Privacy Policy

1. Introduction

This Privacy Policy governs the collection, use, storage, and disclosure of personal information by titi99 (referred to as "we," "us," or "our") in connection with the online gaming services provided through our website at https://titi99.cam. By creating an account, depositing funds, or using any titi99 services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

We are committed to handling your personal information in accordance with applicable Indonesian data protection laws and international best practices. This policy applies to all users of titi99 services, including players, visitors, and anyone who interacts with our platform.

2. Information We Collect

2.1 Personal Information You Provide

When you register an account with titi99, we collect the following personal information directly from you:

• Identity Information: Full legal name as it appears on your Indonesian National Identity Card (KTP), date of birth, gender, nationality, and KTP number.
• Contact Information: Email address, mobile phone number, residential address including city and postal code.
• Account Credentials: Username, password (stored in encrypted form), and security questions for account recovery.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet information (OVO, DANA, GoPay account identifiers), and transaction history including deposits, withdrawals, bets placed, and winnings.
• Verification Documents: Clear copies or photos of your KTP, selfie photographs holding your KTP for identity verification, proof of address documents such as utility bills or bank statements, and any additional documentation required for enhanced due diligence or compliance purposes.

2.2 Information We Collect Automatically

When you access and use titi99 services, we automatically collect certain technical and usage information:

• Device Information: Device type (desktop, mobile phone, tablet), operating system and version, browser type and version, screen resolution, and device identifiers.
• Connection Information: IP address, internet service provider, geographic location (city and region inferred from IP address), and connection timestamps.
• Usage Data: Pages visited on our website, games played, bets placed (amounts, types, outcomes), session duration, click patterns, feature usage, and interaction with customer support.
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to recognize your device, remember your preferences, and analyze site traffic. See Section 8 for detailed information about cookies.

2.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment processors and banks when you make deposits or withdrawals.
• Identity verification services that help us confirm your age and identity.
• Fraud prevention services that screen transactions for suspicious activity.
• Marketing partners (only if you have provided consent to those partners to share your information).

3. How We Use Your Information

3.1 Primary Purposes

titi99 uses your personal information for the following purposes:

• Account Management: Creating and maintaining your player account, authenticating your identity when you log in, and providing customer support.
• Service Provision: Processing your deposits and withdrawals, enabling you to place bets and play games, calculating winnings and losses, and maintaining accurate transaction records.
• Legal Compliance: Verifying that you are at least 21 years of age and legally eligible to gamble under Indonesian law, conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks, preventing fraud, money laundering, and other illegal activities, and complying with legal obligations including reporting requirements to regulatory authorities.
• Security and Fraud Prevention: Protecting your account from unauthorized access, detecting and preventing cheating, collusion, and bonus abuse, monitoring for suspicious betting patterns or account activity, and investigating violations of our Terms & Conditions.
• Platform Improvement: Analyzing usage patterns to improve our website design and user experience, developing new features and gaming products, optimizing platform performance and reliability, and conducting market research and statistical analysis.
• Marketing and Communications: Sending you promotional offers, bonuses, and tournament invitations (only if you have opted in to marketing communications), notifying you of important account updates, policy changes, and service announcements, and providing customer support through live chat, email, and WhatsApp.
• Responsible Gaming: Monitoring your gaming behavior to identify signs of problem gambling, implementing deposit limits, session time limits, and self-exclusion requests, and providing access to responsible gaming tools and resources.

3.2 Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (providing gaming services as outlined in our Terms & Conditions).
• Legal Obligation: Processing is required to comply with Indonesian laws and regulations governing online gambling, age verification, AML, and consumer protection.
• Legitimate Interests: Processing serves our legitimate business interests in preventing fraud, improving our services, and ensuring platform security, provided these interests do not override your privacy rights.
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

4. How We Share Your Information

4.1 Third-Party Service Providers

titi99 may share your personal information with trusted third-party service providers who assist us in operating our platform and delivering our services. These include:

• Payment Processors: Banks, e-wallet providers, and payment gateways that process your deposits and withdrawals. These providers receive only the financial information necessary to complete transactions.
• Identity Verification Services: Third-party services that verify your age, identity, and address against official databases to comply with KYC requirements.
• Cloud Hosting Providers: Secure data centers where our servers and databases are hosted. We use providers with ISO 27001 certification and strict security protocols.
• Customer Support Tools: Live chat platforms, ticketing systems, and CRM software that enable our support team to assist you efficiently.
• Analytics and Advertising Partners: Services that help us understand user behavior, measure marketing campaign effectiveness, and deliver targeted advertisements (only with your consent).

All third-party service providers are contractually bound to maintain the confidentiality and security of your information and may only use it for the specific purposes we authorize.

4.2 Legal and Regulatory Disclosure

We may disclose your personal information to government authorities, law enforcement agencies, or regulatory bodies when:

• Required by Indonesian law, court order, or legal process.
• Necessary to investigate suspected fraud, money laundering, or other illegal activities.
• Needed to protect the rights, property, or safety of titi99, our users, or the public.
• Requested by gaming regulators as part of licensing compliance or investigations.

4.3 Business Transfers

In the event that titi99 is involved in a merger, acquisition, sale of assets, or bankruptcy proceeding, your personal information may be transferred to the successor entity. We will notify you via email and website notice before your information is transferred and becomes subject to a different privacy policy.

4.4 Information We Do Not Share

titi99 will never sell, rent, or trade your personal information to third parties for their marketing purposes. We do not share your gaming history, betting patterns, or financial details with advertisers or data brokers.

5. Data Security

titi99 takes data security extremely seriously and implements multiple layers of protection to safeguard your personal information:

• Encryption: All data transmitted between your device and our servers is protected using 256-bit SSL (Secure Socket Layer) encryption, the same standard used by banks. Passwords are stored using industry-standard cryptographic hashing algorithms and are never stored in plain text.
• Secure Servers: Our servers are housed in certified data centers with 24/7 physical security, fire suppression systems, redundant power supplies, and restricted access controls. We use firewalls, intrusion detection systems, and regular security audits to protect against unauthorized access.
• Access Controls: Employee access to personal information is strictly limited to those who need it to perform their job duties. All employees with data access undergo background checks and sign confidentiality agreements.
• Regular Monitoring: We continuously monitor our systems for suspicious activity, conduct penetration testing, and apply security patches promptly to address vulnerabilities.
• Fraud Prevention: Advanced fraud detection algorithms analyze transaction patterns to identify and prevent unauthorized access, account takeovers, and fraudulent transactions.

6. Data Retention

titi99 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal obligations:

• Active Accounts: While your account remains active, we retain your account information, gaming history, and transaction records to provide services and support.
• Closed Accounts: After account closure, we retain certain information for up to seven years to comply with Indonesian financial record-keeping requirements, tax laws, and AML regulations.
• Marketing Data: If you opt out of marketing communications, we retain your email address on a suppression list to ensure we do not contact you in the future.
• Legal Holds: If your information is subject to a legal investigation, dispute, or regulatory inquiry, we retain it until the matter is resolved.

After the retention period expires, we securely delete or anonymize your personal information so that it can no longer be used to identify you.

7. Your Privacy Rights

Under Indonesian data protection laws, you have the following rights regarding your personal information:

• Right to Access: You may request a copy of the personal information we hold about you, including your account details, transaction history, and verification documents.
• Right to Correction: If any information we hold about you is inaccurate or incomplete, you may request that we correct or update it.
• Right to Deletion: You may request deletion of your personal information, subject to our legal obligations to retain certain records for compliance purposes.
• Right to Object: You may object to processing of your information for direct marketing purposes at any time. You may also object to processing based on legitimate interests if you have compelling grounds.
• Right to Data Portability: You may request that we provide your personal information in a structured, commonly used, and machine-readable format for transfer to another service provider.
• Right to Withdraw Consent: Where processing is based on your consent (such as marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

To exercise any of these rights, please contact our customer support team at [email protected] (please manually type this address into your email client). We will respond to your request within 30 days and may ask you to verify your identity before processing your request to protect your information from unauthorized access.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. They help us recognize your device, remember your preferences, and improve your user experience.

8.2 Types of Cookies We Use

• Essential Cookies: Required for the website to function properly, including authentication, security features, and basic navigation. These cannot be disabled.
• Preference Cookies: Remember your settings such as language preference, currency display, and display options.
• Analytics Cookies: Help us understand how visitors use our site by collecting anonymous statistics on page views, bounce rates, and traffic sources.
• Marketing Cookies: Track your browsing activity to deliver relevant advertisements and measure campaign effectiveness. These require your consent.

8.3 Managing Cookies

You can control cookie settings through your browser preferences. However, disabling essential cookies may affect your ability to use certain features of our platform. Most browsers allow you to refuse cookies, delete existing cookies, or receive notification before cookies are stored.

9. International Data Transfers

titi99 primarily operates within Indonesia and stores player data on servers located within Indonesian jurisdiction. However, some of our third-party service providers (such as cloud hosting, payment processors, and analytics tools) may be located outside Indonesia. When we transfer your information internationally, we ensure appropriate safeguards are in place including:

• Using service providers that comply with international data protection standards such as ISO 27001 or SOC 2.
• Implementing contractual data protection clauses that require providers to protect your information at the same level as Indonesian law requires.
• Encrypting data in transit and at rest to prevent unauthorized access during transfer.

10. Children's Privacy

titi99 services are intended exclusively for adults aged 21 years and older, which is the legal gambling age in Indonesia. We do not knowingly collect personal information from individuals under 21. If we become aware that we have inadvertently collected information from someone under 21, we will immediately delete that information and close the associated account. Parents or guardians who believe their child has provided us with personal information should contact us immediately.

11. Changes to This Privacy Policy

titi99 reserves the right to update this Privacy Policy to reflect changes in our practices, legal requirements, or technological developments. We will notify you of material changes through email, account notification, or prominent notice on our website at least 30 days before the changes take effect. Your continued use of titi99 services after the effective date constitutes acceptance of the revised policy. We recommend reviewing this Privacy Policy periodically to stay informed about how we protect your information. The "Last Updated" date at the top of this page indicates when the most recent changes were made.

12. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data handling practices, please contact us:

• Email: [email protected] (displayed as plain text; please manually type this address into your email client)
• Live Chat: Available 24/7 through the titi99 website
• WhatsApp: Available 24/7 (contact details provided in your account dashboard)

We aim to respond to all privacy inquiries within five business days. If you are not satisfied with our response, you have the right to lodge a complaint with the Indonesian Data Protection Authority (if applicable) or seek legal remedies through Indonesian courts.