Privacy Policy — How sqtoto Protects Your Data

1. Introduction

sqtoto ("we," "our," "us," or the "Platform") operates the online betting and casino website located at sqtoto.cam. We are committed to handling the personal information of our Members, visitors, and prospective users (collectively, "you" or "Data Subjects") with transparency, integrity, and strict security practices.

This Privacy Policy (the "Policy") describes how sqtoto collects, stores, processes, and protects personal data in connection with your use of our services. It applies to all information collected through the sqtoto website, mobile interface, customer support channels, and any other medium through which you interact with us.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which form part of the overall agreement between you and sqtoto. By registering an Account or continuing to use sqtoto's services, you acknowledge that you have read and understood this Policy and consent to the collection and use of your data as described herein.

2. Definitions

For the purposes of this Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information that relates to an identified or identifiable natural person, including but not limited to name, email address, date of birth, national identity number, financial account details, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" refers to sqtoto, as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" refers to any third party that processes Personal Data on sqtoto's behalf, such as payment processors, cloud hosting providers, or analytics services.
• "Member" or "User" refers to any individual who has registered an Account on sqtoto or who accesses sqtoto's website and services.
• "KYC Data" refers to identity verification documents and information submitted by Members for the purpose of Know Your Customer compliance, including government-issued ID documents, proof of address, and selfie photographs.
• "Cookies" refers to small text files placed on your device by sqtoto's website to facilitate functionality, analytics, and session management.
• "Sensitive Data" refers to categories of Personal Data that warrant heightened protection, including financial data, identity documents, and information relating to health or vulnerability (e.g., responsible gaming assessments).

3. Information We Collect

sqtoto collects the following categories of Personal Data from Members and visitors:

3.1. Account Registration Data

When you create a sqtoto Account, we collect:

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Email address
• Mobile telephone number
• Residential address (including city, province, and postal code)
• Username and encrypted password
• Preferred currency (Indonesian Rupiah, IDR)

3.2. Identity Verification (KYC) Data

To comply with anti-money laundering (AML) regulations and to verify your age and identity, we collect:

• Copies of government-issued photo identification (KTP / Indonesian national identity card, passport, or driver's license)
• Proof of residential address (utility bills, bank statements, or official government correspondence dated within the last three months)
• Selfie photographs with the Member holding their identification document
• In certain cases, proof of source of funds (bank statements, employment records)

3.3. Financial and Transaction Data

When you make deposits or request withdrawals, we collect:

• Bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, and Bank Permata
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja account references)
• Transaction amounts, dates, and reference numbers
• Deposit and withdrawal history

3.4. Gaming and Betting Activity Data

As part of providing our services, we record:

• Bets placed, including game type, market, stake, and outcome
• Game session history (start/end times, duration, results)
• Bonus claims, wagering progress, and promotional participation
• Account balance history and transaction logs

3.5. Technical and Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Login timestamps and session identifiers
• Referral source (how you arrived at sqtoto.cam)
• Clickstream data (pages visited, buttons clicked, time spent)

3.6. Communications Data

• Records of all customer support interactions (chat transcripts, email correspondence)
• Feedback, complaints, and dispute records
• Responses to surveys or promotional communications (if you participate)

4. How We Collect Your Information

sqtoto collects your Personal Data through the following channels:

5. How We Use Your Information

sqtoto processes your Personal Data for the following purposes:

• Account Management: To create, maintain, and administer your Member Account, including authentication, password management, and account security.
• Service Delivery: To process bets, settle game outcomes, manage deposits and withdrawals via BCA, BRI, BNI, Mandiri, and supported e-wallets, and provide access to sqtoto's full game library.
• Identity Verification (KYC): To verify your identity, age (21+), and residential address in compliance with international AML and anti-fraud regulations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised Account access, money laundering, collusion, and other prohibited conduct.
• Bonus and Promotions Administration: To process bonus claims, track wagering requirements, and deliver promotional communications if you have opted in to receive them.
• Responsible Gaming: To monitor gambling patterns and, where appropriate, initiate responsible gaming outreach, enforce self-exclusion requests, or apply account-level deposit limits or session time-outs in accordance with our Responsible Gaming Policy.
• Customer Support: To respond to your enquiries, resolve complaints, and maintain records of all support interactions for quality assurance and dispute resolution purposes.
• Legal and Regulatory Compliance: To meet our obligations under applicable international gaming, AML, and data protection regulations, including retaining records as required by law.
• Platform Improvement: To analyse usage patterns and technical performance data, identify bugs, and impro ve the reliability, speed, and user experience of sqtoto's platform.

6. Legal Basis for Processing

sqtoto processes your Personal Data on the following legal bases:

• Contractual Necessity: Processing is required to perform the contract between you and sqtoto — specifically, to operate your Account, process bets, and handle deposits and withdrawals.
• Legal Obligation: Processing is necessary to comply with applicable AML regulations, age verification requirements, and record-keeping obligations imposed by international gaming authorities.
• Legitimate Interests: sqtoto has a legitimate interest in preventing fraud, protecting platform security, improving our services, and detecting responsible gaming concerns, provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we rely on your consent — for example, to send promotional communications or to use non-essential cookies — you may withdraw that consent at any time by contacting [email protected] or adjusting your cookie preferences.

7. Information Sharing and Disclosure

sqtoto does not sell, rent, or trade your Personal Data to any third party. We may, however, share your information with the following categories of recipients where strictly necessary:

7.1. Payment Processors and Financial Partners

To facilitate deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja, we share transaction-specific data (account holder name, account number, and transaction amount) with the relevant financial institution or payment gateway. These partners process this data solely to execute the requested transaction and are bound by their own confidentiality and regulatory obligations.

7.2. KYC and Identity Verification Partners

We may engage authorised third-party identity verification services to assist with KYC processing. Any KYC partner engaged by sqtoto is subject to strict data processing agreements and is prohibited from using your identity data for any purpose other than the verification service they have been engaged to perform.

7.3. Game Software Providers

sqtoto partners with game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft to deliver our game library. These providers may receive anonymised session data (game ID, stake amount, outcome) to facilitate game delivery, RNG audits, and jackpot processing. Personal identifiers are not shared with game providers.

7.4. Legal and Regulatory Authorities

sqtoto may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts if required to do so by applicable law, court order, or regulatory directive. We will take reasonable steps to notify affected Members of such disclosure requests unless prohibited from doing so by law.

7.5. Professional Advisers

We may share limited Personal Data with our legal counsel, auditors, accountants, and insurers where necessary for the provision of professional services to sqtoto, subject to confidentiality obligations.

8. International Data Transfers

sqtoto operates as an internationally licensed platform and may process or store your Personal Data on servers located outside of Indonesia. Where data is transferred to countries that do not offer an equivalent level of data protection, sqtoto implements appropriate safeguards to ensure your data remains protected, including:

• Data processing agreements with contractual clauses ensuring data protection standards equivalent to those in this Policy
• End-to-end encryption of data in transit and at rest
• Access controls limiting data access to authorised personnel only
• Regular security audits of third-party data processors

By using sqtoto's services, you acknowledge and consent to the transfer of your Personal Data to sqtoto's servers and authorised processors, which may be located outside Indonesia, subject to the safeguards described above.

9. Data Retention

sqtoto retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply as a general guide:

Upon the expiry of the applicable retention period, sqtoto will securely delete or anonymise your Personal Data so that it can no longer be associated with you individually. Where data is anonymised, it may be retained indefinitely for statistical and analytical purposes.

10. Data Security

sqtoto employs a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, alteration, disclosure, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS 1.3 encryption for all data transmitted between your device and sqtoto's servers
• AES-256 encryption at rest for all stored Personal Data and KYC documents
• Certified Tier-3 data centres with physical access controls, 24/7 monitoring, and redundant connectivity
• Role-based access controls ensuring that only authorised staff can access specific categories of Personal Data
• Regular penetration testing and vulnerability assessments conducted by independent security specialists
• Multi-factor authentication (MFA) for all internal administrative systems
• Automated anomaly detection systems that flag unusual login patterns, large transactions, or other security indicators in real time

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, sqtoto will notify affected Members promptly and take all reasonable steps to contain and remediate the breach.

You also play an important role in keeping your Account secure. You are responsible for maintaining the confidentiality of your login credentials and for notifying sqtoto immediately if you suspect that your Account has been accessed without your authorisation.

11. Cookies and Tracking Technologies

sqtoto uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device by your browser when you visit sqtoto.cam. We use the following categories of cookies:

sqtoto does not use third-party advertising or behavioural tracking cookies. You can manage or delete cookies through your browser settings. Please note that disabling strictly necessary or security cookies may impair your ability to log in or use certain features of the Platform.

12. Your Privacy Rights

As a Member of sqtoto, you have the following rights in relation to your Personal Data. To exercise any of these rights, please contact us at [email protected]:

• Right of Access: You have the right to request a copy of the Personal Data sqtoto holds about you, along with information about how it is being processed.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure ("Right to be Forgotten"): You may request that sqtoto delete your Personal Data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. This right is subject to our legal data retention obligations, which may require us to retain certain records for specified periods even after Account closure.
• Right to Restriction of Processing: You may request that we restrict processing of your Personal Data in certain circumstances, such as while a dispute is being investigated.
• Right to Data Portability: You have the right to receive a copy of your Personal Data in a structured, commonly used, machine-readable format, and to transmit that data to another service provider where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Object: You have the right to object to processing based on legitimate interests, including direct marketing (if applicable).

sqtoto will respond to all valid data rights requests within 30 calendar days of receipt. In complex cases, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it. We may request proof of identity before fulfilling any data rights request to ensure that we do not disclose data to unauthorised parties.

13. Minors and Age Restriction

sqtoto's services are strictly intended for adults aged 21 and above. We do not knowingly collect Personal Data from individuals under the age of 21. If you are under 21 years of age, you must not register an Account or attempt to use sqtoto's services.

If sqtoto becomes aware that a Member's Account is held by an individual under the age of 21, the Account will be suspended immediately, all associated funds will be forfeited, and any Personal Data collected in connection with that Account will be securely deleted as soon as practicable. If you are a parent or guardian and believe that a person under your care has registered an Account on sqtoto, please contact us immediately at [email protected].

14. Changes to This Policy

sqtoto reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or the services we offer. When we make material changes to this Policy, we will update the "Last Updated" date at the top of this page and, where the changes significantly affect your rights or how we handle your data, we will notify you by email or by displaying a notice on the Platform.

We encourage you to review this Policy periodically to stay informed about how sqtoto protects your Personal Data. Your continued use of sqtoto's services following the posting of any updated Policy constitutes your acknowledgement and acceptance of the changes.

15. Contact and Data Requests

If you have any questions, concerns, or requests relating to this Privacy Policy or your Personal Data, please reach out to sqtoto's support team. We are committed to responding to all privacy-related enquiries promptly and professionally.