Privacy Policy

1.Introduction

m11too ("we", "us", "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the m11too platform at https://m11too.cam (the "Platform"). This Privacy Policy sets out in detail how m11too collects, uses, stores, shares, and safeguards your personal information in connection with our sports betting, live casino, togel (Indonesia's traditional numbers lottery), and other gaming services.

This Policy applies to all current and former players, prospective players who browse or interact with the Platform without completing registration, and any individual who contacts m11too through our support channels. It applies in addition to, and should be read alongside, our Terms & Conditions.

We operate primarily in and for the Indonesian market. While our platform is written in English, our data practices are designed with the specific context of Indonesian players in mind, including the use of local banking partners such as BCA, BRI, BNI, Mandiri, and CIMB Niaga, and e-wallet providers including OVO, DANA, GoPay, ShopeePay, and LinkAja.

2.Definitions

3.Data We Collect

m11too collects the following categories of personal data, depending on your level of interaction with the Platform:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID.
• Date of birth (used to verify that you are at least 21 years of age).
• Residential address, including city (e.g., Jakarta, Surabaya, Bandung, Medan, Bali) and postal code.
• Email address and mobile phone number.
• Copies of identity documents submitted for KYC (e.g., KTP — Kartu Tanda Penduduk — or passport).

3.2 Financial Data

• Bank account numbers, account holder names, and bank names (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) associated with deposit or withdrawal transactions.
• E-wallet account identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Transaction history: deposit amounts, withdrawal requests, wager amounts, winnings, bonus credits — all denominated in Indonesian Rupiah (IDR / Rp).

3.3 Account & Gaming Activity Data

• Username, account registration date, and login history.
• Betting history: markets wagered on (including sports such as BRI Liga 1 matches, Champions League, and esports tournaments), bet amounts, outcomes, and bonus usage.
• Game session data: session duration, game titles played, session frequency.
• Responsible gaming preferences: deposit limits, self-exclusion elections, and session time-out settings.

3.4 Technical & Device Data

• IP address and geolocation data (country and city level).
• Device type, operating system, browser type and version.
• Referring URL and pages visited within the Platform.
• Cookie identifiers and session tokens (see Section 9).

3.5 Communications Data

• Records of live chat, email, and any other written communication you submit to our support team.
• Responses to surveys or feedback forms submitted voluntarily.

4.How We Collect Data

We collect your personal data through the following channels and mechanisms:

• Direct registration: Information you provide when creating your m11too account, completing KYC verification, or updating your profile.
• Platform usage: Data generated automatically when you log in, browse the Platform, place wagers, or interact with games.
• Payment transactions: Data shared by payment processors when you initiate deposits or withdrawals via local banks or e-wallets.
• KYC verification services: Identity data returned by our third-party KYC providers following document authentication.
• Customer support interactions: Communications you initiate via live chat, email, or other support channels.
• Cookies and tracking technologies: Automated collection of device and behavioral data as described in Section 9.
• Fraud prevention partners: Risk signals and flagged data from third-party anti-fraud and security monitoring services.

5.Purposes of Processing

m11too processes your personal data for the following specific purposes:

6.Legal Basis for Processing

m11too processes your personal data on one or more of the following legal grounds:

• Contractual necessity: Processing required to perform the contract between you and m11too — including account creation, payment processing, and service delivery.
• Legitimate interests: Processing necessary for our legitimate business interests — including fraud prevention, platform security, and analytics — where those interests are not overridden by your privacy rights.
• Legal obligation: Processing required to comply with applicable laws, regulatory requirements, or lawful government directives.
• Consent: Processing based on your freely given, specific, and informed consent — in particular, for marketing communications and optional analytics cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7.Data Sharing & Disclosure

m11too does not sell your personal data to third parties. We may, however, share your data with carefully selected third-party partners and service providers for the purposes described in this Policy:

7.1 Payment Processors

We share the minimum necessary financial and identity data with our Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals. These partners process data under their own privacy policies and are bound by applicable financial regulations.

7.2 KYC & Identity Verification Providers

Your identity documents and personal details are shared with certified third-party KYC service providers for the sole purpose of verifying your identity and age. These providers are contractually prohibited from using your data for any other purpose.

7.3 Game Software Providers

Session data and account identifiers are shared with our licensed game software partners — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — to the extent required to deliver their gaming products within the Platform environment.

7.4 Fraud Prevention & Security Partners

We work with specialist anti-fraud and cybersecurity providers who may process certain technical and behavioral data to detect and prevent fraudulent activity on our platform.

7.5 Legal & Regulatory Authorities

We may disclose personal data to law enforcement agencies, regulatory bodies, or courts when required to do so by applicable law, a valid legal order, or when we reasonably believe disclosure is necessary to protect the rights, property, or safety of m11too, our players, or the public.

8.International Data Transfers

As an internationally operating platform serving Indonesian players, some of your personal data may be transferred to and processed in countries outside Indonesia. This may occur when our game software providers, cloud infrastructure partners, or KYC service providers are located in different jurisdictions.

Where such transfers occur, m11too takes appropriate measures to ensure that your data receives an adequate level of protection consistent with this Privacy Policy. These measures may include contractual data protection clauses, data processing agreements, and where applicable, reliance on adequacy decisions or equivalent protective frameworks.

By using the m11too Platform, you acknowledge and consent to the transfer of your personal data to the jurisdictions of our operating and technology partners for the purposes described in this Policy.

9.Cookies & Tracking Technologies

m11too uses cookies and similar tracking technologies to improve your experience on the Platform. The following categories of cookies may be placed on your device:

You can control and manage cookies through your browser settings. Note that disabling certain cookies may impair the functionality of the Platform. Most modern browsers allow you to view, delete, and block cookies on a per-site basis. For detailed instructions, refer to your browser's help documentation.

10.Data Retention

m11too retains your personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable law and our operating obligations. Our standard retention periods are as follows:

• Active account data: Retained for the duration of your account relationship with m11too plus a minimum of 5 years following account closure, to meet audit and legal compliance requirements.
• KYC documents: Retained for a minimum of 5 years from the date of submission or from the date of account closure, whichever is later.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction, in accordance with anti-money laundering record-keeping requirements.
• Customer support communications: Retained for 3 years from the date of each communication, unless the subject matter requires longer retention for dispute resolution purposes.
• Marketing consent records: Retained for the duration of your consent status plus 1 year following withdrawal, to evidence compliance.
• Technical and device logs: Retained for up to 12 months on a rolling basis, unless specific logs are required for an active security investigation.

At the end of the applicable retention period, personal data is securely deleted or anonymized in accordance with our internal data lifecycle procedures.

11.Data Security

m11too implements industry-standard technical and organisational security measures to protect your personal data against unauthorized access, loss, alteration, disclosure, or destruction. Our security framework includes:

• SSL/TLS encryption: All data transmitted between your device and the m11too Platform is encrypted using Transport Layer Security (TLS) protocols.
• Access controls: Personal data is accessible only to authorised m11too personnel who require it to perform their legitimate job functions, on a strict need-to-know basis.
• Password security: Account passwords are stored using strong one-way hashing algorithms. We do not store your password in readable form.
• Regular security audits: Our platform and infrastructure undergo regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Incident response: We maintain a documented data breach response procedure. In the event of a breach that poses a risk to your rights, we will notify affected players within a reasonable timeframe.

12.Your Rights

Subject to applicable law, you hold the following rights in respect of your personal data held by m11too. To exercise any of these rights, please contact our Data Protection team using the details in Section 16.

• Right of access: You may request a copy of the personal data we hold about you, together with information about how it is being processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data held in your account or our records.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes it was collected, subject to our legal retention obligations.
• Right to restrict processing: You may request that we limit the processing of your data in certain circumstances — for example, while a dispute about its accuracy is resolved.
• Right to data portability: Where processing is based on your consent or a contract, you may request a copy of your data in a structured, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
• Right to object to marketing: You may opt out of receiving promotional communications at any time by contacting support or using the unsubscribe mechanism in any marketing email we send.

We will respond to all valid data rights requests within 30 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.

13.Minors & Age Policy

The m11too Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not register an account or use any m11too services.

As part of our KYC process, we verify the age of every player before withdrawal privileges are granted. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to close the relevant account, delete the collected data, and — where applicable — return any real-money balance to the payment method used for deposit.

If you believe that a minor has registered on the Platform, please notify us immediately at [email protected] so that we can take prompt action.

14.Third-Party Services

The m11too Platform may display content or functionality powered by third-party providers — including game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft, as well as payment infrastructure partners. Each of these third parties operates under its own privacy policy, and m11too is not responsible for their data practices.

We recommend that you review the privacy policies of any third-party service you interact with in connection with your use of the m11too Platform. If you have concerns about how a third-party provider handles your data, please contact that provider directly or raise the matter with our support team and we will assist where we are able to do so.

15.Policy Amendments

m11too reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, platform services, or applicable legal requirements. When material changes are made, we will notify active players via a prominent notice on the Platform or by email to the address registered on your account, at least 7 days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy. If you do not agree with the amended Policy, you should discontinue use of the Platform and may request account closure as set out in our Terms & Conditions.

16.Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact the m11too Data Protection team. Our 24/7 Indonesian-speaking customer support agents are available to assist with general enquiries, while privacy-specific requests will be escalated to our Data Protection Officer.

For responsible gaming concerns or to request account self-exclusion, please visit our dedicated Responsible Gaming page, where additional guidance and tools are available.