Privacy Policy — koitot Platform

1. Introduction

koitot is committed to protecting the privacy and security of our players' personal information. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have regarding your personal information. We recognize that privacy is a fundamental right, and we have designed our platform and practices to respect that right.

This Privacy Policy applies to all users of the koitot platform accessible at https://koitot.cam, including visitors who browse the site without registering, registered players with active accounts, and former players whose accounts have been closed. It covers personal data collected through the website, mobile interface, customer support channels, and any other point of contact between you and koitot.

2. Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person. This includes but is not limited to names, email addresses, phone numbers, residential addresses, dates of birth, government-issued identity numbers, payment details, IP addresses, and behavioral data.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Subject" means the individual to whom Personal Data relates — in this context, the player or user of the koitot platform.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this case, koitot.
• "Third Party" means any entity other than koitot and the Data Subject, including service providers, payment processors, and regulatory authorities.
• "Cookies" means small text files placed on your device by a website to store information about your preferences and activity.

3. Data Controller

koitot is the Data Controller responsible for your Personal Data. We determine how and why your information is processed. If you have any questions about how we handle your data, or if you wish to exercise any of your data rights, you may contact us at the details provided in Section 15 of this policy.

4. Information We Collect

4.1 Account Registration Data

When you create an account on koitot, we collect the following Personal Data:

• Full legal name as it appears on your government-issued identity document.
• Date of birth to verify that you meet the minimum age requirement of 21 years.
• Residential address including street, city, province, and postal code.
• Email address for account communication and support.
• Mobile phone number for account verification and security alerts.
• Username and password (passwords are stored in encrypted form and are not accessible to koitot staff).

4.2 Identity Verification (KYC) Data

To comply with Know Your Customer (KYC) and anti-money laundering regulations, we collect:

• Copies of government-issued photo identification documents (Indonesian National Identity Card / KTP, passport, or driver's license / SIM).
• Proof of residential address documents (utility bills, bank statements, or official correspondence dated within the last three months).
• Selfie photographs holding your identity document for facial verification.
• Payment method verification documents (screenshots or statements confirming ownership of bank accounts or e-wallets such as BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay).

4.3 Financial Transaction Data

When you make deposits or withdrawals, we collect:

• Payment method details (bank account numbers, e-wallet IDs).
• Transaction amounts, dates, and times.
• Transaction reference numbers and status.
• Currency used (typically Indonesian Rupiah / IDR).

Note: koitot does not store full credit card numbers or CVV codes. Card payments, where available, are processed by PCI-DSS compliant third-party payment processors.

4.4 Betting and Gaming Data

We collect information about your activity on the platform, including:

• Bets placed, including bet type (sports betting, togel numbers lottery, casino games, slots), stake amounts, odds, and outcomes.
• Games played, session durations, win/loss records.
• Bonus claims, wagering progress, and promotional participation.
• Responsible gaming tool usage (deposit limits, self-exclusion requests, session alerts).

4.5 Technical and Device Data

When you access koitot, we automatically collect:

• IP address and geographic location data (city/region level).
• Device type, operating system, browser type and version.
• Screen resolution, language settings, time zone (typically WIB, UTC+7 for Indonesia).
• Pages visited, features used, time spent on the platform.
• Referral source (how you arrived at the koitot website).

4.6 Communication Data

If you contact our customer support team, we collect:

• The content of your messages, inquiries, and support tickets.
• Email correspondence, live chat transcripts, and any documents or screenshots you provide.
• Support ticket resolution history and feedback.

5. How We Collect Data

koitot collects Personal Data through the following methods:

• Directly from you: When you register an account, complete KYC verification, make deposits or withdrawals, place bets, or contact customer support.
• Automatically through technology: Via cookies, web beacons, server logs, and similar tracking technologies that record your interactions with the platform.
• From third parties: Payment processors provide transaction confirmation data. Identity verification services may provide authentication results. Sports data providers supply odds and results for betting markets.
• From publicly available sources: In rare cases, we may verify information you provide against publicly available databases to comply with anti-fraud and anti-money laundering obligations.

6. How We Use Your Data

koitot processes your Personal Data for the following purposes:

6.1 Account Management

To create, maintain, and manage your player account, including verifying your identity, processing registrations, and maintaining accurate records.

6.2 Service Delivery

To provide access to betting markets, casino games, togel lottery draws, and all other services offered on the koitot platform. This includes processing your bets, calculating winnings, and crediting payouts to your account balance.

6.3 Payment Processing

To process deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja). This includes verifying payment method ownership and preventing fraudulent transactions.

6.4 Regulatory Compliance

To comply with Know Your Customer (KYC), anti-money laundering (AML), and counter-terrorism financing (CTF) regulations. This includes age verification, identity authentication, and transaction monitoring.

6.5 Platform Security

To detect and prevent fraud, collusion, bonus abuse, multi-accounting, hacking attempts, and other prohibited activities. We use automated systems and manual reviews to protect platform integrity and player funds.

6.6 Customer Support

To respond to your inquiries, resolve technical issues, investigate disputes, and provide assistance in both English and Indonesian (Bahasa Indonesia) through our 24/7 support team.

6.7 Responsible Gaming

To identify problem gambling behaviors, enforce responsible gaming tools (deposit limits, self-exclusion, session alerts), and intervene when player activity suggests potential harm. This is a core component of our commitment to player welfare.

6.8 Marketing Communications

With your consent, to send promotional emails about bonuses, new game releases, and special offers. You may opt out of marketing communications at any time by clicking the unsubscribe link in any email or contacting support.

6.9 Platform Improvement

To analyze aggregated usage patterns, improve user experience, optimize performance, and develop new features. This includes A/B testing, feature usage analysis, and performance monitoring.

7. Data Sharing & Disclosure

koitot does not sell or rent your Personal Data to third parties for marketing purposes. However, we may share your data in the following circumstances:

7.1 Service Providers

We share data with trusted third-party service providers who perform functions on our behalf, including:

• Payment processors to facilitate deposits and withdrawals.
• Identity verification services to conduct KYC checks and authenticate documents.
• Cloud hosting providers to store data securely.
• Customer support software providers to manage support tickets and live chat.
• Analytics providers to understand platform usage (with anonymized or pseudonymized data where possible).

All service providers are contractually required to protect your data and use it only for the purposes specified by koitot.

7.2 Game Providers

When you play games from third-party studios (Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, Pocket Games Soft, Spribe), limited data (user ID, bet amounts, game outcomes) is shared with those providers to deliver the gaming experience. Game providers are bound by their own privacy policies and contractual obligations to koitot.

7.3 Regulatory Authorities

We may disclose Personal Data to regulatory bodies, licensing authorities, law enforcement agencies, or other government entities when required by law or when we believe in good faith that disclosure is necessary to comply with legal obligations, protect our rights, or investigate potential violations.

7.4 Corporate Transactions

In the event of a merger, acquisition, asset sale, or bankruptcy, your Personal Data may be transferred to the acquiring entity or successor organization, subject to the same privacy protections outlined in this policy.

7.5 With Your Consent

We may share your data with other third parties if you provide explicit consent at the time of collection or sharing.

8. Cookies & Tracking Technologies

koitot uses cookies and similar tracking technologies to enhance your experience on the platform. Cookies are small text files stored on your device that allow us to remember your preferences, keep you logged in, and analyze platform usage.

8.1 Types of Cookies We Use

• Essential Cookies: Required for the platform to function. These cookies enable core features such as account login, session management, and secure checkout. You cannot opt out of essential cookies without losing functionality.
• Performance Cookies: Collect anonymous data about how you use the platform, which pages you visit, and which features you use. This helps us identify and fix technical issues and improve overall performance.
• Functionality Cookies: Remember your preferences such as language selection, currency display, and interface settings to provide a personalized experience.
• Advertising Cookies: Track your activity across the web to deliver relevant marketing messages (if you have consented to marketing). These cookies are typically set by third-party ad networks.

8.2 Managing Cookies

You can control and delete cookies through your browser settings. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies will prevent you from using certain features of the koitot platform, including account login and placing bets.

9. Data Security Measures

koitot employs industry-standard technical and organizational measures to protect your Personal Data against unauthorized access, accidental loss, destruction, or damage. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encrypted storage of sensitive data including passwords (using bcrypt or similar hashing algorithms) and payment information.
• Access controls restricting employee access to Personal Data on a need-to-know basis, with all access logged and audited.
• Firewalls and intrusion detection systems to protect against unauthorized network access.
• Regular security audits and penetration testing to identify and remediate vulnerabilities.
• Employee data protection training and confidentiality agreements binding all staff members.
• Secure data centers with physical access controls, redundant power supplies, and environmental monitoring.

Despite these measures, no data transmission over the internet or storage system is 100% secure. While we strive to protect your Personal Data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

10. Data Retention

koitot retains your Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by applicable law.

• Active accounts: Data is retained for the duration of your account's active status.
• Closed accounts: After account closure, we retain Personal Data for up to seven (7) years to comply with financial record-keeping, tax, and anti-money laundering regulations.
• Inactive accounts: Accounts with no login activity for 24 consecutive months may be classified as dormant and subject to data archival or deletion after notification.
• Marketing data: If you opt out of marketing communications, your email address is retained on a suppression list to ensure you do not receive future marketing messages.
• Technical data: Server logs and anonymized usage data may be retained for up to 12 months for security and performance analysis.

11. Your Data Rights

Under applicable data protection laws, you have the following rights regarding your Personal Data:

11.1 Right of Access

You have the right to request a copy of all Personal Data koitot holds about you. We will provide this information in a structured, commonly used, and machine-readable format within 30 days of your request.

11.2 Right of Rectification

If any of your Personal Data is inaccurate or incomplete, you have the right to request correction. You can update most information directly through your account settings, or contact our support team for assistance.

11.3 Right of Erasure

You have the right to request deletion of your Personal Data, subject to certain legal exceptions. We may be required to retain data for regulatory compliance (e.g., financial transaction records) even after account closure.

11.4 Right to Restrict Processing

You may request that we limit how we use your Personal Data in certain circumstances, such as while we verify the accuracy of data you have disputed.

11.5 Right to Data Portability

You have the right to receive your Personal Data in a portable format and to transmit it to another service provider where technically feasible.

11.6 Right to Object

You have the right to object to Processing of your Personal Data based on legitimate interests or for marketing purposes. You can opt out of marketing communications at any time.

11.7 Right to Withdraw Consent

Where Processing is based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of Processing conducted prior to withdrawal.

11.8 Exercising Your Rights

To exercise any of these rights, please contact our support team at [email protected] (plain text, not clickable). We will respond to all requests within 30 days. Proof of identity may be required before we can process your request.

12. International Data Transfers

koitot primarily serves players in Indonesia. However, some of our service providers and data processing infrastructure may be located outside Indonesia. When we transfer Personal Data internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by data protection authorities.
• Ensuring the recipient country provides an adequate level of data protection.
• Obtaining your explicit consent where required by law.

13. Children's Privacy (21+ Only)

The koitot platform is strictly for adults aged 21 years and over. We do not knowingly collect Personal Data from individuals under 21. If we become aware that a person under 21 has provided Personal Data, we will take immediate steps to delete that information and close the associated account. If you believe a minor has registered on our platform, please contact us immediately.

14. Changes to This Privacy Policy

koitot reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other operational factors. We will notify you of material changes by email or through a prominent notice on the platform at least 14 days before the changes take effect. Your continued use of the platform after the effective date constitutes acceptance of the revised policy.

We encourage you to review this Privacy Policy periodically. The "Last updated" date at the top of this document indicates when the policy was most recently revised.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how koitot handles your Personal Data, please contact us:

Email: [email protected] (plain text — not a clickable link)

Support Hours: 24/7 (Indonesian and English-speaking agents available)

We aim to respond to all privacy-related inquiries within 48 hours (WIB, UTC+7). For urgent data protection concerns, please mark your inquiry as "Privacy Request" in the subject line to ensure expedited handling.