At too12, your privacy is a fundamental commitment, not a compliance checkbox. This Privacy Policy explains precisely what personal data we collect when you use the too12 platform, how that data is processed and protected, with whom it may be shared, and what rights you hold as a data subject. Please read this document in full before registering an account.
These highlight cards summarize our core privacy principles. They do not replace the full policy text below — all members are required to read the complete document.
too12 collects only the data strictly necessary to operate your account, process payments in IDR, comply with KYC obligations, and deliver a personalized betting experience. We do not collect data beyond these defined purposes.
All data transmitted between your device and too12's servers is protected by industry-standard 256-bit SSL/TLS encryption. Sensitive data at rest — including payment credentials and KYC documents — is stored using AES-256 encryption.
too12 does not sell, rent , or trade your personal data to third-party marketers or data brokers under any circumstances. Data shared with service providers is governed by strict data processing agreements limiting use to defined purposes only.
You have the right to access, correct, and request deletion of your personal data at any time. too12 honors data subject requests within 30 business days of verified submission. See Section 9 below for full details on exercising your rights.
too12 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by our international licensing authority. Accounts inactive for 5 years and with zero balance are subject to anonymization procedures.
Promotional communications are only sent to members who have explicitly opted in. You may withdraw consent and unsubscribe from all marketing at any time through your account settings panel or by contacting our 24/7 live chat support team.
too12 ("we", "us", "our", or "the Platform") operates the online betting and gaming website located at https://too12.net, together with all associated sub-domains, mobile interfaces, and platform applications. This Privacy Policy describes our practices with respect to the collection, use, storage, disclosure, and protection of personal data provided by or collected from individuals ("you", "your", or "Member") who access or use any part of the too12 Platform.
too12 is committed to handling personal data responsibly, lawfully, and transparently in accordance with internationally recognized data protection principles and the requirements of our international operating license. Our primary market is Indonesia, and the majority of our members are Indonesian residents transacting in Indonesian Rupiah (IDR) via local payment channels including BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja. This context informs how we structure our data processing activities, particularly with respect to payment verification and KYC compliance.
By accessing the too12 Platform, completing the account registration process, or continuing to use too12 after the effective date of this policy, you acknowledge that you have read, understood, and agree to the data practices described herein. If you do not agree, you must discontinue use of the Platform immediately.
For the purposes of applicable data protection law, too12 acts as the data controller in respect of all personal data collected from members through the Platform. As data controller, too12 determines the purposes for which and the means by which personal data is processed.
Where too12 engages third-party service providers — such as KYC verification vendors, payment processors, or licensed game studios — to process personal data on its behalf, those providers act as data processors operating under written data processing agreements that restrict their use of member data to the specific services they provide to too12. too12 remains accountable for the lawful processing of your data in all such arrangements.
Our Data Protection contact can be reached at: [email protected] — please mark your subject line "Data Protection Enquiry" so your message is routed to the appropriate team.
too12 collects personal data through several channels: directly from you during registration and account use, automatically through your use of the Platform, and from third-party verification services. The categories of data we collect are set out in the table below:
| Data Category | Specific Data Points | Collection Trigger |
|---|---|---|
| Registration Data | Full legal name, date of birth, Indonesian residential address, email address, username, password (hashed) | Account registration |
| KYC Identity Data | Government-issued ID (KTP, passport, driving license), proof of address document, selfie/liveness photograph | KYC verification request |
| Payment Data | Bank account name and number (BCA, BRI, BNI, Mandiri, etc.), e-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history in IDR | Deposit or withdrawal request |
| Betting & Gaming Data | Wager history, game session logs, sportsbook bet slips, togel ticket records, win/loss history, bonus redemption records | Platform use |
| Technical Data | IP address, device type, browser type and version, operating system, screen resolution, session duration, page views, referring URL | Automatic — on site visit |
| Communications Data | Live chat transcripts, email correspondence, support ticket content, records of marketing consent and opt-out | Customer support or marketing interaction |
| Responsible Gaming Data | Deposit limit settings, cooling-off period records, self-exclusion status, session time reminder configurations | Responsible gaming tool activation |
too12 does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric data (beyond liveness photographs required for KYC), or data concerning health, unless you voluntarily provide such information in the context of a responsible gaming support request.
too12 uses the personal data described in Section 3 for the following defined purposes:
too12 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:
too12 does not sell, rent, or trade your personal data to any third party for commercial marketing purposes. Your data may be shared with the following categories of recipients, strictly for the purposes described:
In all cases of data sharing with third parties, too12 implements contractual safeguards — including data processing agreements and confidentiality clauses — to ensure that recipient organizations process your data lawfully and securely.
too12 uses cookies and similar tracking technologies to enable core platform functionality, maintain your logged-in session, and gather aggregate analytical data about how members use the Platform. The categories of cookies we use are as follows:
Most modern browsers allow you to view, manage, and delete cookies through the browser settings menu. Disabling essential cookies will impair your ability to use the too12 Platform. Disabling analytical or functional cookies will not prevent you from accessing too12's services but may reduce the personalization of your experience.
too12 retains personal data for the minimum period necessary to fulfill the purpose for which it was collected, subject to any longer retention periods required by our international licensing authority or applicable anti-money laundering regulations. The following retention periods apply by data category:
| Data Category | Retention Period | Reason |
|---|---|---|
| Registration & Account Data | Duration of account + 5 years post-closure | Licensing obligation, dispute resolution |
| KYC Identity Documents | 5 years from date of submission | AML compliance requirement |
| Transaction & Payment Records | 7 years from transaction date | Financial audit and licensing reporting |
| Betting History | 5 years from bet settlement date | Dispute resolution, regulatory reporting |
| Technical & Log Data | 13 months on a rolling basis | Fraud detection and security monitoring |
| Marketing Consent Records | Duration of consent + 3 years | Proof of consent / opt-out compliance |
| Self-Exclusion Records | Minimum 6 years from exclusion date | Responsible gaming compliance |
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in such a manner that it can no longer be attributed to an identifiable individual. Anonymized data may be retained indefinitely for aggregate statistical analysis.
As a data subject, you hold the following rights in relation to your personal data held by too12. These rights may be exercised free of charge by submitting a written request to [email protected] with the subject line "Data Subject Request" and your registered username:
Request a copy of all personal data too12 holds about you, including its source, purpose, and any third parties with whom it has been shared.
Request correction of any inaccurate or incomplete personal data held in your account record. You may also update many details directly through your account settings panel.
Request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to our overriding legal obligations to retain certain records under our licensing conditions.
Request that too12 restrict processing of your data — for example, while the accuracy of data is being contested or while an objection to processing is being assessed.
Request a structured, machine-readable copy of personal data you provided to too12 under a consent or contract basis, suitable for transmission to another service provider.
Object to processing of your personal data carried out on the basis of too12's legitimate interests — for example, direct marketing or certain fraud-prevention profiling activities.
too12 will respond to all verified data subject requests within 30 business days of receipt. Where a request is particularly complex or where too12 receives a high volume of concurrent requests, this period may be extended by a further 30 days, in which case you will be notified in writing of the extension and the reason for it.
Please note that certain rights — particularly the right to erasure — may be limited where too12 is subject to a legal obligation to retain your data, or where retention is necessary for the establishment, exercise, or defense of legal claims. In such cases, too12 will explain the specific reason why your erasure request cannot be fully honored.
too12 implements a comprehensive, layered information security framework to protect member personal data against unauthorized access, accidental loss, alteration, or destruction. Our technical and organizational security measures include:
While too12 takes every reasonable precaution to protect your personal data, no internet transmission or electronic storage system can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your too12 account credentials and for notifying too12 immediately at [email protected] if you suspect unauthorized access to your account.
The too12 Platform is strictly restricted to adults aged 21 years and over. too12 does not knowingly collect personal data from individuals under the age of 21, and the Platform's registration process includes date-of-birth verification as a mandatory step designed to prevent access by minors.
If too12 becomes aware — through KYC verification, account review, or any other means — that a member is under the age of 21, the account will be suspended immediately, all funds will be returned to the verified payment source, and all personal data associated with the underage account will be deleted as promptly as is consistent with our legal obligations.
If you are a parent or guardian and have reason to believe that a minor in your care has registered an account with too12, please contact our support team immediately via live chat or at [email protected] so that we may take prompt corrective action.
too12 operates on internationally licensed infrastructure, and certain data processing activities — including game delivery by third-party studios and KYC verification services — may involve the transfer of personal data to servers or processors located outside Indonesia. Where such transfers occur, too12 ensures that adequate safeguards are in place to protect your data to a standard equivalent to that described in this Privacy Policy.
Safeguards used for international transfers include:
If you wish to obtain further details about the safeguards applied to any specific international transfer of your personal data, please contact too12's Data Protection team at [email protected].
The too12 Platform may, from time to time, contain references to or integrations with third-party game providers, payment gateways, and sports data feed providers. While too12 selects its third-party partners carefully and requires them to meet defined security and data protection standards via contractual agreements, too12 is not responsible for the independent privacy practices of those third parties once data passes beyond too12's direct control.
We encourage you to review the privacy policies of any third-party services you interact with in connection with your too12 account. This Privacy Policy applies only to data collected and processed by too12 through the too12 Platform; it does not govern the practices of third-party processors acting as independent controllers of their own data environments.
too12 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, Platform features, legal obligations, or applicable regulatory requirements. When material changes are made, too12 will:
Your continued use of the too12 Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the revised Privacy Policy, you must cease using the Platform and may request account closure by contacting our support team.
We recommend that you review this Privacy Policy periodically — at minimum on an annual basis — to stay informed of how too12 protects your personal data. Archived versions of previous Privacy Policies are available upon written request to [email protected].
If you have any questions, concerns, or requests regarding this Privacy Policy or too12's data processing practices, please contact our Data Protection team through any of the following channels:
too12 is committed to resolving all privacy-related enquiries promptly and transparently. If you are not satisfied with the response you receive, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.
too12 is committed to keeping your personal data secure so you can focus on what matters — placing bets, chasing wins, and enjoying Indonesia's most trusted online betting experience. Explore our full range of products today.