Privacy Policy

1 Definitions

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

• "tum123," "We," "Us," or "Our" refers to the internationally licensed operating entity that owns and operates the tum123 platform accessible at https://tum123.cam.
• "Platform" means the tum123 website, mobile-optimized interface, and all associated services, features, and functionality.
• "You" or "User" means any individual who accesses, browses, registers on, or uses the Platform, including registered Members and unregistered visitors.
• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly — including name, date of birth, email address, phone number, device identifiers, and transaction records.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transfer, or deletion.
• "KYC" (Know Your Customer) means the identity and document verification process required by tum123 to confirm a Member's identity, age, and eligibility prior to processing withdrawals or at tum123's discretion.
• "Cookies" means small text files placed on your device by the Platform to facilitate session management, analytics, and personalization.
• "Third-Party Processors" means external service providers engaged by tum123 to assist in delivering Platform services — including payment processors, identity verification providers, and hosting infrastructure providers — who process Personal Data on tum123's behalf.

2 Scope & Application

2.1 This Privacy Policy applies to all Personal Data collected, processed, or stored by tum123 in connection with the operation of the Platform and the provision of betting, gaming, and customer support services to Users.

2.2 This policy covers Users who access the Platform from Indonesia and all other jurisdictions where tum123 makes its services available. Where applicable local data protection law imposes additional obligations on tum123, those obligations will be observed in respect of Users in that jurisdiction.

2.3 This policy does not apply to third-party websites or services that may be linked from the Platform. tum123 is not responsible for the privacy practices of any third-party website, and you should review the privacy policies of those sites independently.

2.4 By using the Platform, you confirm that you are at least 21 years of age and that you have the legal capacity to consent to the processing of your Personal Data as described in this policy.

3 Data We Collect

3.1 tum123 collects the following categories of Personal Data from Users:

3.2 tum123 does not intentionally collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, or health data. If any such data is incidentally disclosed in communications with our support team, it will not be recorded or used for any purpose beyond resolving the relevant support query.

4 How We Collect Data

4.1 Directly from You. The majority of Personal Data we hold is provided by you directly through: account registration, KYC document submission, payment processing forms, customer support communications, and any feedback or survey responses you voluntarily submit.

4.2 Automatically. When you access the Platform, certain Technical Data and Usage Data are collected automatically through server logs, session cookies, and analytics integrations. This data is collected regardless of whether you are a registered Member or an unregistered visitor.

4.3 Third-Party Sources. tum123 may receive Personal Data about you from third-party sources in limited circumstances, including:

• Identity verification providers — to cross-check the accuracy of KYC documents you submit.
• Payment processors — to confirm successful deposit or withdrawal transactions and flag potentially fraudulent payment activity.
• Fraud prevention and AML screening services — to meet our regulatory compliance obligations.

4.4 tum123 does not purchase Personal Data lists from data brokers or marketing list providers.

5 Purpose of Processing

5.1 tum123 processes your Personal Data for the following specific purposes:

• Account Management: To create, maintain, and administer your tum123 Member account, including authentication and account security.
• Service Delivery: To process bets, settle winnings, execute deposits and withdrawals in IDR, and provide access to all Platform features — including football sportsbook markets, togel (Indonesia's traditional numbers lottery) markets, live casino, and slot games.
• KYC & Age Verification: To verify that you are at least 21 years of age and eligible to use the Platform, and to fulfill our legal identity verification obligations.
• Fraud Prevention & Security: To detect, investigate, and prevent unauthorized access, money laundering, bonus abuse, and other fraudulent or illegal activity on the Platform.
• Regulatory Compliance: To comply with applicable AML, counter-terrorism financing (CTF), and other regulatory obligations, including maintaining records of transactions and identity documents as required by law.
• Customer Support: To respond to your inquiries, resolve disputes, process complaints, and improve our support service quality.
• Platform Improvement: To analyze usage patterns, diagnose technical issues, and develop new features and service enhancements based on aggregated behavioral data.
• Personalization: To tailor the Platform experience to your preferences, including displaying relevant promotions and recommending game categories based on your activity history.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates via email or SMS — strictly only where you have opted in to receive such communications.

5.2 tum123 will not process your Personal Data for any purpose not listed above without first obtaining your explicit consent or establishing a new lawful basis for such processing.

6 Legal Basis for Processing

6.1 tum123 processes Personal Data under the following legal bases:

• Contractual Necessity: Processing required to fulfill our obligations to you under the tum123 Terms & Conditions — including account creation, bet processing, payment execution, and KYC verification — is carried out on the basis that it is necessary for the performance of the contract between us.
• Legal Obligation: Processing required to comply with applicable laws and regulations — including AML/CTF record-keeping, identity verification, and fraud reporting obligations — is carried out on the basis of legal compliance.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, abuse detection, and internal analytics is based on tum123's legitimate interest in operating a secure, fair, and financially sound platform. We conduct a balancing assessment to ensure our legitimate interests do not override your fundamental rights.
• Consent: Processing for direct marketing communications (promotional emails and SMS) and the placement of non-essential cookies is based on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

7.1 tum123 does not sell, rent, or license your Personal Data to any third party for their own commercial purposes. Data sharing is limited to the following categories of recipients and circumstances:

• Third-Party Processors: Service providers engaged by tum123 to assist in delivering Platform services, including payment processors (handling IDR transactions via BCA, BRI, BNI, Mandiri, OVO, DANA, and other local channels), identity verification providers, cloud hosting and infrastructure providers, and customer support platform operators. All Third-Party Processors are bound by data processing agreements and may only process your data on tum123's documented instructions.
• Regulatory & Law Enforcement Authorities: tum123 may disclose Personal Data to governmental, regulatory, or law enforcement authorities where required to do so by applicable law, valid legal process, or a binding regulatory directive — including AML/CTF reporting obligations.
• Fraud Prevention Networks: In cases of suspected fraud, account manipulation, or money laundering, tum123 may share relevant account and transaction data with industry fraud prevention databases and screening services to protect the integrity of the Platform.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of tum123's business, your Personal Data may be transferred to the acquiring entity as part of the transaction, subject to appropriate confidentiality protections. You will be notified of any such transfer in advance where practicable.

7.2 In all cases where Personal Data is shared with third parties, tum123 takes reasonable steps to ensure that appropriate contractual, technical, and organizational safeguards are in place to protect your data.

8 Data Retention

8.1 tum123 retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following indicative retention periods apply:

8.2 Where Personal Data is no longer required and no legal obligation requires its continued retention, tum123 will securely delete or irreversibly anonymize that data.

9 Security Measures

9.1 tum123 implements a layered set of technical and organizational security measures designed to protect Personal Data against unauthorized access, accidental loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between User devices and tum123 servers.
• Encryption or hashing of sensitive data fields at rest, including passwords and payment account identifiers.
• Access controls and role-based permission systems limiting internal access to Personal Data to authorized personnel with a legitimate operational need.
• Regular security audits and penetration testing conducted by qualified third-party security specialists.
• Intrusion detection and monitoring systems operating continuously to identify and respond to anomalous access patterns.
• Incident response procedures providing for prompt investigation and notification in the event of a data breach.

9.2 While tum123 takes all reasonable precautions to protect your Personal Data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the security of your account credentials and for notifying tum123 immediately if you suspect unauthorized access to your account.

9.3 In the event of a Personal Data breach that poses a high risk to your rights and freedoms, tum123 will notify affected Users without undue delay, providing information about the nature of the breach, the data affected, and the steps we are taking to address it.

10 Cookies & Tracking Technologies

10.1 tum123 uses cookies and similar technologies (including local storage and session tokens) to operate the Platform and improve your user experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, load-balancing cookies, and security cookies. These cannot be disabled without impairing Platform functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymized data about how Users interact with the Platform — including pages visited, time on page, and error events — to help tum123 identify and fix issues and improve the overall experience.
• Functionality Cookies: Used to remember your preferences within the Platform, such as language settings and account region, so that you do not need to re-enter them each visit.
• Marketing & Targeting Cookies: Used only where you have provided explicit consent, to identify your engagement with promotional content and measure the effectiveness of marketing campaigns. tum123 does not use cookies to track your activity on third-party websites outside the Platform.

10.2 You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use the Platform. Disabling analytics or marketing cookies will not impair core Platform functionality.

10.3 tum123 does not use fingerprinting techniques or other covert tracking methods beyond those described in this clause.

11 Your Data Rights

11.1 Subject to applicable law and certain limitations, you have the following rights in respect of your Personal Data held by tum123:

• Right of Access: You may request a copy of the Personal Data tum123 holds about you, together with information about how it is being processed.
• Right to Rectification: You may request that inaccurate or incomplete Personal Data be corrected or updated. For account details, many fields can be updated directly through your account settings.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data in certain circumstances — for example, where the data is no longer needed for the purpose for which it was collected. This right is subject to tum123's legal retention obligations under AML/CTF regulations, which may require us to retain certain data for up to five years post-account closure regardless of any erasure request.
• Right to Restriction of Processing: You may request that tum123 restrict the processing of your Personal Data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, you may request that tum123 provide your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of tum123's legitimate interests. tum123 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.

11.2 To exercise any of the above rights, please contact tum123 at [email protected]. We will respond to your request within 30 days of receipt. In cases of complexity or high volume, this period may be extended by a further 60 days, and we will notify you of any such extension.

11.3 tum123 will not charge a fee for processing data rights requests unless requests are manifestly unfounded or excessive, in which case a reasonable administrative fee may be applied.

12 Minors

12.1 The tum123 Platform is strictly intended for adults aged 21 and over. tum123 does not knowingly collect Personal Data from any person under the age of 21.

12.2 Age is verified during the registration process and again during KYC verification. Where tum123 discovers that Personal Data has been collected from a person under 21 — whether through a false declaration at registration or otherwise — that account will be immediately closed, all associated data will be deleted (subject to any applicable legal retention obligation), and any winnings will be voided.

12.3 Parents and guardians are encouraged to make use of parental control software to restrict access to gambling websites. If you believe your child has registered on the tum123 platform, please contact us immediately at [email protected] and we will take prompt action.

13 International Data Transfers

13.1 tum123 operates as an internationally licensed platform, and as a result, your Personal Data may be transferred to, stored in, or processed in jurisdictions outside Indonesia. Where such transfers occur, tum123 takes steps to ensure that appropriate safeguards are in place to protect your data to a standard at least equivalent to the protections described in this policy.

13.2 Safeguards for international data transfers may include: contractual clauses requiring the recipient to protect Personal Data to an equivalent standard; processing only in jurisdictions recognized as providing adequate data protection; or obtaining your explicit consent to the transfer where required.

13.3 By using the tum123 Platform, you acknowledge and agree to the transfer of your Personal Data as described in this clause, subject to the safeguards described above.

14 Policy Amendments

14.1 tum123 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. When material changes are made, the revised policy will be published on the Platform with an updated effective date.

14.2 Where a change materially affects how we process your Personal Data, tum123 will provide reasonable advance notice via email to your registered address, where practicable. Your continued use of the Platform after the revised policy's effective date constitutes your acceptance of the updated terms.

14.3 The current version of this Privacy Policy is always accessible at https://tum123.cam/privacy-policy. We recommend that you review this page periodically.

15 Contact Us

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by tum123, please contact our Data Privacy team using the details below:

15.2 For requests to exercise your data rights under clause 11, or to report a suspected data breach affecting your account, please use the same contact address and include "Privacy Request" or "Data Breach Report" in the subject line so that your message reaches the appropriate team promptly.

15.3 For matters relating to account closure or self-exclusion, please also refer to our Responsible Gaming page. For general platform terms and eligibility queries, see our Terms & Conditions.