Privacy Policy

1. Definitions

Throughout this Privacy Policy, the following terms have the meanings assigned below:

• "pptoto", "we", "us", or "our" refers to the pptoto platform and its operating entity.
• "User", "you", or "your" refers to any person who visits, registers for, or uses the pptoto website or associated services.
• "Personal Data" means any information that identifies or can reasonably identify you as a natural person, including your name, email address, phone number, national identification number, bank account details, and IP address.
• "Processing" means any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, and deletion.
• "Third Party" means any person or entity other than you and pptoto.
• "KYC" (Know Your Customer) refers to the identity verification process required by our compliance obligations before processing withdrawals.
• "Cookies" means small text files stored on your device by your web browser at the request of a website to enable certain functionality.

2. Scope and Application

This Privacy Policy applies to all Personal Data collected by pptoto through the pptoto website at https://pptoto.cam, any pptoto mobile application, and any interactions with our customer support team via email or live chat.

This Policy is intended for users located primarily in Indonesia. By registering an account or using the pptoto platform, you confirm that you have read and understood this Privacy Policy and consent to the collection and processing of your Personal Data as described herein.

3. Information We Collect

3.1 Information You Provide Directly

When you register for an account, make a deposit, request a withdrawal, or contact our support team, pptoto may collect the following categories of Personal Data:

• Identity Data: Full legal name, date of birth, gender, nationality, and Indonesian National Identity Card (KTP) number or passport number.
• Contact Data: Email address, mobile phone number, and city of residence (e.g., Jakarta, Surabaya, Bandung, Medan, Bali).
• Financial Data: Bank account number, account holder name, and e-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja). We do not store full payment card numbers.
• Verification Data: Photographs of government-issued identity documents and selfies submitted for KYC verification purposes.
• Communications: Records of your interactions with our support team, including emails and live chat transcripts.

3.2 Information Collected Automatically

When you use the pptoto platform, we automatically collect certain technical data, including:

• Device and Browser Data: IP address, browser type and version, operating system, device type (desktop or mobile), and screen resolution.
• Usage Data: Pages visited, features used, betting and gaming activity, session duration, click patterns, and navigation paths.
• Location Data: Approximate geographic location derived from your IP address (country and city level). We do not collect precise GPS coordinates.
• Cookie Data: Information stored via cookies and similar tracking technologies as described in Section 6 of this Policy.

3.3 Information from Third Parties

In some circumstances, we may receive Personal Data about you from third parties, including:

• Identity verification providers used to assist with KYC checks.
• Payment processors and Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) confirming transaction details.
• Fraud prevention and anti-money laundering (AML) databases accessed as part of our compliance program.

4. How We Use Your Information

pptoto uses your Personal Data for the following lawful purposes:

Purpose	Legal Basis
Creating and managing your pptoto account	Performance of contract
Processing deposits and withdrawals via Indonesian banks and e-wallets	Performance of contract
Conducting KYC identity verification before the first withdrawal	Legal obligation / Legitimate interests
Detecting, preventing, and investigating fraud or money laundering	Legal obligation / Legitimate interests
Providing customer support and resolving disputes	Performance of contract / Legitimate interests
Sending account notifications (deposits confirmed, withdrawals processed)	Performance of contract
Sending promotional communications about bonuses and new features	Consent (opt-in only)
Personalizing your platform experience and game recommendations	Legitimate interests / Consent
Analyzing platform usage to improve performance and user experience	Legitimate interests
Enforcing our Terms & Conditions and Responsible Gaming policies	Legal obligation / Legitimate interests

4.1 Marketing Communications

pptoto will only send you marketing emails or SMS messages if you have explicitly opted in to receiving them during registration or through your account settings. You may opt out of marketing communications at any time by updating your notification preferences in your account dashboard or by contacting us at [email protected]. Opting out of marketing does not affect transactional notifications related to your account activity.

5. Sharing and Disclosure

5.1 When We Share Your Data

pptoto does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We share your data only in the following limited circumstances:

• Payment Processors: We share the minimum necessary financial information with Indonesian banking partners (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process your transactions.
• KYC and Identity Verification Providers: We engage trusted third-party identity verification services to assist with KYC compliance. These providers process your identity documents solely for verification and are bound by strict confidentiality obligations.
• Fraud Prevention Services: We may share data with anti-fraud and AML providers to detect and prevent financial crime.
• Gaming Content Providers: Game studios such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and Spribe may receive anonymized session data necessary to deliver their games. They do not receive your personally identifiable information.
• Legal and Regulatory Compliance: We may disclose your Personal Data to government authorities, law enforcement bodies, or regulators if required by applicable law or a valid legal order.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of our business assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

5.2 Aggregate and Anonymized Data

pptoto may share aggregated or anonymized statistical data (e.g., total number of active users in Jakarta, average deposit amounts) with business partners or in public reports. This data cannot be used to identify individual users.

6. Cookies and Tracking Technologies

6.1 Types of Cookies We Use

pptoto uses the following categories of cookies on our platform:

• Essential Cookies: Required for the platform to function. These include session management cookies that keep you logged in and security cookies that protect against cross-site request forgery (CSRF). These cannot be disabled.
• Performance Cookies: Collect anonymized data about how users interact with pptoto, including which pages are most visited and where users encounter errors. This data is used to improve platform performance.
• Functionality Cookies: Remember your preferences, such as your preferred language, display settings, and last-visited sports markets.
• Analytics Cookies: Help us understand traffic patterns and user behavior on the platform using analytics tools. Data is aggregated and does not identify individual users.

6.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling essential cookies may prevent you from logging in or using certain features of pptoto. Refer to your browser's help documentation for instructions on managing cookie settings.

7. Data Retention

pptoto retains your Personal Data for as long as your account remains active and for a reasonable period thereafter, in accordance with the following schedule:

• Account Data: Retained for the duration of your account plus 12 months after closure, to allow for dispute resolution and fraud investigation.
• Transaction Records: Financial transaction records (deposits, withdrawals, bets) are retained for a minimum of 5 years to comply with our legal and regulatory obligations.
• KYC Documents: Identity verification documents are retained for a minimum of 5 years following account closure as required by anti-money laundering regulations.
• Marketing Communications Records: Records of your marketing consent preferences are retained until you withdraw consent or close your account, whichever occurs first.
• Support Communications: Email and chat support records are retained for 3 years to assist with future support inquiries and quality improvement.

After the applicable retention period expires, your Personal Data is securely deleted or anonymized. You may request earlier deletion of your data by contacting us, subject to our legal retention obligations.

8. Data Security

pptoto employs industry-standard technical and organizational security measures to protect your Personal Data from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and pptoto servers is protected by 256-bit SSL/TLS encryption. Sensitive data stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data is restricted to authorized pptoto personnel who require it to perform their job duties. All access is logged and monitored.
• Two-Factor Authentication: pptoto staff access to internal systems requires multi-factor authentication.
• Regular Security Audits: Our infrastructure undergoes periodic third-party security assessments and penetration testing to identify and remediate vulnerabilities.
• Secure Payment Processing: All payment processing with Indonesian banks and e-wallets is conducted through PCI-DSS compliant channels. We do not store full payment card numbers.
• Incident Response: We maintain an incident response plan to detect, contain, and respond to any data security breach. In the event of a breach affecting your Personal Data, we will notify you and relevant authorities as required by law.

9. Your Rights

As a pptoto user, you have the following rights regarding your Personal Data:

• Right of Access: You have the right to request a copy of all Personal Data we hold about you. We will provide this information in a structured, machine-readable format within 30 days of your request.
• Right to Rectification: If any of your Personal Data is inaccurate or incomplete, you have the right to request correction. You can update most information directly from your account dashboard.
• Right to Erasure (Right to be Forgotten): You may request deletion of your Personal Data, subject to our legal retention obligations (e.g., we must retain financial records for regulatory compliance).
• Right to Restrict Processing: You may request that we temporarily stop processing your Personal Data in certain circumstances, such as while we verify the accuracy of disputed data.
• Right to Data Portability: You have the right to receive your Personal Data in a portable format and to request that we transfer it directly to another service provider where technically feasible.
• Right to Object: You may object to processing of your Personal Data for direct marketing purposes at any time. You may also object to processing based on legitimate interests by explaining your particular situation.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time. This will not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact us at [email protected] with the subject line "Privacy Rights Request." We will respond to all requests within 30 days. We may require identity verification before processing your request to prevent unauthorized access to your data.

10. Protection of Minors

pptoto is strictly for adults aged 21 years and older. We do not knowingly collect Personal Data from individuals under 21. Our registration process includes age verification, and all accounts are subject to KYC verification before the first withdrawal.

If we become aware that we have inadvertently collected Personal Data from a person under 21, we will take immediate steps to delete that data and permanently close the account. Parents or guardians who believe their child has registered an account on pptoto should contact us immediately at [email protected].

11. International Data Transfers

pptoto operates under international licensing. Your Personal Data may be transferred to, stored, and processed in jurisdictions outside Indonesia where our servers, service providers, or business partners are located. These jurisdictions may have data protection laws that differ from those in Indonesia.

When we transfer your Personal Data internationally, we ensure that it receives an equivalent level of protection through one or more of the following mechanisms:

• The recipient jurisdiction has been deemed to provide adequate data protection standards.
• We have implemented standard contractual clauses approved by relevant data protection authorities with our service providers.
• The recipient is certified under an approved data protection framework.

By using pptoto, you acknowledge and consent to the international transfer of your Personal Data as described in this section.

12. Changes to This Policy

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

• Sending an email notification to the email address registered on your account.
• Displaying a prominent notice on the pptoto homepage and within your account dashboard.
• Updating the "Last Updated" date at the top of this Privacy Policy.

We encourage you to review this Privacy Policy periodically. Your continued use of pptoto following notification of changes constitutes your acceptance of those changes. If you do not agree with the updated Privacy 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 our data practices, please contact us:

• Email: [email protected] (use subject line "Privacy Inquiry" for fastest response)
• Data Protection Requests: For access, correction, or deletion requests, use subject line "Privacy Rights Request"
• Support Hours: 09:00 – 22:00 WIB (Western Indonesia Time), daily
• Website: https://pptoto.cam

We aim to respond to all privacy-related inquiries within 30 days. For urgent security concerns (e.g., suspected account breach), please mark your email as "URGENT" and we will prioritize your request.