Privacy Policy

1 Introduction

titi4 ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you — or that you provide to us — will be processed by us in connection with your use of the titi4 Platform at titi4.app.

titi4 is an internationally licensed online gaming platform serving players in Indonesia. Our operations are subject to the requirements of our international gaming licence, applicable anti-money laundering (AML) regulations, and internationally recognised data-protection standards. We treat compliance with these standards not as a legal formality but as a fundamental part of the trust relationship between titi4 and every player who registers with us.

This Policy explains: what personal data titi4 collects; why and how we use it; with whom it may be shared; how long we keep it; and what rights you hold over your information. If you have any questions about this Policy or about how titi4 handles your data, please contact us at [email protected].

2 Data We Collect

titi4 collects personal data in the following categories:

2.1 Registration & Account Data

When you create a titi4 Account via the titi4 Login page, we collect:

• Full legal name (as it appears on your government-issued ID);
• Date of birth (to verify the 21+ age requirement);
• Email address and Indonesian mobile phone number;
• Username and hashed password (passwords are never stored in plain text);
• Country and city of residence (e.g., Jakarta, Surabaya, Bandung, Bali);
• Preferred language and notification settings.

2.2 Identity Verification (KYC) Data

To comply with AML regulations and our responsible gaming obligations, we collect:

• Copies of government-issued photo identification (Indonesian KTP, passport, or driving licence);
• Proof of address documents (utility bills, bank statements from BCA, BRI, BNI, Mandiri, or similar);
• Proof of ownership of payment methods (screenshots of OVO, DANA, GoPay, ShopeePay, or bank account details showing your name);
• Selfie photographs where requested for enhanced identity confirmation.

2.3 Financial & Transaction Data

For every deposit and withdrawal processed in Indonesian Rupiah (IDR / Rp), we record:

• Transaction amount, date, time, and reference number;
• Payment method used (e.g., BCA bank transfer, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja);
• Bank account numbers or e-wallet identifiers associated with your Account;
• Account balance history and bonus credit/debit records.

titi4 does not store full card numbers or CVV codes. Payment instrument data is handled exclusively by our PCI-DSS compliant payment processing partners.

2.4 Gaming & Betting Activity Data

• All bets placed, game sessions initiated, and wagers settled — including Sportsbook bets on BRI Liga 1, EPL, Champions League, and mix parlay accumulators; live casino sessions; slot gacor spins; Bandar Ceme hands; and Online Poker activity;
• Promotion and bonus claims, wagering-requirement progress, and promotional eligibility history;
• Game preferences and session duration data used for responsible gaming monitoring.

2.5 Technical & Device Data

• IP address and approximate geolocation (city/region level);
• Device type, operating system, browser type and version;
• Session timestamps and page-interaction logs;
• Cookies and similar tracking technologies (see Section 6).

2.6 Communications Data

When you contact titi4 support via live chat or email, we retain a record of those communications — including the content of your messages, timestamps, and the resolution outcome — for quality assurance, dispute resolution, and training purposes.

3 How We Use Your Data

titi4 uses the personal data it collects for the following purposes:

Purpose	Data Categories Used
Account creation and management	Registration data, KYC data
Processing deposits and withdrawals in IDR	Financial & transaction data, KYC data
Providing gaming and sportsbook services	Gaming activity data, account data
Identity verification and age confirmation (21+)	KYC data, registration data
AML screening and fraud prevention	Financial data, technical data, KYC data
Responsible gaming monitoring and enforcement	Gaming activity data, session data
Customer support and dispute resolution	Communications data, account data, transaction data
Marketing communications (with consent)	Registration data, gaming preferences
Platform security and abuse prevention	Technical data, gaming activity data
Regulatory reporting and legal compliance	All categories as required

4 Legal Basis for Processing

titi4 processes your personal data on the following legal grounds, consistent with internationally recognised data-protection principles:

• Contractual necessity: Processing required to fulfil our obligations under the Account Agreement — including account registration, transaction processing, game provision, and customer support.
• Legal obligation: Processing required to comply with applicable AML regulations, KYC requirements under our gaming licence, and any lawful request from a competent regulatory authority.
• Legitimate interests: Processing necessary for platform security, fraud and abuse prevention, responsible gaming monitoring, and improving our services — where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for optional purposes — specifically, sending marketing communications by email or SMS — where we have obtained your prior, freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

5 Data Sharing

5.1 Service Providers. titi4 engages trusted third-party service providers who process personal data strictly on our behalf and under our instructions. These include:

• Payment processors and local bank integration partners facilitating IDR transactions via BCA, BRI, BNI, Mandiri, and e-wallets including OVO, DANA, GoPay, ShopeePay, and LinkAja;
• KYC and identity verification technology providers;
• Game content studios whose platforms are embedded in titi4 (e.g., Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Pocket Games Soft) — these studios process only the minimum data required to deliver their game services;
• Customer support platform providers;
• Cloud infrastructure and data hosting providers operating in jurisdictions with adequate data protection standards.

All service providers are bound by data-processing agreements that prohibit the use of your personal data for any purpose other than delivering the contracted service to titi4.

5.2 Regulatory Authorities. titi4 may disclose personal data to its gaming licence regulator, financial intelligence units, law-enforcement agencies, or courts where required to do so by law or where disclosure is necessary to protect the rights, property, or safety of titi4, its players, or the public.

5.3 Business Transfers. In the event of a merger, acquisition, or sale of all or a substantial part of titi4's assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and of any resulting changes to this Privacy Policy with reasonable advance notice.

5.4 No Commercial Sale. titi4 does not sell, rent, lease, or otherwise commercially transfer your personal data to any third party for that party's own marketing or commercial purposes.

6 Cookies & Tracking Technologies

titi4 uses cookies and similar technologies (including local storage, session tokens, and pixel tags) on the titi4 Platform. These technologies serve the following functions:

Cookie Type	Purpose	Can Be Disabled?
Essential	Session management, titi4 Login authentication, security tokens, fraud prevention	No — required for the Platform to function
Functional	Remembering language preferences, display settings, and game filters	Yes — via browser settings
Analytics	Understanding how players navigate the Platform; improving UX and performance	Yes — opt out in Account settings
Marketing	Delivering relevant promotional content to consenting players	Yes — withdraw consent in Account settings

You can manage cookie preferences through your browser settings at any time. Please note that disabling essential cookies will impair Platform functionality, including the titi4 Login process. For a full list of cookies in use on titi4.app, please contact [email protected].

7 Data Security

7.1 Technical Measures. titi4 implements robust technical security measures to protect your personal data, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and titi4 servers;
• AES-256 encryption for sensitive data fields stored at rest;
• Bcrypt hashing for all stored passwords — titi4 staff cannot retrieve your plain-text password;
• Web application firewall (WAF) and DDoS mitigation;
• Intrusion detection and security event monitoring (24/7);
• Regular independent penetration testing and vulnerability assessments.

7.2 Organisational Measures. Access to personal data within titi4 is restricted on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and receive regular data-protection training. Access logs are maintained and reviewed.

7.3 Data Breach Response. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, titi4 will notify affected players without undue delay — and in any event within 72 hours of becoming aware of the breach — providing details of the nature of the breach, the data affected, and the remedial steps taken.

7.4 Player Responsibility. While titi4 takes every reasonable measure to protect your data, the security of your Account also depends on your own actions. Please refer to Section 5 of the Terms & Conditions for your password and account security responsibilities.

8 Data Retention

titi4 retains personal data for no longer than is necessary for the purposes for which it was collected, subject to the following minimum retention periods required by our regulatory obligations:

• Account and KYC records: Retained for a minimum of five (5) years following permanent account closure, as required under AML regulations applicable to our gaming licence.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Gaming activity logs: Retained for three (3) years following account closure for responsible gaming audit purposes.
• Customer support communications: Retained for two (2) years following resolution of the relevant support case.
• Marketing preference records: Retained for the duration of your Account and for one (1) year following account closure as evidence of consent status.

Following the expiry of the applicable retention period, personal data is securely deleted from titi4 systems or irreversibly anonymised so that it can no longer be attributed to any identifiable individual.

9 Your Rights

Subject to applicable law and our regulatory obligations, you have the following rights in respect of the personal data titi4 holds about you:

• Right of Access: You may request a copy of all personal data titi4 holds about you.
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected. For account details, many fields can be updated directly via your Account dashboard.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations. Note that we are required by our gaming licence to retain certain records for five years and cannot fulfil erasure requests for those categories during the retention period.
• Right to Restriction: You may request that processing of your personal data be restricted in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: You may request a copy of personal data you have provided to titi4 in a commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests (including profiling for responsible gaming purposes) and to direct marketing at any time.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact the titi4 data team at [email protected]. We will acknowledge your request within 48 hours and provide a substantive response within 30 days. In complex cases, we may extend this period by a further 30 days and will inform you accordingly.

10 International Data Transfers

titi4 operates as an internationally licensed platform. Your personal data may be transferred to and processed in countries outside Indonesia — including the jurisdiction in which titi4 holds its gaming licence and the jurisdictions where our cloud infrastructure and service providers are located.

Whenever personal data is transferred outside Indonesia, titi4 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Privacy Policy. These safeguards include contractual data-transfer clauses, service-provider data-processing agreements, and, where applicable, the use of providers certified under internationally recognised data-protection frameworks.

11 Minors

The titi4 Platform is strictly for individuals aged 21 years or older. titi4 does not knowingly collect personal data from any person under the age of 21. If you are a parent or guardian and believe your child has provided personal information to titi4 without your consent, please contact us immediately at [email protected]. We will take prompt steps to delete that information and close any associated account.

titi4 strongly encourages parents and guardians to use appropriate parental-control software to prevent underage access to gambling websites, including titi4.app.

12 Third-Party Services

The titi4 Platform integrates third-party game content and services provided by studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft. When you launch a game provided by these studios, certain technical data (such as session tokens and game-round IDs) is exchanged with the relevant studio's servers. This data exchange is governed by the studio's own data-processing terms, which are subject to the data-processing agreements titi4 holds with each partner.

titi4 does not control, and is not responsible for, the privacy practices of any third-party websites that may be linked to or from the titi4 Platform. We strongly advise you to read the privacy policy of any external site you visit. Note that titi4 does not include outbound links to third-party websites in its standard site navigation.

13 Marketing Communications

13.1 Opt-In Requirement. titi4 will only send you promotional and marketing communications — including bonus offers, seasonal promotions (such as Idul Fitri reload bonuses, Ramadhan cashback campaigns, or Indonesian Independence Day prize draws), and product updates — if you have explicitly opted in to receive them during registration or subsequently via your Account settings.

13.2 Channels. Marketing communications may be sent by email and/or SMS to the contact details registered on your titi4 Account. We do not make unsolicited marketing telephone calls.

13.3 Withdrawal of Consent. You may unsubscribe from marketing communications at any time by:

• Clicking the "Unsubscribe" link in any marketing email;
• Updating your notification preferences in your titi4 Account settings; or
• Contacting [email protected] with an explicit unsubscribe request.

Withdrawal of marketing consent will be processed within 10 business days and will not affect your ability to continue using the titi4 Platform or receive transactional communications (such as deposit confirmations and withdrawal notifications).

14 Changes to This Privacy Policy

titi4 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or the services we offer. Material changes will be communicated to registered players by email to the address on file, no less than 14 days before the revised Policy takes effect. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision.

We encourage you to review this Privacy Policy periodically. Your continued use of the titi4 Platform following the effective date of any revision constitutes acceptance of the updated Policy. If you do not agree with any material change, you should cease using the Platform and request Account closure before the revised Policy takes effect.

15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way titi4 handles your personal data, please contact our data protection team through the following channels:

• Support Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please use "Privacy Request — [Your Username]" to ensure prompt routing to our data team.
• Live Chat: Available 24/7 via the titi4 Platform — average response time under 3 minutes.
• Operating Hours: 00:00–24:00 WIB (UTC+7) daily, including Indonesian public holidays.

titi4 aims to acknowledge all privacy-related enquiries within 48 hours and to resolve standard requests within 30 days. For complex matters — including formal erasure requests or data portability packages — we will keep you informed of progress and any applicable extension of the response timeline.