Privacy Policy

Introduction

This Privacy Policy applies to all personal data processed by matoto (referred to as "we", "us", "our", or "the Company") through the website https://matoto.cam (the "Platform"), as well as any related mobile applications, APIs, and digital services we operate.

We recognize that privacy is a fundamental right. As an online betting platform serving Indonesian players, matoto processes personal information in accordance with international data protection standards, including principles derived from the European Union's General Data Protection Regulation (GDPR) and Indonesia's Personal Data Protection Law (UU PDP No. 27 of 2022), adapted to the context of our international licensing and offshore operations.

This Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, and what rights you have regarding your personal information. Please read this document carefully alongside our Terms & Conditions, which govern your use of the matoto Platform.

Data Controller

For the purposes of applicable data protection laws, the data controller responsible for your personal information is:

matoto
An internationally licensed online gaming operator
Email: [email protected]

All questions, requests, or complaints regarding the processing of your personal data should be directed to the contact details provided in Section 15 of this Policy.

Data We Collect

matoto collects and processes the following categories of personal data:

3.1 Registration and Account Data

• Full legal name (as it appears on government-issued identification)
• Date of birth (to verify you are 21 years of age or older)
• Email address
• Mobile phone number
• Physical address (city, province, postal code)
• Account username and encrypted password
• Preferred currency (IDR / Indonesian Rupiah)

3.2 Identity Verification (KYC) Data

• Government-issued identity documents: National Identity Card (KTP), Passport, or Driver's License
• Proof of address documents: utility bills, bank statements, or government correspondence
• Proof of payment method ownership: screenshots or scans of bank account or e-wallet registrations
• Selfie photographs (where required for enhanced verification)

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method details: bank account numbers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Transaction amounts, timestamps, and processing status
• Wallet balance history
• Bonus claim and wagering history

3.4 Gaming and Betting Data

• Bet placement records: sports markets, casino games, togel (lottery) selections, and other gaming products
• Bet outcomes, winnings, and losses
• Game session duration and frequency
• Favorite games and betting patterns

3.5 Technical and Device Data

• IP address and geolocation data (city-level; WIB, WITA, or WIT time zones)
• Device type, operating system, browser type and version
• Screen resolution and device identifiers
• Referral source (how you arrived at matoto.cam)
• Cookies and similar tracking technologies (see Section 10)

3.6 Communication and Support Data

• Live chat transcripts
• Email correspondence with customer support
• Survey responses and feedback submissions
• Complaint records and resolution notes

How We Collect Data

Personal data is collected through the following methods:

4.1 Direct Collection

You provide information directly to matoto when you:

• Register for an Account
• Complete identity verification (KYC) procedures
• Make deposits or request withdrawals
• Place bets or play games on the Platform
• Contact customer support via live chat, email, or in-app messaging
• Participate in promotions, surveys, or competitions

4.2 Automated Collection

Technical data is collected automatically through:

• Cookies, web beacons, and similar tracking technologies embedded in the Platform
• Server logs that record IP addresses, access times, and page views
• Analytics tools that measure user behavior and Platform performance

4.3 Third-Party Sources

In limited cases, we may receive data from third parties, including:

• Payment processors confirming transaction validity
• Identity verification services cross-referencing submitted documents
• Fraud prevention databases checking for high-risk indicators

Purposes of Processing

matoto processes your personal data for the following purposes:

Purpose	Data Categories Used
Account Management Creating and maintaining your registered Account	Registration data, account credentials, contact information
Age and Identity Verification Ensuring compliance with 21+ age requirement and preventing fraud	KYC documents, identity data, proof of address
Payment Processing Processing deposits, withdrawals, and financial transactions	Financial data, payment method details, transaction records
Gaming Services Enabling sports betting, casino games, and togel participation	Gaming data, bet records, wallet balance
Customer Support Responding to inquiries, resolving disputes, handling complaints	Communication data, support tickets, account history
Fraud Prevention & Security Detecting and preventing fraudulent activity, bonus abuse, and security threats	Technical data, device identifiers, behavioral patterns, IP addresses
Responsible Gaming Implementing self-exclusion, deposit limits, and problem gambling detection	Gaming behavior data, session duration, responsible gaming tool settings
Marketing & Promotions Sending promotional offers, bonuses, and newsletters (with your consent)	Email address, gaming preferences, opt-in status
Legal Compliance Meeting regulatory obligations under gaming licenses and AML laws	All categories as required by applicable law
Platform Improvement Analyzing user behavior to improve Platform functionality and user experience	Technical data, usage statistics, anonymized behavioral data

Legal Basis for Processing

Under applicable data protection law, matoto relies on the following legal bases to process your personal data:

6.1 Contractual Necessity

Processing is necessary to perform our contract with you under the Terms & Conditions. This includes account management, payment processing, delivering gaming services, and customer support.

6.2 Legal Obligation

Processing is required to comply with legal obligations imposed by our gaming licenses, anti-money-laundering (AML) regulations, responsible gaming laws, and tax reporting requirements.

6.3 Legitimate Interests

Processing is necessary for our legitimate business interests, including fraud prevention, Platform security, responsible gaming monitoring, and service improvement — provided these interests do not override your fundamental rights.

6.4 Consent

Where required by law (e.g., for marketing communications or non-essential cookies), we process data based on your explicit, freely given consent. You may withdraw consent at any time through your Account settings or by contacting support.

Data Sharing and Disclosure

matoto does not sell your personal data to third parties. However, we may share your information with the following categories of recipients for the purposes described above:

7.1 Service Providers

• Payment processors: Banks, e-wallet providers, and payment gateways that facilitate deposits and withdrawals
• Game providers: Pragmatic Play, Evolution Gaming, PG Soft, and other licensed studios whose games you play
• Identity verification services: Third-party KYC providers that authenticate documents and detect fraud
• Cloud hosting providers: Infrastructure partners who host our servers and databases securely
• Customer support platforms: Live chat and ticketing systems that help us respond to your inquiries

All service providers are contractually bound to process data only on our instructions and maintain appropriate security measures.

7.2 Legal and Regulatory Authorities

We may disclose personal data to regulatory bodies, law enforcement agencies, courts, or government authorities when required by law, court order, subpoena, or to protect our legal rights.

7.3 Business Transfers

In the event matoto undergoes a merger, acquisition, sale of assets, or other corporate restructuring, your personal data may be transferred to the successor entity, subject to the same privacy protections outlined in this Policy.

Data Retention

matoto retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law.

8.1 Active Accounts

Data associated with active Accounts is retained for the duration of your relationship with matoto, plus any period required by our gaming licenses and AML obligations (typically 5–7 years from the date of your last transaction).

8.2 Closed Accounts

If you close your Account, we will retain certain records — including transaction history, KYC documents, and responsible gaming logs — for regulatory compliance purposes. Non-essential data (marketing preferences, session logs) is deleted within 90 days of Account closure.

8.3 Legal Holds

Where data is subject to ongoing litigation, investigation, or dispute, retention periods are extended until the matter is resolved.

Security Measures

matoto employs industry-standard technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using Secure Socket Layer technology
• Encrypted Data Storage: Sensitive data (passwords, payment details, KYC documents) is encrypted at rest using AES-256 encryption
• Access Controls: Personal data is accessible only to authorized employees and contractors who require it to perform their duties, under strict confidentiality obligations
• Two-Factor Authentication (2FA): Optional 2FA is available to add an extra layer of Account security
• Regular Security Audits: Independent third-party penetration testing and vulnerability assessments are conducted quarterly
• Secure Data Centers: Our infrastructure is hosted in certified data centers with physical security, redundancy, and disaster recovery protocols
• Employee Training: All staff receive regular training on data protection, confidentiality, and cybersecurity best practices

Despite these measures, no internet-based system is entirely secure. You are responsible for safeguarding your login credentials and should notify us immediately at [email protected] if you suspect unauthorized access to your Account.

Cookies and Tracking Technologies

matoto uses cookies, web beacons, and similar technologies to enhance Platform functionality, analyze user behavior, and deliver personalized experiences.

10.1 Types of Cookies We Use

• Essential Cookies: Required for core Platform functionality (login sessions, security, load balancing). These cannot be disabled.
• Performance Cookies: Collect anonymized data on how users interact with the Platform to help us improve speed and usability.
• Functional Cookies: Remember your preferences (language, currency, favorite games) for a better user experience.
• Marketing Cookies: Track your activity across sessions to deliver relevant promotional offers. Require your consent.

10.2 Managing Cookies

You can control cookie preferences through your browser settings. Note that disabling essential cookies may impair Platform functionality. Marketing and non-essential cookies can be managed via the cookie consent banner displayed on your first visit or through your Account settings.

Your Rights

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

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Correct inaccurate or incomplete personal information
• Right to Erasure ("Right to be Forgotten"): Request deletion of your data, subject to legal retention obligations
• Right to Restriction: Limit how we process your data in certain circumstances
• Right to Data Portability: Receive your personal data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for marketing purposes
• Right to Withdraw Consent: Revoke consent previously given for marketing or non-essential cookies
• Right to Lodge a Complaint: File a complaint with a supervisory data protection authority if you believe your rights have been violated

To exercise any of these rights, please contact us at [email protected] with your Account username and a clear description of your request. We will respond within 30 days as required by applicable law.

Children's Privacy

matoto is strictly an adult-only Platform. We do not knowingly collect personal data from individuals under the age of 21 years. If we discover that a minor has provided personal information or created an Account, we will immediately close the Account, void all transactions, and delete the associated data.

Parents or guardians who believe their child has accessed matoto should contact us immediately at [email protected] so we can take appropriate action.

International Data Transfers

matoto operates as an internationally licensed offshore gaming platform. Your personal data may be transferred to, stored in, and processed in jurisdictions outside Indonesia, including countries that may have different data protection standards than those in your country of residence.

Where such transfers occur, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by regulatory authorities
• Adequacy decisions recognizing the recipient jurisdiction's data protection framework
• Binding corporate rules within our group of companies

By using the matoto Platform, you acknowledge and consent to such international transfers of your personal data.

Changes to This Privacy Policy

matoto reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated to registered Account holders via email and through a prominent notice on the Platform at least 14 days before the updated Policy takes effect.

The "Effective Date" at the top of this document indicates when the current version was last revised. Your continued use of the Platform after changes take effect constitutes your acceptance of the updated Privacy Policy.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how matoto handles your personal data, please contact us through the following channels:

• Email: [email protected] (response within 48 hours)
• Live Chat: Available 24/7 on the Platform
• Subject Line for Privacy Requests: "Privacy Policy Inquiry" or "Data Subject Request"

For formal complaints or data protection concerns, please mark your communication "Attention: Data Protection Officer" to ensure prompt routing to the appropriate team.