1. Introduction and Scope
toke69 operates an online betting and gaming platform serving the Indonesian market, offering sports betting, live casino games, togel (Indonesia's traditional numbers lottery), sabung ayam (live cockfighting streams), slot games, and other gaming products. As part of providing these Services, we collect and process personal information about our Members in accordance with applicable Indonesian data protection laws and international best practices.
This Privacy Policy applies to all Users and Members of the toke69 platform, including visitors who browse the website without registering, individuals who create an Account, and active Members who place bets and engage with our gaming products. This policy covers all data collection, processing, and storage activities conducted through the toke69 website (https://toke69.cam) and any related mobile-optimized versions or applications.
2. Information We Collect
We collect several categories of personal information to operate the Platform, verify identities, process transactions, prevent fraud, and deliver personalized Services. The types of information we collect include:
2.1 Information You Provide Directly
When you register for an Account on toke69, you provide the following information:
- Identity Information: Full legal name (as it appears on your government-issued identification), date of birth, gender, nationality, and a copy of your Indonesian National Identity Card (KTP Nasional), passport, or driver's license.
- Contact Information: Email address, mobile phone number, residential address (street address, city, province, postal code), and country of residence.
- Account Credentials: Username, password (stored in encrypted form), and security questions or PIN codes used for account authentication.
- Financial Information: Bank account details (bank name, account number, account holder name) or e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja account numbers) used for deposits and withdrawals. We do not store full credit or debit card numbers; payment card transactions are processed through encrypted third-party payment gateways.
- Verification Documents: Copies of government-issued identification, proof of address (utility bills, bank statements), and selfie photographs holding identification documents, submitted for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance.
2.2 Information We Collect Automatically
When you access and use the 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 (Chrome, Safari, Firefox, Edge), screen resolution, and device identifiers (IMEI, MAC address, advertising ID).
- Connection Information: IP address, Internet Service Provider (ISP), approximate geographic location (derived from IP address), time zone setting, and connection timestamps.
- Usage Data: Pages viewed, features accessed, time spent on each page, click patterns, navigation paths, search queries, game selections, bet history, transaction history, deposit and withdrawal records, session duration, and frequency of visits.
- Communication Records: Transcripts of live chat conversations with customer support, email correspondence, WhatsApp messages, in-app messages, and any other communications between you and toke69.
- Marketing Preferences: Whether you have opted in or out of promotional emails, SMS messages, push notifications, and other marketing communications.
2.3 Information from Third Parties
We may receive information about you from third-party sources, including:
- Payment Processors: Transaction details, payment method verification, and fraud risk scores from banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja).
- Identity Verification Services: Results of identity checks, document authenticity verification, and fraud detection screenings conducted by third-party KYC/AML service providers.
- Marketing Partners: If you access toke69 through an affiliate link or marketing campaign, we may receive information about the referral source and campaign parameters.
3. How We Use Your Information
toke69 uses your personal information for the following purposes:
3.1 Account Management and Service Delivery
- To create, maintain, and manage your Account.
- To authenticate your identity and prevent unauthorized access.
- To process deposits, withdrawals, and other financial transactions.
- To provide access to betting markets, casino games, togel, sabung ayam streams, and slot games.
- To calculate and credit winnings, settle bets, and adjust account balances.
- To display transaction history, bet history, and account statements.
3.2 Legal and Regulatory Compliance
- To verify that you are at least 21 years of age and legally eligible to gamble.
- To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations.
- To detect, prevent, and investigate fraud, money laundering, terrorist financing, and other illegal activities.
- To respond to legal requests, court orders, subpoenas, and regulatory inquiries from Indonesian or international authorities.
- To enforce our Terms & Conditions and investigate suspected violations.
3.3 Customer Support and Communication
- To respond to your inquiries, questions, and support requests via live chat, email, WhatsApp, and in-app messaging.
- To notify you of account activity, transaction confirmations, withdrawal approvals, and security alerts.
- To send administrative messages related to changes in our policies, terms, or services.
3.4 Marketing and Promotions
- To send promotional offers, bonus announcements, and marketing communications (only if you have opted in).
- To personalize marketing content based on your gaming preferences and betting history.
- To conduct surveys, collect feedback, and measure customer satisfaction.
3.5 Platform Improvement and Analytics
- To analyze usage patterns, identify popular features, and optimize the user experience.
- To detect and fix technical issues, bugs, and performance bottlenecks.
- To conduct A/B testing and experiment with new features or layouts.
- To generate aggregated, anonymized statistics for internal business purposes (these anonymized statistics do not identify individual users).
3.6 Responsible Gaming and Player Protection
- To monitor betting patterns and identify signs of problem gambling.
- To enforce deposit limits, session time limits, and self-exclusion requests.
- To provide access to responsible gaming tools and resources.
- To comply with our obligations under our Responsible Gaming Policy.
4. Legal Basis for Processing (Indonesian Context)
Under Indonesian data protection principles and international standards, we process your personal information based on the following legal grounds:
- Consent: You provide explicit consent when you create an Account and accept this Privacy Policy.
- Contractual Necessity: Processing is necessary to fulfill our obligations under the Terms & Conditions, including providing Services, processing transactions, and settling bets.
- Legal Obligation: Processing is required to comply with Indonesian and international laws, including KYC/AML regulations, tax reporting, and responses to lawful government requests.
- Legitimate Interest: Processing is necessary for our legitimate business interests, such as fraud prevention, security, platform improvement, and marketing (where you have not opted out).
5. How We Share Your Information
toke69 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may share your information with the following categories of recipients:
5.1 Service Providers and Business Partners
- Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata), e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), and payment gateway operators process your financial transactions on our behalf.
- Identity Verification Providers: Third-party KYC/AML service providers verify your identity documents, conduct fraud checks, and screen for politically exposed persons (PEPs) and sanctions lists.
- Game Providers: Licensed game studios (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, Pocket Games Soft, Play'n GO, Habanero, OneTouch, Hacksaw Gaming, Push Gaming) receive limited information (username, session ID, bet amounts) to operate live casino tables and slot games.
- Cloud Hosting and Infrastructure: We use secure cloud hosting services to store data and deliver the Platform. These providers are contractually bound to maintain strict security and confidentiality standards.
- Customer Support Tools: Live chat, email ticketing, and CRM platforms process your communications with our support team.
- Analytics and Marketing Platforms: We use analytics tools (Google Analytics, Mixpanel, Amplitude) and marketing automation platforms (SendGrid, Mailchimp) to measure performance and deliver promotional content. These tools may collect anonymized or pseudonymized data.
5.2 Legal and Regulatory Authorities
We may disclose your information to Indonesian government agencies, law enforcement, regulatory bodies, or courts if required by law, court order, subpoena, or regulatory investigation. This includes disclosures related to:
- Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) investigations.
- Tax reporting and compliance with Indonesian tax authorities.
- Criminal investigations, fraud prevention, and protection of public safety.
- Enforcement of intellectual property rights or legal claims.
5.3 Business Transfers
In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor company. You will be notified of any such change via email or prominent notice on the Platform.
6. Data Security Measures
toke69 implements industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security practices include:
6.1 Technical Safeguards
- Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS (Secure Sockets Layer / Transport Layer Security) protocols. Sensitive data stored in our databases (passwords, financial information) is encrypted at rest using AES-256 encryption.
- Access Controls: Access to personal data is restricted to authorized personnel only, based on role-based access control (RBAC) principles. Employees and contractors with access to personal data are bound by strict confidentiality agreements.
- Firewalls and Intrusion Detection: Our servers are protected by enterprise-grade firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) that monitor for suspicious activity and block unauthorized access attempts.
- Regular Security Audits: We conduct periodic security audits, vulnerability assessments, and penetration testing to identify and remediate potential weaknesses.
- Multi-Factor Authentication (MFA): We offer optional two-factor authentication (2FA) for Account login, adding an extra layer of security beyond username and password.
6.2 Organizational Safeguards
- Employee Training: All toke69 employees and contractors receive mandatory training on data protection, privacy best practices, and security protocols.
- Incident Response Plan: We maintain a documented incident response plan to quickly detect, contain, and remediate any data breach or security incident. In the event of a breach affecting your personal information, we will notify you and relevant authorities as required by law.
- Data Minimization: We collect only the minimum amount of personal information necessary to provide Services and comply with legal obligations. We regularly review and delete data that is no longer needed.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:
| Data Type |
Retention Period |
Reason |
| Account Information |
Duration of Account + 7 years |
Legal and tax compliance, dispute resolution |
| Transaction Records |
7 years from transaction date |
Indonesian tax law, AML regulations |
| KYC/AML Documents |
7 years after Account closure |
Regulatory compliance, legal requirements |
| Bet History |
Duration of Account + 7 years |
Dispute resolution, audit trails |
| Marketing Communications |
Until opt-out or Account closure |
Marketing consent management |
| Support Transcripts |
3 years from conversation date |
Quality assurance, training, dispute resolution |
After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with our data retention and deletion policies.
8. Your Privacy Rights
As a User of toke69, you have the following rights regarding your personal information:
8.1 Right to Access
You have the right to request a copy of the personal information we hold about you. To exercise this right, contact our customer support team at [email protected]. We will provide the requested information within 30 days, subject to identity verification.
8.2 Right to Rectification
If any of your personal information is inaccurate, incomplete, or outdated, you have the right to request correction or update. You can update most information directly through your Account settings, or contact customer support for assistance.
8.3 Right to Erasure (Right to be Forgotten)
You have the right to request deletion of your personal information under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent. However, we may be required to retain certain information for legal, regulatory, or legitimate business purposes (e.g., transaction records for tax compliance, AML documentation).
8.4 Right to Restrict Processing
You have the right to request that we restrict or limit the processing of your personal information in certain situations, such as when you contest the accuracy of the data or when processing is unlawful but you do not want the data deleted.
8.5 Right to Data Portability
You have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format (e.g., CSV, JSON), and to request that we transmit this data to another service provider where technically feasible.
8.6 Right to Object to Processing
You have the right to object to processing of your personal information for direct marketing purposes at any time. You can opt out of marketing communications by clicking the "unsubscribe" link in promotional emails, adjusting your Account preferences, or contacting customer support.
8.7 Right to Withdraw Consent
Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of processing conducted prior to withdrawal.
8.8 Right to Lodge a Complaint
If you believe that we have violated your privacy rights or applicable data protection laws, you have the right to lodge a complaint with the relevant Indonesian data protection authority or supervisory body.
9. Cookies and Tracking Technologies
toke69 uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. Types of cookies we use include:
- Strictly Necessary Cookies: Essential for the operation of the Platform, including session management, authentication, and security. These cookies cannot be disabled.
- Performance and Analytics Cookies: Collect anonymized information about how visitors use the Platform, including page views, click patterns, and session duration. This data helps us improve the user experience.
- Functionality Cookies: Remember your preferences (e.g., language, time zone, currency display) to provide a more personalized experience.
- Marketing and Advertising Cookies: Track your activity across websites to deliver targeted advertisements and measure the effectiveness of marketing campaigns. These cookies may be set by third-party advertising networks.
You can control cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, but disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, visit your browser's help documentation.
10. Third-Party Links and Services
The toke69 Platform may contain links to third-party websites, services, or content (e.g., game provider websites, social media platforms, payment processor portals). We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party services you access through our Platform.
11. Children's Privacy
toke69 is an adults-only platform. We do not knowingly collect personal information from individuals under the age of 21 (or the legal age of majority in your jurisdiction, whichever is greater). If we become aware that we have inadvertently collected information from a minor, we will take immediate steps to delete that information and terminate the associated Account. If you believe that we have collected information from a minor, please contact us immediately at [email protected].
12. International Data Transfers
Your personal information may be transferred to, stored, and processed in countries outside of Indonesia, including jurisdictions that may have different data protection standards. When we transfer data internationally, we implement appropriate safeguards to ensure that your information remains protected in accordance with this Privacy Policy and applicable laws. These safeguards may include standard contractual clauses, data processing agreements, and adequacy decisions.
13. Changes to This Privacy Policy
toke69 reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. The "Last Updated" date at the top of this document reflects the most recent revision. We will notify you of material changes by posting a prominent notice on the Platform or by sending an email to the address associated with your Account. Your continued use of the Platform after any changes constitutes acceptance of the revised Privacy Policy.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using the following methods:
- Email: [email protected]
- Live Chat: Available 24/7 through the toke69 website
- WhatsApp: +62 811 0000 6969 (available 07:00–23:00 WIB daily)
- In-App Messaging: Send a message through your Account dashboard
We aim to respond to all privacy-related inquiries within 14 business days. For urgent privacy concerns, please use live chat or WhatsApp for the fastest response.