Privacy Policy

This Privacy Policy ("Policy") describes how netoto ("we", "us", or "our"), the operator of the online betting platform accessible at https://netoto.cam, collects, uses, stores, shares, and protects the personal data of individuals ("you" or "your") who access or use our Platform, register a player account, or otherwise engage with our services.

netoto is committed to handling your personal data with the highest standards of care, transparency, and security. This Policy is written to be clear and accessible — not buried in impenetrable legal language — so that you can make fully informed decisions about your personal data at every stage of your relationship with us.

By accessing the Platform, creating an Account, or using any of our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately. This Policy should be read alongside our Terms & Conditions, which govern the overall legal relationship between you and netoto.

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, residential address, payment details, device identifiers, and IP addresses.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means netoto, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of netoto, under a contractual obligation and in accordance with our instructions.
• "Consent" means any freely given, specific, informed, and unambiguous indication of your wishes by which you agree to the processing of your Personal Data.
• "Account" means the personal member account you hold with netoto upon successful registration.
• "Platform" refers to the netoto website, mobile-optimized version, and any associated application or interface through which our services are accessible.
• "Cookies" means small text files placed on your device by the Platform to enable functionality, analytics, and personalization.

netoto collects Personal Data in the following categories, depending on how you interact with the Platform:

We do not collect any special categories of sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information) unless strictly required by applicable law or regulatory obligation, in which case we will seek your explicit consent.

netoto collects your Personal Data through the following channels:

• Direct submission: Data you actively provide when completing your registration form, updating your Account profile, submitting KYC documents, making deposit or withdrawal requests, completing responsible gaming questionnaires, or contacting our customer support team.
• Automated technologies: Data collected automatically when you access the Platform, including via cookies, web beacons, pixel tags, server logs, and similar tracking technologies. This includes your IP address, device fingerprint, browser type, and session behavior data.
• Payment processors: Transaction confirmation data shared with us by our payment processing partners when you complete a deposit or withdrawal via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, or LinkAja.
• Identity verification providers: Data received from third-party KYC and age verification services engaged by netoto to validate the authenticity of documents you submit.
• Fraud prevention services: Risk signals and fraud indicators shared by specialist anti-fraud data providers to help us protect the integrity of the Platform and the safety of all Players.
• Publicly available sources: Information available from public registers, sanctions lists, PEP (Politically Exposed Persons) databases, and adverse media sources used to fulfill our regulatory compliance obligations.

netoto processes your Personal Data for the following clearly defined purposes:

1. Account creation and management: To register your Account, verify your identity, maintain your profile, process login requests, and manage your Account settings and preferences throughout your relationship with netoto.
2. Service delivery: To enable you to place bets on sports markets (including BRI Liga 1, EPL, La Liga, Champions League, and international tournaments), play casino games, participate in togel (Indonesia's traditional numbers lottery) draws, and access all other services available on the Platform.
3. Payment processing: To process deposits and withdrawals via your nominated local bank account or e-wallet, and to maintain a complete and accurate record of all financial transactions on your Account.
4. KYC and age verification: To verify that you are at least 21 years of age and to confirm your identity in compliance with our anti-money laundering (AML) and Know Your Customer (KYC) obligations.
5. Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized Account access, money laundering, collusion, and any other conduct that breaches our Terms & Conditions or applicable law.
6. Regulatory compliance: To fulfill our legal and regulatory obligations, including record-keeping requirements, reporting obligations, and responses to lawful requests from competent authorities.
7. Customer support: To respond to your inquiries, resolve disputes, handle complaints, and provide technical assistance. All support communications are conducted in English and Bahasa Indonesia by our 24/7 team.
8. Responsible gaming: To monitor your gaming activity for indicators of problem gambling behavior, administer player-protection tools (deposit limits, self-exclusion, cooling-off periods), and fulfill our duty of care obligations under responsible gaming standards.
9. Personalization: To tailor your experience on the Platform, including presenting relevant promotions, personalized game recommendations, and localized content based on your preferences and gaming history.
10. Marketing communications: To send you promotional emails, bonus notifications, and platform updates where you have provided consent to receive such communications. You may opt out at any time by contacting our support team.
11. Analytics and improvement: To analyze aggregated usage data, identify technical issues, measure Platform performance, and continuously improve the quality and reliability of our services.

For each processing activity, netoto relies on at least one of the following lawful bases:

• Contractual necessity: Processing required to perform the contract between you and netoto — including Account registration, service delivery, payment processing, and customer support — is conducted on the basis that it is necessary to fulfill our contractual obligations to you.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML/KYC requirements, tax reporting obligations, and responses to lawful requests from regulatory or law enforcement authorities.
• Legitimate interests: Processing conducted for purposes such as fraud prevention, Platform security, responsible gaming monitoring, analytics, and service improvement, where those interests are not overridden by your fundamental rights and freedoms. We conduct a balancing test before relying on this basis.
• Consent: Processing for direct marketing communications and the use of non-essential cookies, where we rely on your freely given and specific consent. You may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

netoto does not sell, rent, or trade your Personal Data to any third party for their own marketing purposes. We may, however, share your data with the following categories of recipients where necessary and lawful:

• Payment processors and financial institutions: Your banking and transaction data is shared with our approved payment partners — including local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) — strictly for the purpose of processing your financial transactions.
• KYC and identity verification providers: Document and identity data is shared with specialist third-party verification services to confirm your age and identity as required by our compliance framework.
• Game content providers: Certain usage data (such as game session identifiers and bet histories) may be shared with our licensed game studio partners — including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft — solely to facilitate game delivery and resolve technical disputes.
• Fraud prevention and security services: Technical and behavioral data may be shared with specialist fraud prevention providers to help identify and mitigate fraudulent activity across the Platform.
• Regulatory and law enforcement authorities: We are required by law to disclose certain data to competent regulatory bodies, tax authorities, financial intelligence units, or law enforcement agencies upon receipt of a lawful request. We will not notify you of such disclosures where prohibited by law from doing so.
• Professional advisors: Our lawyers, auditors, accountants, and insurers may access your data on a strictly confidential, need-to-know basis in the course of providing professional services to netoto.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of netoto's business, your Personal Data may be transferred to the successor entity. We will notify you of any such transfer and the privacy policy applicable thereafter.

All third parties with whom we share your Personal Data are required to maintain its confidentiality and to process it only in accordance with our instructions and applicable data protection law.

The netoto Platform uses cookies and similar tracking technologies to enhance your browsing experience, maintain your session, deliver personalized content, and gather analytics data. The types of cookies we use are:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session authentication cookies that keep you logged in, language preference cookies, and security tokens. These cookies cannot be disabled without severely impairing the Platform's functionality.
• Functional cookies: Used to remember your preferences — such as your preferred payment method, display settings, and notification preferences — so that you do not need to re-enter them each time you visit.
• Analytics cookies: Used to collect anonymized information about how Players interact with the Platform — including which pages are visited most frequently, session durations, and navigation paths — to help us understand and improve Platform performance.
• Marketing and personalization cookies: Used, with your consent, to build a profile of your gaming interests and present you with promotions and game recommendations that are relevant to your preferences. These cookies may track your activity across sessions.

You may manage your cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies will affect your ability to use core Platform features, including logging into your Account.

netoto retains your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Our general retention periods are as follows:

• Account and identity data: Retained for the duration of your active Account relationship with netoto, plus a minimum of 5 years following Account closure, to comply with AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction, in accordance with financial crime prevention and tax reporting obligations.
• KYC documents: Retained for a minimum of 5 years following the completion of the verification process, or longer if required by applicable law or ongoing investigations.
• Customer support communications: Retained for 2 years from the date of the last communication, unless the matter remains subject to an ongoing dispute or legal proceeding.
• Analytics and usage data: Retained in aggregated, anonymized form indefinitely for Platform improvement purposes; identifiable usage logs are deleted within 12 months of collection.
• Marketing consent records: Retained for the duration of your consent plus 1 year, to provide evidence of compliance with applicable marketing regulations.

When data is no longer required, it is securely deleted or anonymized in accordance with our internal data destruction procedures. Physical documents are shredded; digital records are overwritten using industry-standard secure deletion protocols.

netoto implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, or disclosure. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers, ensuring that your login credentials, payment details, and personal information cannot be intercepted in transit.
• Encrypted data storage — all sensitive data stored on our servers is encrypted at rest using AES-256 encryption, ensuring that even in the event of a physical server breach, data remains unreadable without the decryption key.
• Strict access controls — access to Personal Data within netoto is restricted on a role-based, need-to-know basis. Only authorized personnel with a legitimate operational requirement may access player data, and all access is logged and audited.
• Multi-factor authentication (MFA) available on all Player Accounts and mandatory for all internal systems accessed by netoto staff.
• Continuous intrusion detection — our systems are monitored 24/7 for unusual access patterns, potential breaches, and unauthorized data access attempts.
• Regular penetration testing and security audits conducted by independent specialist security firms to identify and remediate vulnerabilities before they can be exploited.
• Segregated player fund accounts — your deposited funds are held separately from netoto's operational accounts, protecting them in the event of any financial difficulty affecting the business.

Despite these measures, no system is entirely immune to security threats. If you suspect that your Account has been compromised, please contact our support team immediately at [email protected]. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, netoto will notify you without undue delay and in accordance with applicable notification obligations.

Subject to applicable law and certain conditions, you hold the following rights in relation to your Personal Data held by netoto:

• Right of access: You have the right to request a copy of all Personal Data we hold about you, together with information about how it is being processed.
• Right to rectification: You have the right to request that inaccurate or incomplete Personal Data be corrected or updated without undue delay.
• Right to erasure ("right to be forgotten"): You have the right to request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (if consent was the basis), or where processing is unlawful. This right is subject to overriding legal retention obligations.
• Right to restrict processing: You have the right to request that we limit our processing of your data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to data portability: You have the right to receive your Personal Data in a structured, commonly used, machine-readable format and to have it transmitted to another controller where technically feasible.
• Right to object: You have the right to object to processing based on our legitimate interests, including profiling, at any time. You also have an absolute right to object to processing for direct marketing purposes.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please submit a written request to [email protected]. We will respond to all valid requests within 30 days. We may ask you to verify your identity before processing any data rights request to ensure that data is not disclosed to unauthorized parties.

The netoto Platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect, process, or store the Personal Data of any person under the age of 21. Age verification is conducted as part of our mandatory KYC process, and any Account found to belong to a person under 21 will be immediately suspended and all associated data flagged for review.

If you are a parent or guardian and believe that a minor under your care has accessed the Platform or provided Personal Data to netoto, please contact us immediately at [email protected]. Upon verification of the report, we will take all necessary steps to delete the minor's data and close the Account without delay.

netoto operates on a globally distributed infrastructure and may transfer your Personal Data to servers, processors, or affiliated entities located outside of Indonesia. Where such transfers occur, we ensure that your data continues to receive an equivalent level of protection by implementing one or more of the following safeguards:

• Contractual clauses that impose data protection obligations equivalent to applicable international standards on all recipient parties.
• Transfer only to jurisdictions that have been recognized as providing an adequate level of data protection by competent international standards bodies.
• Binding corporate rules or other approved transfer mechanisms where transfers are made to entities within the netoto corporate group.

If you would like further information about the specific safeguards applied to any international transfer of your Personal Data, please contact us at [email protected].

netoto reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services we offer. The date of the most recent revision is displayed prominently at the top of this page.

Where changes are material — meaning they could significantly affect your rights or the way we use your Personal Data — we will notify you by email to your registered address and/or by 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 of any revision constitutes your acceptance of the updated Policy.

We encourage you to review this Policy periodically to stay informed about how netoto protects your personal information. Archived versions of previous policy revisions are available upon request by contacting our support team.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way netoto handles your Personal Data, please reach out to our dedicated privacy support team through any of the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly through the Platform dashboard
• Response Time: Email responses within 24 hours; live chat responses within 30 seconds
• Languages: English and Indonesian (Bahasa Indonesia) — native-speaking agents available around the clock
• Support Hours: 24 hours a day, 7 days a week, including Idul Fitri, Nyepi, and all Indonesian national holidays

When submitting a data rights request or privacy inquiry by email, please include your registered Account email address, a clear description of your request, and any relevant reference information. We may ask you to verify your identity before processing the request to ensure your data is protected.

Our support team is distributed across WIB (UTC+7), WITA (UTC+8), and WIT (UTC+9) time zones, ensuring that players across the entire Indonesian archipelago — from Sabang to Merauke — receive timely and knowledgeable assistance with any privacy-related matter.