to178 is committed to protecting the privacy of every player on our platform. This Privacy Policy explains precisely what personal data we collect, how we use it, who we share it with, how long we retain it, and what rights you have over it as a player in Indonesia.
This Privacy Policy applies to all personal data processed by to178 in connection with the operation of the online betting and casino platform available at https://to178.app (the "Platform"). It covers all players, registered account holders, visitors who browse the Platform without registering, and individuals who contact to178 customer support.
By registering an account on to178, depositing funds, placing a wager, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with how to178 processes personal data, you should not use the Platform.
This Policy should be read alongside to178's Terms & Conditions and Responsible Gaming policy, both of which are incorporated by reference. In the event of any inconsistency between this Privacy Policy and the Terms & Conditions regarding data processing matters, this Privacy Policy takes precedence.
For the purposes of this Privacy Policy, the data controller responsible for the personal data of players registered on to178 is the entity operating the to178 platform under its international license. References to "to178", "we", "us", and "our" throughout this document refer to that entity.
to178 operates under international licensing and serves players on a cross-border basis. Players based in Indonesia access the platform subject to both to178's internal data governance standards and applicable international data protection principles. to178 is committed to implementing data protection safeguards consistent with internationally recognized privacy frameworks.
For all data-related inquiries, requests, and complaints, players may contact to178's data protection point of contact at [email protected] with the subject line "Data Protection Request."
to178 collects the following categories of personal data:
| Category | Specific Data Points |
|---|---|
| Identity Data | Full legal name, date of birth, government-issued identity document number, nationality, photographs provided for KYC verification. |
| Contact Data | Email address, mobile phone number, WhatsApp contact number, and — where provided — residential address. |
| Account Data | Username, hashed password, account registration date, account status, responsible gaming preferences, and communication preferences. |
| Financial Data | Bank account names and numbers (for bank transfer verification — BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OCBC NISP), e-wallet account identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction histories, deposit amounts, withdrawal amounts, and balance history — all denominated in IDR. |
| Transaction Data | Details of all bets placed, games played, outcomes, winnings, bonus transactions, and promotional activity on the Platform. |
| Technical Data | IP address, browser type and version, device type, operating system, screen resolution, time zone, session duration, pages visited, and click-path data. |
| Communications Data | Records of all communications with to178 customer support, including live chat transcripts, email correspondence, and WhatsApp messages. |
| KYC Documents | Copies of government-issued identity documents, selfie photographs, and proof of address documents submitted during identity verification. |
to178 does not collect special category data (such as health data, racial or ethnic origin, political opinions, or religious beliefs) and does not require the submission of such data at any stage of account registration or use.
to178 collects personal data through the following means:
to178 uses personal data for the following purposes:
to178 processes personal data on the following legal bases:
to178 may share personal data with the following categories of third parties, strictly for the purposes described in this Policy:
All third-party service providers who process personal data on behalf of to178 are bound by data processing agreements that require them to process data only on to178's documented instructions, implement appropriate security measures, and not use the data for any other purpose.
to178 operates as an international platform. Personal data may be transferred to and processed in countries outside Indonesia, including countries where data protection laws may differ from those in your jurisdiction. to178 ensures that any such international transfer of personal data is subject to appropriate safeguards, including:
to178 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to any longer retention period required by legal or regulatory obligation. The following indicative retention periods apply:
| Data Category | Retention Period |
|---|---|
| Account and identity data | Duration of account plus 5 years following account closure, to meet anti-money laundering record-keeping obligations. |
| Financial transaction records | 7 years from the date of each transaction, consistent with international financial record-keeping standards. |
| KYC documents | Duration of account plus 5 years following account closure. |
| Customer support records | 3 years from the date of the most recent support interaction. |
| Technical and usage logs | 13 months from the date of collection, after which logs are anonymized or deleted. |
| Marketing consent records | Until consent is withdrawn, plus 12 months following withdrawal to evidence compliance. |
Where data is no longer required for any of the purposes outlined above, to178 will securely delete or anonymize it.
to178 implements the following technical and organizational security measures to protect personal data against unauthorized access, disclosure, alteration, or destruction:
While to178 takes all reasonable steps to protect your personal data, no internet-based platform can guarantee absolute security. Players are responsible for maintaining the confidentiality of their account credentials and for notifying to178 immediately at [email protected] if they suspect unauthorized account access.
to178 uses cookies and similar tracking technologies to operate the Platform, maintain sessions, and analyze usage patterns. The following categories of cookies are used:
You may manage cookie preferences through your browser settings at any time. Disabling functional or analytics cookies will not affect your ability to use core Platform features. Disabling strictly necessary cookies may prevent you from logging in or placing bets.
to178 recognizes the following individual rights with respect to personal data. To exercise any of these rights, contact [email protected] with the subject line "Data Rights Request." to178 will acknowledge your request within 48 hours and respond substantively within 30 calendar days.
to178 will not charge a fee for exercising any data right unless the request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply. to178 reserves the right to request proof of identity before processing any data rights request to protect player security.
to178 uses age verification at the point of registration and KYC verification prior to withdrawal processing to enforce the 21+ age restriction. If you are a parent or guardian and believe that a minor under your care has registered on to178, please contact us immediately at [email protected] with the subject line "Underage Account Report." to178 will investigate and act within 24 hours of receiving such a report.
to178 reserves the right to update this Privacy Policy at any time. Where changes are material — for example, where to178 begins processing data for a new purpose, introduces a new category of data collection, or appoints a new category of third-party processor — to178 will provide not less than 14 days' advance notice by publishing the updated Policy on this page and, where appropriate, by notifying registered players by email.
The date shown in the "Last updated" field at the top of this page reflects the date on which the most recent version came into effect. Continued use of the Platform after the effective date of any updated Policy constitutes acceptance of the revised terms. Players who do not agree with any change are entitled to close their account before the change takes effect by contacting [email protected].
Minor updates — such as clarifications of existing language, correction of typographical errors, or updates to contact details — may be made without advance notice and will take effect upon publication.
For any questions, concerns, data rights requests, or complaints regarding this Privacy Policy or to178's data processing practices, please contact to178 through the following channels:
to178 will acknowledge all privacy-related contacts within 48 hours and provide a substantive response within 30 calendar days. Where a complaint remains unresolved after to178's internal process, you may escalate to a competent data protection authority or seek independent legal advice.
Six concrete commitments to178 makes to every player on how their personal data is handled.
to178 does not sell, rent, or trade personal data to any third party for commercial or marketing purposes. Your data is processed solely to operate the Platform and meet legal obligations — nothing more.
Every connection to the to178 Platform is secured with 256-bit SSL/TLS encryption. Financial data, KYC documents, and account credentials are encrypted both in transit and at rest using AES-256 standards.
You can request a copy of your data, correct inaccuracies, restrict processing, object to marketing, request deletion, or withdraw consent at any time — simply by emailing [email protected]. Responses within 30 calendar days, guaranteed.
to178 retains data only as long as legally required or operationally necessary. Technical logs are anonymized after 13 months. Financial records are retained for 7 years per international anti-money laundering standards, then deleted.
to178 never knowingly collects data from persons under 21 years of age. Age is verified at registration and at KYC. Any underage account is terminated and its data deleted within 24 hours of detection or report.
Every third-party service provider that handles player data on to178's behalf — from payment partners to game studios — is bound by a data processing agreement that restricts how they may use your information.
to178 protects your data with enterprise-grade security and gives you full control over how it is used. Explore the Platform knowing your privacy is in safe hands. Adults 21+ only. Please play responsibly.