Privacy Policy

1. Introduction

actoto ("we," "us," "our") operates an online betting platform at actoto.cam (the "Platform") that provides sports betting, live casino games, slot machines, online togel (Indonesia's traditional numbers lottery), and related entertainment services to Users located in Indonesia. This Privacy Policy governs the collection, use, storage, and disclosure of personal information obtained through your use of the Platform.

actoto is committed to protecting your privacy and ensuring that your personal data is handled in accordance with international best practices for data protection. We recognize that privacy is a fundamental right, and we have designed our data practices to be transparent, secure, and respectful of User autonomy. This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the Platform.

By registering an Account, depositing funds, placing bets, or otherwise using actoto's services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not consent to these practices, you must not use the Platform.

2. Information We Collect

actoto collects several categories of personal information to provide, maintain, and improve our services. The types of data we collect include:

2.1 Account Registration Data

When you create an actoto Account, we collect the following information:

• Personal Identification Information: Full legal name, date of birth, gender, nationality, residential address in Indonesia.
• Contact Information: Email address, mobile phone number.
• Account Credentials: Username, password (stored in hashed form), security questions and answers.

2.2 Know Your Customer (KYC) Verification Data

To comply with anti-money laundering (AML) regulations and verify your identity before processing withdrawals, we collect:

• Government-Issued Identification: Indonesian KTP (national identity card), passport, or driver's license — including document number, issue date, expiry date, and a copy of the document itself.
• Proof of Address: Utility bill, bank statement, or government correspondence dated within the last 90 days showing your name and residential address.
• Payment Method Verification: Bank account statement or e-wallet screenshot showing your name, account number, and financial institution name.
• Selfie Verification: A photograph of you holding your ID document to verify that the person in the ID matches the Account holder.

2.3 Financial Transaction Data

When you deposit funds into or withdraw funds from your actoto Account, we collect:

• Deposit Information: Payment method used (bank name, e-wallet provider), transaction amount in IDR, transaction timestamp, transaction reference number.
• Withdrawal Information: Destination payment method, withdrawal amount, processing status, completion timestamp.
• Transaction History: A complete record of all deposits, withdrawals, bets placed, winnings, losses, bonuses claimed, and bonus wagering progress.

Important: actoto does not store full credit card numbers, CVV codes, or bank account passwords. Payment processing is handled by certified third-party payment processors who maintain PCI-DSS compliance.

2.4 Gameplay and Betting Data

To operate the Platform and ensure fair play, we collect:

• Betting Activity: Sports bets placed (event, market, odds, stake, outcome), casino game sessions (game played, bet size, win/loss results, session duration), slot spins (game title, spin results, RTP data).
• Bonus Activity: Bonuses claimed, wagering progress toward bonus requirements, games played while bonus is active, bonus expiry dates.
• Responsible Gaming Data: Deposit limits set, loss limits set, session time limits, self-exclusion requests, reality-check acknowledgments.

2.5 Technical and Device Data

When you access actoto, we automatically collect certain technical information:

• Device Information: Device type (mobile, tablet, desktop), operating system (Android, iOS, Windows, macOS), browser type and version, screen resolution.
• Network Information: IP address, ISP (internet service provider), approximate geographic location (city/region level, not precise GPS coordinates).
• Usage Data: Pages visited, time spent on each page, clickstream data, referral source (how you arrived at actoto.cam), session duration.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, local storage data, device fingerprints. See Section 9 for detailed information on cookies.

2.6 Communications Data

When you contact actoto's customer support team via live chat, email, or other communication channels, we collect:

• Support Inquiries: The content of your messages, timestamps, support ticket history, resolution outcomes.
• Marketing Communications: If you opt in to receive promotional emails or SMS messages, we track open rates, click-through rates, and unsubscribe requests.

3. How We Collect Your Information

actoto collects personal data through the following methods:

3.1 Information You Provide Directly

Most personal data is provided voluntarily by you when you:

• Register for an actoto Account and fill out the registration form.
• Complete the KYC verification process by uploading identity documents.
• Make deposits or request withdrawals through the cashier interface.
• Contact customer support with questions or issues.
• Adjust responsible gaming limits or request self-exclusion.

3.2 Information Collected Automatically

Technical and usage data is collected automatically through:

• Cookies and Tracking Technologies: Small data files stored on your device that track session information, preferences, and usage patterns.
• Server Logs: actoto's web servers automatically log IP addresses, browser types, timestamps, and pages accessed.
• Analytics Tools: We use analytics platforms to measure traffic, user engagement, and conversion rates.

3.3 Information from Third Parties

In limited cases, actoto receives information from third-party sources:

• Payment Processors: Confirmation of successful deposits and withdrawals, transaction reference numbers, payment method details.
• Game Providers: Gameplay data, RTP statistics, jackpot winners (for games provided by Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, and other third-party studios).
• Fraud Prevention Services: Device fingerprints, IP reputation scores, and fraud risk assessments from specialized anti-fraud vendors.

4. How We Use Your Information

actoto uses your personal data for the following purposes:

4.1 Account Management and Service Delivery

• Creating and maintaining your actoto Account.
• Processing deposits, withdrawals, and financial transactions.
• Enabling you to place bets on sports markets, play casino games, and participate in online togel draws.
• Applying bonuses, tracking wagering requirements, and crediting winnings to your Account balance.
• Providing customer support and resolving technical issues.

4.2 Identity Verification and Fraud Prevention

• Verifying your identity through KYC procedures before processing withdrawals.
• Detecting and preventing fraudulent activity, multi-accounting, bonus abuse, and money laundering.
• Monitoring betting patterns for signs of match-fixing, collusion, or other forms of cheating.
• Complying with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.

4.3 Legal and Regulatory Compliance

• Maintaining records required by our international gaming license.
• Responding to lawful requests from government authorities, regulators, or law enforcement.
• Enforcing our Terms & Conditions and investigating suspected violations.

4.4 Platform Improvement and Analytics

• Analyzing usage patterns to improve website performance, user experience, and mobile optimization.
• Conducting A/B testing on new features, interface designs, and promotional offers.
• Identifying popular games, markets, and features to guide content expansion.

4.5 Marketing and Promotions (With Your Consent)

• Sending promotional emails, SMS messages, or push notifications about new bonuses, special offers, and platform updates (only if you have opted in).
• Personalizing marketing content based on your gameplay history and preferences.
• Conducting customer satisfaction surveys to gather feedback.

Opt-Out: You may unsubscribe from marketing communications at any time by clicking the unsubscribe link in emails, replying "STOP" to SMS messages, or adjusting your preferences in your Account settings.

4.6 Responsible Gaming and Player Protection

• Enforcing deposit limits, loss limits, and session time limits you have set.
• Monitoring gameplay for signs of problem gambling and reaching out with responsible gaming resources if concerning patterns are detected.
• Processing self-exclusion requests and preventing access during exclusion periods.

5. Data Sharing and Disclosure

actoto does not sell, rent, or trade your personal data to third parties for marketing purposes. However, we may share your information in the following limited circumstances:

5.1 Service Providers and Business Partners

We share personal data with trusted third-party service providers who assist in operating the Platform:

• Payment Processors: To process deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Game Providers: To deliver slot games, live dealer tables, and other content (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, etc.).
• KYC Verification Services: To verify identity documents and conduct anti-fraud checks.
• Cloud Hosting Providers: To store data on secure servers.
• Analytics and Marketing Platforms: To measure traffic, track conversions, and deliver targeted promotions (only if you have consented).

All service providers are contractually obligated to handle your data securely and use it only for the specific purposes we authorize. They are prohibited from using your data for their own purposes.

5.2 Legal and Regulatory Authorities

We may disclose personal data to government authorities, regulators, or law enforcement if:

• Required by law or legal process (court order, subpoena, regulatory directive).
• Necessary to comply with our international gaming license obligations.
• Needed to investigate suspected fraud, money laundering, or other illegal activity.
• Required to protect the rights, property, or safety of actoto, our Users, or the public.

5.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer, and the new entity will be bound by this Privacy Policy (or a successor policy with equivalent protections).

5.4 With Your Consent

We may share your data with third parties for purposes not described in this Policy if we obtain your explicit consent at the time of sharing.

6. Data Security Measures

actoto employs industry-standard security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL Encryption: All data transmitted between your device and actoto's servers is encrypted using Transport Layer Security (TLS).
• Secure Data Centers: Personal data is stored on secure servers in facilities with physical access controls, fire suppression systems, and 24/7 monitoring.
• Access Controls: Only authorized actoto personnel with a legitimate business need can access personal data. All access is logged and audited.
• Password Hashing: User passwords are hashed using bcrypt or a similar one-way cryptographic algorithm. actoto does not store plaintext passwords.
• Two-Factor Authentication (2FA): Users are encouraged to enable 2FA on their Accounts for an additional layer of security.
• Regular Security Audits: actoto conducts periodic security assessments and vulnerability scans to identify and remediate potential weaknesses.
• DDoS Protection: Our infrastructure is protected against distributed denial-of-service attacks and other malicious traffic.

7. Data Retention

actoto retains personal data for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with legal obligations:

• Active Accounts: Personal data associated with active Accounts is retained for the duration of your membership and for a period of time thereafter as required by our gaming license (typically 5-7 years from the date of Account closure).
• Transaction Records: Financial transaction data (deposits, withdrawals, bets, winnings) is retained for at least 7 years to comply with AML regulations and tax reporting obligations.
• KYC Documents: Identity verification documents are retained for at least 5 years after Account closure as required by regulatory authorities.
• Marketing Data: If you unsubscribe from marketing communications, we will retain your contact information on a suppression list to ensure we do not contact you again, but we will delete other marketing-related data.
• Support Communications: Customer support chat logs and email correspondence are retained for 3 years for quality assurance and dispute resolution purposes.

After the applicable retention period expires, personal data is securely deleted or anonymized so that it can no longer be associated with you. Anonymized data may be retained indefinitely for statistical and analytical purposes.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request that we correct inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): You may request that we delete your personal data, subject to legal retention requirements and legitimate business interests.
• Right to Restriction of Processing: You may request that we limit how we use your data in certain circumstances.
• Right to Data Portability: You may request a machine-readable copy of your personal data for transfer to another service provider.
• Right to Object: You may object to our processing of your data for direct marketing purposes or based on legitimate interests.
• Right to Withdraw Consent: If we process your data based on consent, you may withdraw that consent at any time (though this does not affect the lawfulness of processing before withdrawal).

To exercise any of these rights, please contact actoto's customer support team at [email protected] (plain text). We will respond to your request within 30 days and may require identity verification before processing your request. Please note that certain data may be exempt from these rights due to legal obligations (e.g., transaction records required for AML compliance cannot be deleted during the retention period).

9. Cookies and Tracking Technologies

actoto uses cookies and similar technologies to enhance user experience, analyze traffic, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize you on return visits.

9.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function (e.g., maintaining your login session, remembering items in your bet slip). These cannot be disabled.
• Performance Cookies: Collect anonymous usage data to help us improve website speed and user experience.
• Functionality Cookies: Remember your preferences (e.g., language selection, timezone, display settings).
• Marketing Cookies: Track your visits across websites to deliver targeted advertisements (only if you have consented).

9.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block cookies, delete existing cookies, or receive warnings before cookies are stored. However, disabling essential cookies will impair Platform functionality (you may not be able to log in or place bets). For more information on managing cookies, consult your browser's help documentation.

10. Third-Party Links and Services

actoto may contain links to third-party websites (e.g., game provider websites, payment processor sites, social media platforms). These third-party sites have their own privacy policies, and actoto is not responsible for their data practices. We encourage you to review the privacy policy of any third-party site you visit. This Privacy Policy applies only to information collected by actoto through actoto.cam and our official mobile applications.

11. Minors and Age Verification

actoto is an adults-only platform. You must be at least 21 years of age to create an Account or use our services. We do not knowingly collect personal data from individuals under 21 years of age. If we become aware that a User is underage, we will immediately suspend the Account, void all bets and bonuses, and delete the associated personal data. If you are a parent or guardian and believe your child has provided personal information to actoto, please contact us immediately at [email protected] (plain text) so we can take appropriate action.

12. Changes to This Privacy Policy

actoto reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. When we make material changes, we will notify you by:

• Posting a prominent notice on the actoto homepage.
• Sending an email to the address associated with your Account.
• Displaying a notification when you next log in to the Platform.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of actoto after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated Policy, you must discontinue use of the Platform and may request Account closure.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how actoto handles your personal data, please contact us:

• Email: [email protected] (plain text, not a clickable link)
• Live Chat: Available 24/7 through the actoto Platform
• Privacy Inquiries: For specific data subject requests (access, deletion, correction), please use the subject line "Privacy Request" in your email and include your Account username and registered email address for verification purposes.

We aim to respond to all privacy inquiries within 30 days. For urgent security matters (suspected unauthorized Account access, data breach concerns), please contact us immediately via live chat for expedited assistance.