the referral source.

4. How We Use Your Personal Data

toro12 processes your personal information for the following purposes:

4.1 Account Management and Service Delivery

• Create, maintain, and manage your toro12 gaming account.
• Verify your identity, age (21+ requirement), and residency in Indonesia to comply with legal and regulatory obligations.
• Process deposits and withdrawals via BCA, BRI, BNI, Mandiri, and e-wallet services.
• Provide access to casino games, sports betting markets, live dealer tables, and all platform features.
• Record and settle bets, calculate winnings, and credit payouts to your account balance.
• Communicate account-related notifications including transaction confirmations, withdrawal approvals, and security alerts.

4.2 Customer Support and Communication

• Respond to your inquiries, support requests, and complaints via live chat, email, or phone.
• Provide technical assistance, troubleshoot account issues, and resolve disputes.
• Send important service announcements including maintenance schedules, Terms updates, and policy changes.

4.3 Compliance, Security, and Fraud Prevention

• Comply with legal obligations including anti-money laundering (AML), counter-terrorism financing (CTF), and responsible gaming regulations.
• Verify the legitimacy of financial transactions and detect fraudulent or suspicious activity.
• Monitor for multi-accounting, bonus abuse, collusion, bot usage, and other Terms violations.
• Protect the security and integrity of the toro12 Platform and prevent unauthorized access.
• Investigate and resolve security incidents, data breaches, and Terms violations.

4.4 Responsible Gaming and Player Protection

• Monitor gaming activity to identify signs of problem gambling behavior.
• Enforce deposit limits, loss limits, session time limits, and self-exclusion requests.
• Provide access to responsible gaming tools and resources.
• Intervene when we detect concerning patterns of play and connect at-risk players with support services.

4.5 Marketing and Promotions (With Your Consent)

• Send promotional offers, bonus notifications, tournament invitations, and VIP program updates via email or SMS.
• Personalize marketing content based on your game preferences and activity history.
• Conduct surveys and request feedback to improve our services.

Note: You may opt out of marketing communications at any time by clicking the unsubscribe link in emails or contacting customer support. Opting out will not affect essential service communications.

4.6 Platform Improvement and Analytics

• Analyze usage patterns, game preferences, and user behavior to improve platform design and functionality.
• Develop new features, games, and services based on user feedback and data insights.
• Conduct A/B testing to optimize user experience.
• Generate aggregated, anonymized statistics and reports (which do not identify individual users) for business analysis.

5. Legal Basis for Processing

Under international data protection principles, we process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations under the Terms and Conditions, including account creation, payment processing, and service delivery.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including age verification, KYC, AML/CTF, tax reporting, and responsible gaming mandates.
• Consent: Where you have provided explicit consent, such as opting in to marketing communications or agreeing to cookie usage.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, platform improvement, and customer support, provided these interests do not override your fundamental rights and freedoms.

6. Data Sharing and Disclosure

toro12 does not sell your personal information to third parties. However, we may share your data with the following categories of recipients under strict confidentiality and data protection obligations:

6.1 Service Providers and Business Partners

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals.
• Game Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and other certified providers to deliver games and verify outcomes.
• Identity Verification Services: Third-party KYC and age verification providers to authenticate your identity and prevent fraud.
• Customer Support Tools: Live chat platforms, helpdesk software, and communication service providers to deliver customer support.
• Cloud Hosting and Data Storage: Secure cloud infrastructure providers to store data and host platform services.
• Analytics and Monitoring Services: Tools that help us analyze usage, detect fraud, and improve performance.

6.2 Legal and Regulatory Authorities

We may disclose your personal information to law enforcement agencies, regulators, tax authorities, or other government bodies when required by law, court order, subpoena, or legal process, or when we believe disclosure is necessary to:

• Comply with applicable laws and regulations, including AML/CTF reporting requirements.
• Respond to lawful requests from public authorities, including national security or law enforcement demands.
• Protect the rights, property, and safety of toro12, our users, or the public.
• Investigate suspected fraud, Terms violations, or illegal activity.

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy involving toro12, your personal information may be transferred to the successor entity or acquiring party, subject to the same privacy protections outlined in this Policy.

6.4 With Your Consent

We may share your information with third parties for purposes not described in this Policy, provided we have obtained your explicit consent to do so.

7. Data Security Measures

toro12 takes data security extremely seriously and has implemented comprehensive technical and organizational measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

While we employ industry-leading security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security; however, we continuously invest in security infrastructure and best practices to minimize risks to your personal data.

8. Data Retention Periods

toro12 retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Account Data: Personal information associated with active accounts is retained for the duration of your membership and for 7 years following account closure to comply with financial regulations, AML/CTF requirements, and tax reporting obligations.
• Transaction Records: Deposit, withdrawal, and gaming transaction records are retained for 7 years as required by financial services regulations.
• Communications: Customer support communications, live chat logs, and emails are retained for 3 years for quality assurance and dispute resolution purposes.
• Marketing Consent: If you opt out of marketing communications, your preference is retained indefinitely to ensure we do not contact you again.
• Self-Exclusion Records: If you self-exclude from toro12, your exclusion record is retained permanently to prevent account reopening and protect your wellbeing.
• Fraud and Security Data: Information related to fraud investigations, security incidents, or Terms violations may be retained indefinitely to protect the Platform and other users.

Upon expiration of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer identify you.

9. Your Privacy Rights

You have the following rights regarding your personal data held by toro12:

9.1 Right of Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of that data. You may access most of your personal information directly through your Account settings page.

9.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You may update your contact details, address, and payment methods via Account settings or by contacting customer support.

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

You may request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. However, we may be required to retain certain data to comply with legal obligations (e.g., 7-year financial record retention for AML/CTF).

9.4 Right to Restrict Processing

You may request that we limit the processing of your personal data in certain situations, such as when you contest the accuracy of the data or object to our processing.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.

9.6 Right to Object

You may object to processing of your personal data based on legitimate interests or for direct marketing purposes. If you object to marketing, we will cease such processing immediately.

9.7 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.

9.8 Right to Lodge a Complaint

If you believe your privacy rights have been violated, you have the right to lodge a complaint with your local data protection authority.

How to Exercise Your Rights: To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 14. We will respond to your request within 30 days. Some requests may require identity verification to protect your data from unauthorized access.

10. Cookies and Tracking Technologies

toro12 uses cookies, web beacons, pixel tags, and similar technologies to enhance your experience, analyze usage, and deliver personalized content. Cookies are small text files stored on your device that help us recognize you on return visits.

Types of Cookies We Use:

• Essential Cookies: Necessary for platform functionality, including login authentication, account security, and session management. These cannot be disabled.
• Performance Cookies: Collect anonymous usage statistics to help us understand how visitors interact with the Website and identify areas for improvement.
• Functionality Cookies: Remember your preferences (language, currency display, game favorites) to personalize your experience.
• Marketing Cookies: Track your activity across websites to deliver targeted advertising. These require your consent and can be disabled via cookie settings.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may impair platform functionality.

11. International Data Transfers

Your personal information may be transferred to and processed in countries other than Indonesia where our servers, service providers, or business partners are located. These countries may have different data protection laws than Indonesia.

When transferring data internationally, toro12 ensures appropriate safeguards are in place, including:

• Standard contractual clauses approved by relevant data protection authorities.
• Binding corporate rules where transfers occur within our corporate group.
• Adequacy decisions confirming that the destination country provides adequate protection.
• Your explicit consent where other safeguards are not available.

12. Children's Privacy

toro12 services are intended exclusively for adults aged 21 years or older. We do not knowingly collect, use, or disclose personal information from individuals under 21. If we discover that we have inadvertently collected personal data from a person under 21, we will delete that information immediately and terminate the associated account.

If you are a parent or guardian and believe your child has provided personal information to toro12, please contact us immediately at [email protected] so we can take appropriate action.

13. Changes to This Privacy Policy

toro12 reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting the updated Privacy Policy on this page with a new "Last Updated" date.
• Sending an email notification to the address registered with your account (for significant changes).
• Displaying a prominent notice on the Website homepage or within your account dashboard.

Your continued use of toro12 services following notification of changes constitutes acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your data.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or how toro12 processes your personal data, please contact us:

For urgent security concerns (such as suspected account compromise or data breach), please contact us immediately via live chat or email [email protected].