ectoto Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by ectoto through our website, mobile applications, and any other digital platforms or services we operate (collectively, the "Platform"). This policy describes what information we collect about you, how we use it, who we share it with, and your rights concerning your data.

By creating an Account, accessing the ectoto Platform, or using any of our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with any part of this policy, you must immediately discontinue use of our Platform and Services.

ectoto operates under internationally recognised data protection standards and complies with applicable Indonesian privacy regulations. We are committed to transparency in our data practices and to providing you with meaningful control over your personal information.

2. Information We Collect

ectoto collects personal information from you in several ways, including information you provide directly to us, information we collect automatically through your use of the Platform, and information we receive from third-party sources. The types of personal data we collect include:

2.1 Information You Provide Directly

• Account Registration Information: When you create an ectoto Account, we collect your full legal name, date of birth, residential address, email address, mobile phone number, preferred username, password, security questions and answers, and any other information you provide during the registration process.
• Identity Verification Documents: To comply with Know Your Customer (KYC) and anti-money laundering (AML) regulations, we may request and collect copies of government-issued identification documents such as your Indonesian national identity card (KTP), passport, driver's licence, or other proof of identity and address.
• Payment Information: We collect information about your payment methods, including bank account details (bank name, account holder name, account number), e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja account identifiers), and transaction history associated with deposits and withdrawals on the Platform.
• Communication Records: When you contact our customer support team via live chat, email, WhatsApp, or in-app messaging, we collect and store the content of your communications, including any attachments, screenshots, or other information you provide to assist with your inquiry.
• Survey and Feedback Responses: If you participate in surveys, contests, promotions, or provide feedback about our Services, we collect the information you submit in those responses.

2.2 Information We Collect Automatically

• Device and Technical Information: We automatically collect information about the device you use to access the Platform, including device type, operating system, browser type and version, screen resolution, IP address, unique device identifiers, mobile network information, and general geographic location derived from your IP address.
• Usage Data: We collect information about how you interact with the Platform, including pages viewed, features used, time spent on pages, links clicked, search queries, games played, bets placed, deposit and withdrawal activity, login and logout times, session duration, and referring/exit pages.
• Cookies and Similar Technologies: We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your browsing behaviour, preferences, and interactions with the Platform. For more details, see Section 10 (Cookies and Tracking Technologies).
• Transaction History: We maintain detailed records of all financial transactions processed through your Account, including deposits, withdrawals, wagers placed, winnings paid out, bonuses awarded and wagered, and adjustments made to your Account balance.
• Gameplay and Betting Activity: We collect data on your gaming behaviour, including games played, betting patterns, stake amounts, win/loss ratios, session frequency and duration, use of responsible gaming tools (deposit limits, time-outs, self-exclusion), and interactions with specific game features.

2.3 Information We Receive from Third Parties

• Payment Processors: When you make a deposit or request a withdrawal, we receive transaction confirmation data from third-party payment processors (banks, e-wallet providers) to verify and reconcile your payments.
• Identity Verification Services: We may use third-party identity verification and fraud prevention services to validate your identity, verify your documents, and screen for suspicious activity. These services may provide us with verification results, risk scores, and related data.
• Affiliate and Marketing Partners: If you reached ectoto through an affiliate link, marketing campaign, or referral programme, we may receive information about the source of your registration and associated campaign identifiers.

3. How We Use Your Information

ectoto uses the personal information we collect for the following purposes:

3.1 Service Provision and Account Management

• To create, maintain, and manage your ectoto Account.
• To process your deposits, withdrawals, and other financial transactions.
• To enable you to place bets, play casino games, participate in togel draws, and access other gambling products on the Platform.
• To track your Account balance, transaction history, and gameplay activity.
• To provide customer support and respond to your inquiries, requests, and complaints.

3.2 Identity Verification and Compliance

• To verify your identity, age, and eligibility to use ectoto Services in accordance with our Terms and Conditions.
• To comply with Know Your Customer (KYC), anti-money laundering (AML), and counter-terrorism financing (CTF) regulations.
• To prevent fraud, detect and investigate suspicious activity, and protect against unauthorised access or use of the Platform.
• To enforce our Terms and Conditions, Responsible Gaming Policy, and other legal agreements.
• To comply with applicable laws, regulations, and legal obligations, including responding to lawful requests from law enforcement, regulatory authorities, and courts.

3.3 Marketing and Communications

• To send you promotional offers, bonus notifications, loyalty programme updates, and other marketing communications via email, SMS, push notifications, or in-app messaging (subject to your consent and communication preferences).
• To personalise your experience on the Platform by tailoring content, game recommendations, and promotional offers based on your preferences and activity.
• To conduct surveys, market research, and customer feedback initiatives to improve our Services.

3.4 Platform Improvement and Analytics

• To analyse usage patterns, trends, and behaviours to understand how Users interact with the Platform and identify areas for improvement.
• To develop, test, and enhance new features, products, and services.
• To monitor and improve the performance, security, and reliability of the Platform.
• To detect and prevent technical issues, bugs, and vulnerabilities.

3.5 Responsible Gaming and Player Protection

• To monitor your gambling behaviour and identify signs of problem gambling or at-risk activity.
• To implement and enforce responsible gaming tools, including deposit limits, loss caps, session timers, reality-check reminders, and self-exclusion periods.
• To provide support and referrals to professional gambling assistance resources if you request help or if we identify concerning patterns in your gameplay.

4. Legal Basis for Processing

ectoto processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and ectoto (i.e., our Terms and Conditions) and to provide you with the Services you have requested, including Account management, transaction processing, and game access.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including KYC, AML, CTF, and age-verification requirements, as well as legal requests from authorities.
• Legitimate Interests: Processing is necessary for ectoto's legitimate business interests, such as fraud prevention, security monitoring, customer support, service improvement, and internal analytics, provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: In certain cases (e.g., marketing communications, use of certain cookies), we process your data based on your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing based on consent before its withdrawal.

5. Data Sharing and Disclosure

ectoto does not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may share your data with the following categories of recipients in the circumstances described below:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to support the operation of the Platform, including payment processors, identity verification services, cloud hosting providers, customer support software vendors, data analytics firms, and marketing automation platforms. These service providers are contractually obligated to use your data only for the purposes of providing services to ectoto and to implement appropriate security measures to protect your information.

5.2 Game and Software Providers

When you play casino games, place sports bets, or participate in other gaming products on the Platform, we share limited information (such as your User ID, bet details, and gameplay data) with the respective game studios, sportsbook providers, and software platforms that power those products. This data sharing is necessary to deliver the Services and ensure fair and secure gameplay.

5.3 Regulatory Authorities and Law Enforcement

We may disclose your personal information to regulatory bodies, law enforcement agencies, tax authorities, and courts when required by law, legal process, court order, subpoena, or when we believe in good faith that disclosure is necessary to comply with legal obligations, protect our rights and property, investigate fraud or security incidents, or protect the safety of our Users or the public.

5.4 Corporate Transactions

In the event that ectoto undergoes a merger, acquisition, asset sale, bankruptcy, or other corporate restructuring, your personal information may be transferred to the acquiring entity or successor organisation as part of the transaction. We will notify you of any such change in ownership or control of your personal data via email or prominent notice on the Platform.

5.5 Affiliates and Group Companies

We may share your information with affiliated companies within our corporate group for purposes consistent with this Privacy Policy, including shared services, internal reporting, and consolidated security monitoring.

6. International Data Transfers

ectoto operates on an international scale and may transfer your personal data to servers and service providers located outside of Indonesia, including in jurisdictions that may not provide the same level of data protection as Indonesian law. When we transfer data internationally, we implement appropriate safeguards to ensure your data remains protected, including:

• Standard Contractual Clauses (SCCs) approved by relevant data protection authorities.
• Binding Corporate Rules for transfers within our corporate group.
• Ensuring that recipient countries have been deemed to provide adequate data protection by Indonesian or international regulatory bodies.
• Obtaining your explicit consent for specific transfers where required by law.

7. Data Security and Protection

ectoto implements industry-standard technical and organisational measures to protect your personal information from unauthorised access, disclosure, alteration, destruction, or loss. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.3 (256-bit SSL encryption) to prevent interception by unauthorised third parties. Sensitive data stored on our servers, including payment information and identity documents, is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorised ectoto personnel and service providers on a need-to-know basis. All staff members with access to personal data are subject to confidentiality obligations and receive regular data protection training.
• Secure Infrastructure: Our Platform is hosted on secure, redundant servers with firewall protection, intrusion detection systems, and regular security audits. We monitor for suspicious activity and potential security threats 24/7.
• Two-Factor Authentication (2FA): We offer optional two-factor authentication for Account logins to provide an additional layer of security. We strongly recommend enabling this feature.
• Regular Security Testing: We conduct regular penetration testing, vulnerability assessments, and security audits to identify and remediate potential weaknesses in our systems.

Despite these measures, no method of data transmission or storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials and for notifying us immediately if you suspect any unauthorised access to your Account.

8. Data Retention

ectoto retains your personal information for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and support business operations. Specific retention periods include:

• Account Data: We retain your Account information for the duration of your active Account and for a period of seven (7) years after Account closure to comply with financial record-keeping and AML regulations.
• Transaction Records: Financial transaction data, including deposits, withdrawals, and betting history, is retained for a minimum of seven (7) years to comply with tax, accounting, and regulatory requirements.
• Identity Verification Documents: Copies of identity documents submitted for KYC purposes are retained for seven (7) years after Account closure or the conclusion of the business relationship, as required by AML regulations.
• Communication Records: Customer support interactions, including live chat transcripts, emails, and in-app messages, are retained for three (3) years for quality assurance and dispute resolution purposes.
• Marketing Data: If you opt out of marketing communications, we retain a record of your opt-out preference indefinitely to ensure we do not contact you inappropriately in the future.

Upon expiry of the applicable retention period, we will securely delete or anonymise your personal data so that it can no longer be associated with you. In certain cases, we may retain anonymised or aggregated data for statistical, research, and analytical purposes without limitation.

9. Your Privacy Rights

Subject to applicable law, you have the following rights concerning your personal information:

• Right of Access: You have the right to request confirmation of whether we process your personal data and to obtain a copy of the data we hold about you.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. You can update most Account information directly through your Account settings.
• Right to Erasure ("Right to be Forgotten"): You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when you object to processing. Note that we may be required to retain certain data to comply with legal obligations.
• Right to Restriction of Processing: You have the right to request that we restrict processing of your personal data in certain situations, such as when you contest the accuracy of the data or object to processing.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to request that we transmit this data to another controller where technically feasible.
• Right to Object: You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. If you object to marketing, we will cease such processing immediately.
• Right to Withdraw Consent: Where we process your data based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: If you believe that we have violated your privacy rights or applicable data protection laws, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with your request. We will respond to your request within thirty (30) days. In some cases, we may request additional information to verify your identity before processing your request.

10. Cookies and Tracking Technologies

ectoto uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and deliver personalised content and advertising. Cookies are small text files stored on your device that allow us to recognise you and remember your preferences.

We use the following types of cookies:

• Essential Cookies: These cookies are necessary for the Platform to function properly and cannot be disabled. They enable core functionality such as security, network management, login authentication, and session management.
• Performance Cookies: These cookies collect information about how you use the Platform, such as which pages you visit most often and whether you receive error messages. This data helps us improve the performance and usability of the Platform.
• Functionality Cookies: These cookies allow the Platform to remember your preferences (such as language, currency, display settings) and provide enhanced, personalised features.
• Advertising Cookies: These cookies are used to deliver targeted advertisements and promotional offers based on your interests and browsing behaviour. They may also be used to limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns.

Most web browsers allow you to control cookies through their settings. You can configure your browser to refuse all cookies or to alert you when a cookie is being set. However, if you disable cookies, some features of the Platform may not function properly, and your user experience may be affected.

11. Third-Party Services and Links

The ectoto Platform may contain links to third-party websites, services, or applications that are not operated or controlled by ectoto. This Privacy Policy does not apply to those external sites. We encourage you to review the privacy policies of any third-party services you access through links on our Platform. ectoto is not responsible for the privacy practices or content of third-party websites.

12. Children's Privacy

ectoto Services are intended solely for adults aged 21 years or older. We do not knowingly collect, use, or solicit personal information from individuals under the age of 21. If we become aware that we have collected personal data from a person under 21 without verification of parental or guardian consent, we will take immediate steps to delete that information. If you believe that we have inadvertently collected data from a minor, please contact us immediately at [email protected].

13. Changes to This Privacy Policy

ectoto reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Any changes will be effective immediately upon posting the revised Privacy Policy on the Platform, and the "Last Updated" date at the top of this document will be revised accordingly.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. If we make material changes that significantly affect your privacy rights, we will provide additional notice via email or prominent notice on the Platform before the changes take effect. Your continued use of the ectoto Platform after any modification to this Privacy Policy constitutes your acceptance of the revised terms.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, or if you wish to exercise any of your privacy rights, please contact our Data Protection Officer:

• Email: [email protected]
• WhatsApp: +62 812 3456 7890
• Live Chat: Available 24/7 via the chat widget on the ectoto Platform
• In-App Messaging: Accessible through the secure messaging centre in your Account dashboard

We aim to respond to all privacy-related inquiries within thirty (30) days. For urgent matters concerning data security or potential data breaches, we recommend using live chat or WhatsApp for the fastest response.