Privacy Policy

1. Introduction

This Privacy Policy applies to all personal information collected by tor23 through our website at https://tor23.cam and all associated services including sports betting, casino games, live dealer games, slot machines, togel (numbers lottery), sabung ayam (cockfighting betting), and other gaming products. This policy describes what information we collect, why we collect it, how we use it, and the choices you have regarding your personal data.

tor23 operates as an online gambling platform specifically designed for the Indonesian market. We process personal information in accordance with international data protection standards and best practices in the online gaming industry. This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming policies.

2. Information We Collect

tor23 collects various types of information to provide, maintain, and improve our services, comply with legal obligations, and protect the security and integrity of our platform.

2.1 Information You Provide Directly

When you register an account with tor23, we collect personal information that you voluntarily provide, including:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification numbers (KTP number)
• Contact Information: Email address, mobile phone number, residential address in Indonesia, postal code
• Account Credentials: Username, password, security questions and answers
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja phone numbers), payment transaction history
• Verification Documents: Copies of government-issued photo identification (KTP, passport, driver's license), proof of address documents (utility bills, bank statements), selfie photographs for identity verification
• Communication Data: Messages sent to customer support, chat transcripts, email correspondence, feedback surveys

2.2 Information Collected Automatically

When you access tor23 services, we automatically collect certain technical information about your device and usage patterns:

• Device Information: Device type (mobile, tablet, desktop), operating system and version, browser type and version, device identifiers, screen resolution
• Usage Data: Pages visited, games played, betting history, deposit and withdrawal records, login times, session duration, click patterns, feature usage
• Location Information: IP address, geographic location (city and province level), time zone
• Technical Data: Referring website, HTTP headers, cookies and similar tracking technologies

2.3 Information from Third Parties

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

• Payment Processors: Transaction verification data from Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay)
• Identity Verification Services: Age verification results, identity authentication confirmations, fraud detection signals
• Marketing Partners: If you access tor23 through a referral or affiliate link, we may receive information about the source of your visit

3. How We Use Your Information

tor23 uses your personal information for the following purposes:

3.1 Service Provision and Account Management

• Creating and managing your tor23 user account
• Verifying your identity and age (21+ requirement for Indonesian users)
• Processing deposits, withdrawals, and payment transactions via BCA, BRI, Mandiri, OVO, DANA, GoPay, and other Indonesian payment methods
• Enabling you to place bets on sports events, play casino games, and access all tor23 gaming products
• Providing customer support and responding to your inquiries through live chat, email, WhatsApp, or Telegram
• Communicating important account notifications, transaction confirmations, and service updates

3.2 Legal and Regulatory Compliance

• Complying with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Verifying eligibility to use online gambling services under applicable laws
• Detecting, preventing, and investigating fraudulent activities, money laundering, or other illegal conduct
• Maintaining records as required by gaming regulations and financial transaction laws
• Responding to legal requests from law enforcement or regulatory authorities
• Enforcing our Terms & Conditions and protecting tor23's legal rights

3.3 Platform Security and Integrity

• Protecting against unauthorized access, account takeovers, and security breaches
• Detecting and preventing bonus abuse, collusion, and terms violations
• Monitoring for suspicious betting patterns or gaming irregularities
• Ensuring fair play through game monitoring and RNG verification
• Preventing creation of multiple accounts by the same individual

3.4 Service Improvement and Personalization

• Analyzing usage patterns to improve user experience and platform performance
• Personalizing game recommendations based on your playing history
• Optimizing website layout, navigation, and mobile responsiveness
• Testing new features and conducting A/B testing for interface improvements
• Understanding Indonesian player preferences for football betting (BRI Liga 1, EPL, La Liga), casino games, and traditional gaming formats

3.5 Marketing and Promotional Communications

• Sending promotional offers, bonus announcements, and special event notifications
• Informing you about new games, features, and platform updates
• Delivering seasonal promotions timed to Indonesian holidays (Independence Day, Idul Fitri, Chinese New Year)
• Providing personalized bonus offers based on your gaming activity and VIP tier

You may opt out of marketing communications at any time by clicking the unsubscribe link in our emails or contacting customer support. Note that even if you opt out of marketing emails, you will still receive essential account-related communications.

4. Legal Basis for Processing Your Data

tor23 processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (providing gambling services as outlined in our Terms & Conditions)
• Legal Obligations: Processing is required to comply with KYC, AML, age verification, and other regulatory requirements
• Legitimate Interests: Processing is necessary for our legitimate business interests such as fraud prevention, security, platform improvement, and customer service, provided these interests do not override your privacy rights
• Consent: For marketing communications and non-essential data processing, we rely on your explicit consent, which you may withdraw at any time

5. How We Share Your Information

tor23 does not sell your personal information to third parties. We share your data only in the following limited circumstances:

5.1 Service Providers and Business Partners

We share information with trusted third-party service providers who assist in operating our platform:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) receive transaction data necessary to process deposits and withdrawals
• Game Providers: Software providers hosting our casino games, live dealer studios, and slot machines receive minimal technical data to enable gameplay
• Identity Verification Services: Third-party KYC providers receive identification documents to verify your age and identity
• Customer Support Tools: Live chat and helpdesk platforms process communication data to deliver customer service
• Cloud Hosting Providers: Infrastructure providers store data on secure servers with encryption and redundancy
• Analytics Services: We use analytics tools to understand website usage and improve user experience

All service providers are contractually bound to protect your data and use it only for specified purposes. They cannot use your information for their own marketing or share it with other parties.

5.2 Legal Requirements and Law Enforcement

We may disclose your information when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, court orders, or regulatory requests
• Respond to lawful requests from law enforcement agencies
• Protect tor23's rights, property, and safety
• Investigate suspected fraud, money laundering, or illegal activities
• Enforce our Terms & Conditions

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent website notice before your data is transferred and becomes subject to a different privacy policy.

6. Data Security Measures

tor23 implements comprehensive security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard 256-bit SSL/TLS encryption — the same security level used by international banks
• Secure Storage: Personal information is stored on encrypted servers with strict access controls. Database encryption protects data at rest
• Access Controls: Only authorized tor23 personnel with legitimate business need can access personal data. Multi-factor authentication is required for administrative access
• Regular Security Audits: Independent security firms conduct periodic audits and penetration testing to identify vulnerabilities
• Firewall Protection: Network-level firewalls and intrusion detection systems monitor for suspicious activity
• Secure Payment Processing: Payment card data is never stored on our servers. All financial transactions are processed through PCI-DSS compliant payment gateways
• Employee Training: All tor23 staff receive regular data protection training and are bound by confidentiality agreements

While we employ robust security measures, no internet transmission is 100% secure. You are responsible for maintaining the confidentiality of your account password and notifying us immediately of any unauthorized access.

7. Data Retention

tor23 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and comply with legal obligations:

• Active Accounts: While your account remains active, we retain all account information, transaction history, and gaming records
• Closed Accounts: After account closure, we retain data for a minimum of 7 years to comply with financial record-keeping requirements, AML regulations, and to resolve disputes or legal claims
• Marketing Data: If you opt out of marketing communications, we retain minimal information (email address, opt-out status) to honor your preference
• Responsible Gaming Records: Self-exclusion requests and gambling problem indicators are retained indefinitely to ensure effective player protection

After the retention period expires, personal information is securely deleted or anonymized so it can no longer identify you.

8. Cookies and Tracking Technologies

tor23 uses cookies and similar tracking technologies to enhance your browsing experience and analyze platform usage.

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They enable the website to remember your preferences and recognize you on return visits.

8.2 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for website functionality, account authentication, and security. Cannot be disabled.	Session / Persistent
Performance Cookies	Collect anonymous usage statistics to help us improve website performance and user experience.	Persistent (up to 2 years)
Functional Cookies	Remember your preferences (language, currency display, game favorites) for a personalized experience.	Persistent (up to 1 year)
Marketing Cookies	Track your activity across websites to deliver relevant advertisements and measure campaign effectiveness.	Persistent (up to 1 year)

8.3 Managing Cookies

Most web browsers allow you to control cookies through settings. You can block or delete cookies, but this may limit your ability to use certain tor23 features. Visit your browser's help section for instructions on managing cookies.

9. Your Privacy Rights

tor23 respects your rights regarding personal information. You have the following rights:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your data (subject to legal retention requirements)
• Objection: Object to processing of your data for certain purposes such as marketing
• Data Portability: Request a copy of your data in a structured, machine-readable format
• Withdraw Consent: Withdraw consent for processing based on consent (e.g., marketing emails)

To exercise any of these rights, please contact our Customer Support team at [email protected] or via live chat. We will respond to your request within 30 days. Please note that certain requests may be declined if processing is required for legal compliance or legitimate business purposes.

10. Children's Privacy

tor23 services are strictly intended for individuals aged 21 years and older. We do not knowingly collect personal information from minors under 21 years of age. If we discover that a user is underage, we will immediately suspend the account, forfeit all funds, and delete associated personal information. If you believe a minor has created an account, please contact us immediately at [email protected].

11. International Data Transfers

While tor23 primarily serves Indonesian users, some service providers and infrastructure components may be located outside Indonesia. When we transfer data internationally, we ensure adequate safeguards are in place through:

• Contractual data protection clauses with service providers
• Selection of providers certified under recognized data protection frameworks
• Encryption of data in transit and at rest

By using tor23 services, you consent to the transfer of your information to countries outside Indonesia for the purposes described in this Privacy Policy.

12. Updates to This Privacy Policy

tor23 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings. Material changes will be communicated through:

• Email notification to registered users
• Prominent notice on the tor23 website
• Update to the "Last Updated" date at the top of this document

Continued use of tor23 services following any changes constitutes acceptance of the revised Privacy Policy. We encourage you to review this policy periodically.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or how tor23 handles your personal information, please contact us:

• Email: [email protected]
• Live Chat: Available 24/7 on the tor23 website
• WhatsApp/Telegram: Contact details available on our website

Our Indonesian-speaking customer support team is available around the clock to address your privacy concerns and assist with any data-related requests.