Your privacy matters to us. This Privacy Policy explains exactly what personal data to123 collects, why we collect it, how we use and protect it, and what rights you hold as a member of the to123 platform.
Important Notice: This Privacy Policy ("Policy") is an integral part of the to123 Terms & Conditions and governs the collection, use, storage, and disclosure of personal data by to123 ("the Platform", "we", "us", "our") in connection with the services offered at https://to123.bet. By registering an Account or using any to123 service, you confirm that you have read and understood this Policy and consent to the data practices described herein. If you do not agree to this Policy, you must not use the to123 Platform.
The following terms carry the meanings defined below throughout this Privacy Policy:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information that identifies or could reasonably be used to identify a living individual, including name, email address, date of birth, national identity number, device identifiers, and IP addresses. |
| "Processing" | Any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transmission, erasure, or destruction. |
| "Data Controller" | to123, the entity that determines the purposes and means of processing your Personal Data. |
| "Data Processor" | Any third party that processes Personal Data on to123's behalf under a written data-processing agreement, including payment processors and KYC service providers. |
| "Member" / "You" | Any individual who has registered an Account on to123 or who accesses the Platform without registration. |
| "Account" | The registered user profile created by a Member on the to123 Platform, containing personal details, preferences, transaction history, and responsible gaming settings. |
| "Cookies" | Small text files placed on your device by the to123 Platform or authorised third-party services for the purposes of session management, analytics, and personalisation. |
| "KYC" | Know Your Customer — the identity and age verification process mandated by to123's anti-money-laundering obligations and responsible gaming commitments. |
| "IDR" | Indonesian Rupiah — the exclusive transaction currency accepted on the to123 Platform. |
to123 operates as an internationally licensed online gaming and sports betting platform, serving players across Indonesia including Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, Semarang, and beyond. In the course of providing our services — which encompass sports betting, live casino, slots, poker tournaments, and fish shooting games — to123 necessarily collects and processes certain categories of personal data about the individuals who use the Platform.
This Policy sets out, in plain and transparent language, precisely what data we collect, the lawful grounds on which we process it, the purposes for which it is used, who we may share it with, how long we retain it, and the specific rights you hold in respect of your data. to123 takes its data protection obligations seriously and has designed its data practices to align with internationally recognised privacy principles, including purpose limitation, data minimisation, accuracy, storage limitation, and integrity.
This Policy applies to all data collected via the to123 website at https://to123.bet, any to123 mobile-optimised web experience, customer support communications (including live chat and email correspondence), and any promotional or marketing communications sent by to123 to registered Members or prospective users.
Policy Scope: This Policy applies exclusively to personal data collected and processed by to123 in connection with the Platform's services. It does not govern the data practices of third-party payment processors (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja), game content providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft), or any other independent third parties whose services may be accessed through or alongside the to123 Platform. You should consult those parties' own privacy notices for information on how they handle your data.
to123 collects personal data across several categories, depending on the nature of your interaction with the Platform. The table below summarises the categories of data collected and provides representative examples within each category.
| Category | Examples of Data Collected | Mandatory / Optional |
|---|---|---|
| Identity Data | Full legal name, date of birth, national identity card (KTP) number, passport number, photograph on identity document | Mandatory (KYC) |
| Contact Data | Email address, mobile phone number, residential address (city, province) | Mandatory (Registration) |
| Financial Data | Bank account name and number (BCA, BRI, BNI, Mandiri, CIMB Niaga, etc.), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), deposit history, withdrawal history, transaction amounts in IDR | Mandatory (Payments) |
| Account Data | Username, hashed password, account creation date, account status, preferred currency (IDR), preferred language, responsible gaming settings | Mandatory (Account) |
| Gaming & Betting Data | Bet history, game session logs, wager amounts, win/loss records, bonus claims, tournament participation records | Mandatory (Service Delivery) |
| Technical Data | IP address, device type (desktop/mobile), operating system, browser type and version, screen resolution, session timestamps (WIB, UTC+7), geolocation at login | Automatic Collection |
| Communications Data | Live chat transcripts, email correspondence, support ticket content, promotional communication preferences | Interaction-Based |
| Cookie & Analytics Data | Pages visited, click-through behaviour, session duration, referral source, A/B test group assignment | Automatic Collection |
to123 does not intentionally collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, health data (except as strictly necessary for responsible gaming assessments), or biometric data. If you voluntarily disclose information of this nature during a support interaction or responsible gaming assessment, it will be handled with the highest level of confidentiality and used only for the specific purpose for which it was shared.
to123 collects personal data through the following channels and mechanisms:
You provide data directly to to123 when you: complete the Account registration form; submit KYC verification documents; make a deposit or request a withdrawal; contact customer support via live chat or email; respond to promotional surveys or competitions; or update your Account profile settings.
When you access the to123 Platform, certain data is collected automatically by our server infrastructure and analytics systems. This includes your IP address, device identifiers, browser fingerprint, session start and end timestamps (recorded in WIB, UTC+7), and your navigation path through the Platform. This data is collected using standard web server logs, first-party analytics scripts, and cookies as described in Section 8.
In limited circumstances, to123 may receive personal data about you from third-party sources to assist with identity verification and fraud prevention. These sources include licensed KYC verification service providers, payment processing partners (for transaction verification purposes), and fraud detection databases. to123 will only use data received from third-party sources in conjunction with data you have directly provided to us, and only for the purposes described in this Policy.
Data Accuracy Obligation: You are responsible for ensuring that all personal data you provide to to123 is accurate, complete, and current. Providing false or misleading personal data — including misrepresenting your age, identity, or residential city — is a breach of the to123 Terms & Conditions and may result in immediate Account suspension and forfeiture of balances. If your personal data changes, you must update your Account profile or notify our support team promptly.
to123 processes your personal data only for clearly defined, legitimate purposes. The table below maps each processing activity to its purpose and the data categories involved:
| Processing Purpose | Data Categories Used | Legal Basis (see § 6) |
|---|---|---|
| Account creation and management | Identity, Contact, Account Data | Contract performance |
| KYC / age and identity verification | Identity, Financial Data | Legal obligation; Contract |
| Processing deposits and withdrawals in IDR | Financial, Identity Data | Contract performance |
| Delivering gaming and sports betting services | Account, Gaming & Betting Data | Contract performance |
| Fraud prevention and anti-money-laundering checks | Identity, Financial, Technical Data | Legal obligation; Legitimate interest |
| Responsible gaming monitoring and intervention | Gaming & Betting, Account Data | Legal obligation; Legitimate interest |
| Customer support and dispute resolution | Identity, Contact, Communications Data | Contract performance; Legitimate interest |
| Personalised promotions and bonus offers | Account, Gaming & Betting, Contact Data | Consent |
| Platform analytics and performance optimisation | Technical, Cookie & Analytics Data | Legitimate interest |
| Legal compliance and regulatory reporting | Identity, Financial, Gaming Data | Legal obligation |
to123 may send you promotional communications — including information about new game launches, seasonal bonus offers tied to events such as Idul Fitri, Ramadhan, Chinese New Year (Imlek), or Indonesian Independence Day (17 August), and platform updates — by email or in-platform notification. These communications will only be sent where you have provided your explicit consent during registration or via your Account's communication preferences settings. You may withdraw your consent to marketing communications at any time by updating your Account preferences or by contacting our support team. Withdrawal of marketing consent does not affect any other aspect of our data processing described in this Policy.
to123 relies on the following legal grounds to process your personal data lawfully:
to123 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We may, however, disclose your personal data to the following categories of recipients where strictly necessary for the purposes described in this Policy:
To process deposits and withdrawals in IDR, to123 shares relevant financial and identity data with licensed payment processing partners supporting BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, Bank Danamon, OVO, DANA, GoPay, ShopeePay, and LinkAja transactions. These partners act as Data Processors and are contractually bound to process your data only as directed by to123 and in accordance with applicable data protection standards.
to123 engages licensed third-party KYC service providers to assist with identity verification and age-checking obligations. These providers may access your identity documents and compare them against authoritative identity databases. All KYC providers are contractually obligated to maintain the confidentiality and security of your data and may not use it for any purpose other than verification on to123's behalf.
When you access games provided by third-party studios — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Pocket Games Soft — minimal technical data (such as session tokens and game outcomes) may be exchanged with those providers for the purpose of game delivery and result verification. to123 does not share your identity or financial data with game content providers beyond what is operationally necessary for session authentication.
to123 may disclose your personal data to law enforcement agencies, regulatory bodies, courts, or other governmental authorities where required to do so by applicable law, a valid legal order, or where such disclosure is necessary to protect the safety or rights of to123, its Members, or the general public. to123 will, where legally permitted, notify you of such disclosure requests prior to compliance.
In the event of a merger, acquisition, restructuring, or sale of all or part of to123's business, your personal data may be transferred to the acquiring entity as part of the transaction. In such circumstances, to123 will ensure that appropriate data protection safeguards are in place and will provide advance notice of any material change to this Policy that results from such a transaction.
No Cross-Border Sale of Data: to123 does not transfer or sell your personal data to third parties outside the scope of the processing activities described above. All third-party Data Processors engaged by to123 are subject to written data-processing agreements that impose confidentiality, security, and purpose-limitation obligations consistent with this Policy.
The to123 Platform uses cookies and similar tracking technologies to deliver, maintain, and improve its services. The following categories of cookies are used:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Session authentication, security token management, load balancing, fraud detection signals. Cannot be disabled without breaking core Platform functionality. | Session / Up to 24 hours |
| Functional | Remembering your language preference (English), game lobby layout preferences, responsible gaming notification acknowledgements, and last-visited category. | Up to 12 months |
| Analytics | Aggregated, anonymised usage statistics — page views, session duration, click paths, feature adoption — used to identify improvements to the Platform experience. No individual profiling for advertising purposes. | Up to 24 months |
| Performance | Monitoring page load times, error rates, and API response times to maintain Platform stability across Indonesian network conditions (including mobile data connections common in Jakarta, Surabaya, and other cities). | Up to 12 months |
Most web browsers allow you to control cookies through their settings panel — you can choose to block or delete cookies entirely. Note that blocking strictly necessary cookies will impair or entirely prevent your ability to log in, play games, or process transactions on the to123 Platform. Analytics and functional cookies can be disabled without affecting core Platform functionality. For instructions on managing cookies in your browser, refer to your browser's help documentation.
to123 does not use third-party advertising networks or place cross-site tracking cookies for the purpose of serving targeted advertising on external websites. The analytics data collected by to123 is used exclusively for internal Platform improvement purposes and is not shared with advertising platforms or data brokers.
to123 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable legal or regulatory obligations. The following retention schedule applies:
At the end of any applicable retention period, personal data will be securely deleted or irreversibly anonymised so that it can no longer be associated with any individual. Where anonymisation is not technically feasible, data will be destroyed in a manner that prevents reconstruction.
to123 implements a layered security architecture designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our technical and organisational security measures include:
Your Security Responsibilities: to123's security measures are most effective when complemented by responsible behaviour on your part. You are responsible for keeping your Account password confidential, not sharing your login credentials with any third party, logging out of your Account after each session on shared devices, and promptly notifying to123 at [email protected] if you suspect your Account has been accessed without your authorisation.
As a Member of to123, you hold the following rights in respect of your personal data. to123 is committed to honouring these rights promptly and without undue formality:
To exercise any of the rights listed above, please contact to123 customer support via live chat or email at [email protected] (written as plain text — not a clickable link). to123 may request that you verify your identity before processing a rights request to ensure that data is not disclosed or modified based on a fraudulent request.
to123 is strictly an adults-only platform. The minimum age requirement for all to123 Members is 21 years. to123 does not knowingly collect personal data from individuals under the age of 21. If to123 discovers or has reason to believe that personal data has been provided by an individual under 21, that Account will be immediately suspended, all associated data will be flagged for review, and any balance will be returned to the deposit source after identity verification confirms the account holder's age.
If you are a parent or guardian and believe that a minor under your care has registered on to123, please contact our support team immediately at [email protected] (plain text only — not a clickable link). We will investigate and take prompt action to close the Account and delete the minor's data.
Age Verification: to123 enforces age verification through KYC document checks for all Members prior to processing any withdrawal. Parents and guardians are encouraged to use parental-control software and to keep login credentials for online banking and e-wallet services (including BCA, BRI, OVO, DANA, and GoPay) secure and out of reach of minors. 21+ only. Gambling is not suitable for anyone under 21 years of age.
The to123 Platform may reference third-party services — including payment providers (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay), game studios (Pragmatic Play, Evolution Gaming, NetEnt), and sports data providers — that operate under their own privacy policies. to123 is not responsible for the data practices of these independent third parties. When you leave the to123 Platform to interact with a third-party service, this Privacy Policy no longer applies. We encourage you to review the privacy notices of any third-party service you use in connection with or alongside your to123 Account.
to123 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. When material changes are made to this Policy, to123 will notify registered Members by email to the address on file and will display a prominent notice on the Platform. The Effective Date and Last Updated date at the top of this page will be revised accordingly.
Your continued use of the to123 Platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and request Account closure. We recommend that you review this Policy periodically to stay informed of how to123 protects your personal data.
For any questions, concerns, or formal requests relating to this Privacy Policy or to123's handling of your personal data, please contact us through the following channels:
When submitting a data rights request, please provide sufficient information to allow to123 to verify your identity and locate your Account record. to123 will not process data rights requests received from unverified sources in order to protect the security of all Member data.
to123 is built on a foundation of transparency, security, and respect for every Member's personal data. Here are the six core principles that guide how we handle your information.
Every byte of data exchanged between your device and the to123 Platform is protected by industry-standard SSL/TLS encryption. Your personal details, payment data, and Account credentials are never transmitted in plaintext.
to123 does not sell, rent, or trade your personal data to advertisers, data brokers, or any third party for commercial gain. Your information is used exclusively to deliver, secure, and improve the to123 Platform experience.
to123 enforces strict Know Your Customer checks to verify every Member's identity and age before any withdrawal is processed. This protects our platform from fraud and ensures compliance with our 21+ adults-only commitment.
We do not hold your data indefinitely. to123 applies clearly defined retention schedules to every category of personal data we hold, and securely deletes or anonymises data once those periods expire — no unnecessary storage, ever.
Your data rights are real and actionable. Request access, correction, deletion, or portability of your personal data at any time by contacting our support team. We respond to verified requests within 30 days as standard.
Marketing communications from to123 — including bonus alerts, seasonal promotions for events like Idul Fitri and Ramadhan, and new game announcements — are consent-based. You may opt out at any time through your Account settings with immediate effect.
Now that you understand how to123 protects your personal data, explore everything the platform has to offer — from live sports betting on BRI Liga 1 and the Champions League, to premium slots, live casino tables, poker tournaments, and fish shooting games. Trusted, secure, and fully committed to responsible gaming. Adults only — 21+.