Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by m11to through our website at https://m11to.cam, mobile applications, and any related services (collectively, "Services"). By registering an account and using m11to Services, you consent to the collection, use, and processing of your personal information as described in this Privacy Policy.

m11to operates as an internationally licensed online betting platform serving Indonesian players. We recognize that privacy is a fundamental right and we are committed to transparency in how we handle your personal data. This policy is designed to help you understand what information we collect, why we collect it, and what we do with it.

If you do not agree with this Privacy Policy, you should discontinue use of m11to Services immediately. Your continued use of our Services following any changes to this Privacy Policy constitutes acceptance of those changes.

2. Information We Collect

2.1 Information You Provide Directly

When you register an account with m11to, you provide us with personal information that is necessary to establish your identity, comply with regulatory requirements, and provide our Services. This information includes:

• Registration Information: Full name, date of birth, gender, email address, phone number, residential address, and country of residence
• Identity Verification Documents (KYC): Indonesian National Identity Card (KTP / Kartu Tanda Penduduk), passport, driver's license, proof of address documents (utility bills, bank statements), and selfie photographs holding identification
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account information (OVO, DANA, GoPay), transaction history, deposit and withdrawal records
• Communication Data: Contents of customer support inquiries via live chat, email, WhatsApp, phone calls, and any feedback or surveys you complete
• Account Preferences: Language preferences, notification settings, responsible gaming limits (deposit limits, loss limits, time limits), and marketing communication preferences

2.2 Information Collected Automatically

When you access and use m11to Services, we automatically collect certain technical and behavioral data:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IP address, device ID)
• Usage Data: Pages visited, features used, time spent on pages, click patterns, search queries, games played, bet history, session duration, access times and dates
• Location Data: Approximate geographic location derived from IP address to verify compliance with geographic restrictions
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies (see Section 8 for detailed cookie policy)

2.3 Information from Third-Party Sources

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

• Payment Processors: Transaction verification and fraud prevention data from banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay)
• Identity Verification Services: Results of identity checks and anti-fraud screening from third-party verification providers
• Game Providers: Game play data, results, and outcomes from third-party gaming providers such as Pragmatic Play, Evolution Gaming, PG Soft, and Microgaming
• Public Sources: Publicly available information for fraud prevention and regulatory compliance purposes

3. How We Use Your Information

m11to collects and processes your personal data for specific, legitimate purposes. We use your information to:

3.1 Provide and Manage Services

• Create and maintain your m11to account
• Process your deposits, withdrawals, and other financial transactions
• Enable you to place bets on sports, play casino games, participate in togel draws, and access other gaming products
• Track your betting history, account balance, and transaction records
• Provide customer support and respond to your inquiries
• Administer bonuses, promotions, and VIP rewards programs

3.2 Comply with Legal and Regulatory Obligations

• Verify your identity and age to ensure you meet eligibility requirements (21+ years for Indonesian players)
• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Detect and prevent fraud, money laundering, and other illegal activities
• Maintain records as required by gaming licenses and regulatory authorities
• Respond to legal requests from law enforcement or government agencies

3.3 Improve and Personalize Your Experience

• Analyze usage patterns to improve website functionality and user experience
• Personalize game recommendations based on your preferences and playing history
• Optimize platform performance and troubleshoot technical issues
• Conduct market research and analyze trends to develop new features

3.4 Marketing and Communications

• Send promotional offers, bonus announcements, and special event notifications (with your consent)
• Communicate important account updates, security alerts, and policy changes
• Provide information about new games, features, and services
• Send newsletters and betting tips tailored to Indonesian football leagues (BRI Liga 1) and international sports

You may opt out of marketing communications at any time through your account settings or by contacting customer support. Transactional and service-related communications cannot be opted out as they are essential to providing our Services.

3.5 Responsible Gaming Protection

• Monitor gambling behavior to identify signs of problem gambling
• Enforce self-imposed limits (deposit limits, loss limits, session time limits)
• Implement self-exclusion requests and cooling-off periods
• Provide access to responsible gaming tools and support resources

4. Information Sharing and Disclosure

m11to does not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your data only in the following limited circumstances:

4.1 Service Providers and Business Partners

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

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay) to process deposits and withdrawals
• Gaming Providers: Pragmatic Play, Evolution Gaming, PG Soft, Microgaming, NetEnt, and other game studios to deliver gaming content
• Identity Verification Services: Third-party KYC providers for identity authentication and fraud prevention
• Customer Support Tools: Live chat software providers and communication platforms
• Technology Infrastructure: Hosting providers, cloud storage services, and IT support vendors

All service providers are contractually obligated to maintain confidentiality and use your data only for the specific purposes we authorize.

4.2 Legal Requirements and Protection of Rights

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

• Comply with legal obligations, court orders, or government requests
• Enforce our Terms & Conditions and other agreements
• Protect the rights, property, or safety of m11to, our users, or the public
• Detect, prevent, or investigate fraud, security breaches, or illegal activities
• Respond to claims that content violates the rights of third parties

4.3 Business Transfers

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

4.4 With Your Consent

We may share your information with third parties when you provide explicit consent for specific purposes not covered by this Privacy Policy.

5. Data Security Measures

m11to implements comprehensive technical and organizational security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. Our security infrastructure includes:

5.1 Encryption and Secure Transmission

• 256-bit SSL (Secure Socket Layer) encryption for all data transmitted between your device and our servers
• TLS (Transport Layer Security) protocols for secure communication
• End-to-end encryption for sensitive financial and identity data
• Encrypted data storage using AES-256 encryption standards

5.2 Access Controls and Authentication

• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Multi-factor authentication for administrative accounts
• Regular password rotation requirements for staff with data access
• Secure login protocols with protection against brute-force attacks

5.3 Infrastructure Security

• Firewalls and intrusion detection systems protecting server infrastructure
• Regular security audits and penetration testing by independent third parties
• 24/7 network monitoring and threat detection systems
• Secure data centers with physical access controls and environmental safeguards
• Redundant backup systems for data recovery in case of system failure

5.4 Employee Training and Policies

• Mandatory data protection training for all employees handling personal information
• Strict confidentiality agreements and non-disclosure obligations
• Clear data handling procedures and incident response protocols
• Regular security awareness updates and phishing simulation exercises

6. Data Retention

m11to retains your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal, regulatory, accounting, and reporting requirements.

6.1 Retention Periods

6.2 Deletion and Anonymization

After the applicable retention period expires, we will either delete your personal data or anonymize it so that it can no longer be associated with you. In cases where data must be retained for legal reasons but is no longer needed for operational purposes, we restrict access to that data and use it only for compliance purposes.

6.3 Inactive Accounts

If your m11to account remains inactive (no login or betting activity) for 12 consecutive months, we will send you a notification. If you do not reactivate your account within 30 days, we may close the account and begin the data retention countdown. You may request account closure at any time by contacting customer support.

7. Your Privacy Rights

As an m11to user, you have certain rights regarding your personal data. We are committed to facilitating the exercise of these rights. Depending on applicable law and your jurisdiction, your rights may include:

7.1 Right to Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of that data. You can access most of your account information directly through your m11to account dashboard. For additional information, contact our customer support team.

7.2 Right to Rectification

If your personal information is inaccurate or incomplete, you have the right to request correction. You can update your account details (email, phone number, address) directly in your account settings. For changes to KYC documents or other verified information, contact customer support with supporting documentation.

7.3 Right to Erasure ("Right to be Forgotten")

You may 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. However, this right is not absolute—we may need to retain certain information to comply with legal obligations, resolve disputes, or enforce our agreements.

7.4 Right to Restrict Processing

You have the right to request that we limit how we use your personal data in certain situations, such as when you contest the accuracy of the data or object to our processing.

7.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.

7.6 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes. You can opt out of marketing communications through your account settings or by clicking unsubscribe links in our emails. You may also object to processing based on legitimate interests by explaining your specific situation.

7.7 Right to Withdraw Consent

Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

7.8 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

• Email: [email protected] with subject line "Privacy Rights Request"
• Live Chat: Available 24/7 through your account dashboard
• Account Settings: Many rights can be exercised directly through your account interface

We will respond to your request within 30 days. We may require additional information to verify your identity before processing requests that involve access to or deletion of personal data.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us recognize your device, remember your preferences, and provide a better user experience. m11to uses both first-party cookies (set by us) and third-party cookies (set by our service providers).

8.2 Types of Cookies We Use

• Essential Cookies: Required for the website to function properly. These cookies enable core functionality such as security, account access, and payment processing. You cannot opt out of essential cookies.
• Performance Cookies: Collect information about how visitors use our website, such as which pages are visited most often. These cookies help us improve site performance and user experience.
• Functionality Cookies: Remember your preferences and choices (language, region, login details) to provide enhanced, personalized features.
• Advertising/Marketing Cookies: Track your browsing activity to deliver relevant promotional content and measure campaign effectiveness. These cookies may be set by us or third-party advertising partners.

8.3 Managing Cookie Preferences

Most web browsers allow you to control cookies through browser settings. You can:

• Block all cookies
• Delete existing cookies
• Set preferences to receive notifications when cookies are sent
• Accept cookies only from trusted sites

Please note that blocking or deleting cookies may impact your ability to use certain features of the m11to platform. Essential cookies are required for basic functionality and cannot be disabled if you wish to use our Services.

8.4 Other Tracking Technologies

In addition to cookies, we may use web beacons (also known as pixel tags), session replay tools, and similar technologies to collect usage data and improve our Services. These technologies operate similarly to cookies and are subject to the same controls.

9. Children's Privacy

m11to Services are strictly intended for adults aged 21 years and older, in accordance with Indonesian gambling age restrictions. We do not knowingly collect personal information from individuals under 21 years of age.

If we become aware that we have inadvertently collected personal data from someone under 21, we will take immediate steps to delete that information from our systems. If you believe a minor has provided us with personal information, please contact us immediately at [email protected].

Parents and guardians are encouraged to monitor their children's internet usage and prevent underage access to gambling websites. Consider using parental control software and restricting access to payment methods.

10. International Data Transfers

m11to operates internationally and may transfer your personal data to countries outside Indonesia for processing and storage. These countries may have data protection laws that differ from Indonesian laws.

When we transfer your data internationally, we ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy, including:

• Contractual agreements with service providers requiring them to protect your data
• Use of data processing facilities in countries recognized as providing adequate data protection
• Adherence to international data protection frameworks and standards

By using m11to Services, you consent to the transfer of your information to countries outside Indonesia for the purposes described in this Privacy Policy.

11. Changes to This Privacy Policy

m11to reserves the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you via email to your registered email address
• Display a prominent notice on our website
• For significant changes affecting your rights, request your renewed consent where required by law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of m11to Services after changes are made constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 through the m11to website
• WhatsApp: Contact details available in your account dashboard
• Customer Support Hours: 24/7 service in English and Indonesian (WIB timezone)

We strive to respond to all privacy inquiries within 7 business days. For urgent security concerns, please mark your communication as "URGENT" to receive priority handling.