Privacy Policy — tores4

1.1  tores4 ("we," "us," "our," or "the Platform") operates the online betting and gaming platform accessible at https://tores4.cam. This Privacy Policy describes our practices regarding the collection, use, storage, sharing, and protection of personal data in connection with your use of our Services, including sports betting (covering BRI Liga 1 fixtures, EPL, Champions League, and other global leagues), live casino, togel (Indonesia's traditional numbers-prediction lottery) markets, slots, and all other gaming products offered on the platform.

1.2  This Privacy Policy applies to all individuals who access or use the tores4 platform, including registered members, visitors who browse without registering, and prospective members who begin but do not complete the registration process.

1.3  This policy should be read together with our Terms & Conditions, which govern your use of the platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on a data privacy matter, this Privacy Policy shall prevail.

Throughout this Privacy Policy, the following terms carry the meanings defined below:

3.1  Registration & Identity Data: When you create a tores4 account, we collect your full legal name, date of birth, residential address (including city — e.g., Jakarta, Surabaya, Bandung, Bali, Yogyakarta, Medan, Semarang, Palembang, or Makassar), email address, and mobile phone number.

3.2  Verification Documents (KYC): To comply with age-verification and anti-money-laundering obligations, we collect copies of government-issued identity documents such as your Indonesian National Identity Card (KTP), passport, or driver's license, and may request a selfie or proof-of-address document.

3.3  Financial Data: We collect bank account details, e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction records necessary to process deposits, withdrawals, and bonus payments in Indonesian Rupiah (IDR). We do not store full payment card numbers on our servers.

3.4  Behavioral & Usage Data: We collect information about how you use the platform, including pages visited, games played, bet amounts, session duration, device type, operating system, browser type, and IP address.

3.5  Communications Data: We retain records of your communications with our support team (via email or live chat), including the content of messages and their timestamps, to ensure quality assurance and resolve disputes.

3.6  Responsible Gaming Data: If you use our responsible gaming tools — such as deposit limits, session limits, or self-exclusion — we record these preferences and their effective dates to enforce your chosen restrictions accurately.

tores4 collects personal data through the following channels:

• Directly from you: Information you provide during registration, KYC submission, deposit/withdrawal requests, customer support interactions, or when completing any other form or request on the platform.
• Automatically via technology: Cookies, web beacons, server logs, and similar tracking technologies collect usage and device data as you interact with the platform (see Clause 10 for full cookie details).
• From payment providers: When you initiate a transaction via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, or LinkAja, our payment processors share transaction confirmation data with us.
• From identity verification providers: Third-party KYC vendors may share the results of identity checks, including document authenticity assessments and age-verification outcomes.
• From fraud prevention and security providers: We may receive risk-scoring data from third-party fraud detection services to protect the platform and its members from fraudulent activity.

tores4 processes your personal data for the following purposes:

6.1  Under applicable data protection principles, tores4 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions) and to provide the Services you have requested. This includes account registration, transaction processing, KYC verification, and service delivery.
• Legal Obligation: Processing is required to comply with legal or regulatory obligations, including age verification, anti-money-laundering checks, tax reporting, and responding to lawful authority requests.
• Legitimate Interests: Processing is necessary for our legitimate business interests — or those of a third party — provided those interests are not overridden by your data protection rights. Legitimate interests include fraud prevention, network security, platform optimization, and direct marketing to existing customers.
• Consent: Where processing does not fall under the above grounds, we rely on your explicit consent. You may withdraw consent at any time by contacting our support team, though withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

6.2  Where we process your data on the basis of legitimate interests, you have the right to object to such processing (see Clause 11 below).

7.1  tores4 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following circumstances:

• Payment Processors: Bank and e-wallet providers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, LinkAja) and their intermediaries, to process deposits and withdrawals.
• Identity Verification Providers: Third-party KYC vendors that perform age and identity verification on our behalf.
• Game Content Providers: Studios such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft receive minimal session data (username, bet amounts, game outcomes) necessary to deliver their games on the platform.
• Fraud Prevention & Security Services: Specialized anti-fraud vendors that analyze transaction patterns and detect suspicious activity to protect the platform and its members.
• Cloud Infrastructure Providers: Hosting and server infrastructure providers that store data on our behalf under strict confidentiality and security agreements.
• Legal & Regulatory Authorities: Where required by law or by binding court order, we may disclose personal data to law enforcement, tax authorities, gaming regulators, or other governmental bodies.
• Professional Advisors: Legal, financial, and technical advisors engaged by tores4, subject to confidentiality obligations.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of our business, your data may be transferred to the successor entity, subject to this Privacy Policy's protections.

7.2  All third-party processors are contractually bound to process your data only in accordance with our instructions and to implement appropriate security measures. They may not use your data for their own purposes.

8.1  tores4 operates internationally and serves customers in Indonesia. The personal data we collect may be transferred to, stored at, and processed in countries outside Indonesia, including jurisdictions where data protection laws may differ from those in Indonesia.

8.2  Where we transfer personal data outside Indonesia, we ensure that adequate safeguards are in place. These safeguards include standard contractual clauses approved by relevant data protection authorities, binding corporate rules, or reliance on jurisdictions deemed to provide adequate data protection.

8.3  By using the tores4 platform, you acknowledge and consent to the international transfer of your personal data as described in this clause, subject to the safeguards outlined above.

9.1  tores4 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.

9.2  Specific retention periods include:

• Account Data: Retained for the duration of your active membership and for seven (7) years following account closure to comply with anti-money-laundering and tax reporting obligations.
• Transaction Records: Retained for a minimum of seven (7) years to satisfy regulatory record-keeping requirements.
• KYC Documents: Retained for seven (7) years following your last transaction on the platform.
• Customer Support Communications: Retained for three (3) years to resolve any subsequent disputes or quality assurance reviews.
• Marketing Consent Records: Retained for as long as you remain subscribed to marketing communications, and for one (1) year following opt-out to honor your preference.
• Self-Exclusion Records: Retained permanently to prevent future account re-opening during the exclusion period and to maintain a responsible gaming audit trail.

9.3  After the applicable retention period expires, your personal data will be securely deleted or anonymized such that it can no longer identify you.

10.1  tores4 uses cookies and similar tracking technologies (web beacons, local storage, device identifiers) to enhance your experience, maintain session integrity, analyze platform performance, and deliver personalized content.

10.2  The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the operation of the platform. These cookies enable you to log in, navigate securely, and access member-only areas. They cannot be disabled without severely affecting platform functionality.
• Performance Cookies: Collect aggregated, anonymized information about how visitors use the platform — such as which pages are most visited and whether error messages are encountered — to help us improve performance.
• Functionality Cookies: Remember your preferences (e.g., language selection, odds format, time-zone display) and provide enhanced, personalized features.
• Targeting/Advertising Cookies: Used to deliver relevant promotional content and measure the effectiveness of marketing campaigns. We do not deploy third-party behavioral advertising networks without your explicit consent.

10.3  You may configure your browser to refuse all or some cookies, or to alert you when cookies are being set. However, if you disable strictly necessary cookies, some parts of the platform may become inaccessible or function improperly.

10.4  Most browsers allow you to manage cookie preferences through their settings menu. For detailed guidance, please consult your browser's help documentation.

11.1  Subject to applicable law, you hold the following rights in relation to your personal data:

11.2  To exercise any of these rights, please contact our data protection officer at support@tores4.cam with "Privacy Rights Request" in the subject line. We will respond to all verified requests within thirty (30) calendar days, or will notify you if we require additional time.

11.3  We may require proof of identity before processing your request to ensure we do not disclose personal data to unauthorized individuals.

12.1  tores4 strictly enforces a minimum age requirement of 21 years. The platform is intended exclusively for adults. We do not knowingly collect personal data from individuals under the age of 21.

12.2  If we become aware that we have inadvertently collected personal data from an individual under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any deposits made will be returned to the payment source; winnings will be forfeited.

12.3  Parents and guardians are encouraged to monitor the online activities of minors under their care and to use parental control software to prevent access to age-restricted platforms.

13.1  tores4 implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or damage. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encrypted storage of sensitive data at rest, including passwords (which are hashed using bcrypt or equivalent algorithms) and financial information.
• Multi-factor authentication for internal staff access to member data, with all access logged and audited.
• Regular penetration testing and vulnerability assessments conducted by independent third-party security firms.
• Strict access controls ensuring that only authorized personnel with a verified business need can access identifiable member data.
• Regular staff training on data protection principles and secure data handling practices.
• Incident response procedures to detect, investigate, and remediate security breaches promptly.

13.2  While we take all reasonable precautions to protect your data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you acknowledge that you provide personal data at your own risk.

13.3  In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and will report the breach to relevant supervisory authorities as required by law.

14.1  The tores4 platform may contain links to third-party websites, services, or applications (including payment providers and game studios). This Privacy Policy applies only to tores4's own data practices and does not extend to any third-party sites.

14.2  We are not responsible for the privacy practices or content of third-party websites. When you leave the tores4 platform, we encourage you to read the privacy policies of any third-party sites you visit.

14.3  Third-party game providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft) may set their own cookies or collect usage data when you play their games on our platform. Such data collection is governed by the respective provider's privacy policy, not by this document.

15.1  tores4 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features.

15.2  When we make material changes to this policy, we will notify you by updating the "Last Updated" date at the top of this page and, where appropriate, by posting a prominent notice on the platform homepage or by sending an email to your registered email address.

15.3  Your continued use of the tores4 platform following notification of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the updated terms, you must discontinue use of the platform and may request account closure.

15.4  We recommend that you review this Privacy Policy periodically to stay informed about how we are protecting your data.

16.1  If you have any questions, concerns, or complaints regarding this Privacy Policy or our data processing practices, or if you wish to exercise any of your privacy rights, please contact the tores4 data protection team:

16.2  Our data protection officer is responsible for overseeing compliance with this Privacy Policy and applicable data protection law. You have the right to contact our data protection officer directly with any privacy concern.

16.3  If you are not satisfied with our response to your privacy complaint, you have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction. We encourage you to contact us first so that we may attempt to resolve your concern directly.