Privacy Policy

Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person — including but not limited to name, email address, phone number, date of birth, national identity number, financial details, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, or deletion.
• "Data Controller" means dor123, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of dor123 under a contractual data processing agreement.
• "Member" means any individual who has registered an account on the dor123 platform.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement to the processing of Personal Data for one or more specified purposes.
• "AML" means Anti-Money Laundering — the regulatory framework requiring financial service providers to identify customers and monitor transactions to prevent financial crime.
• "KYC" means Know Your Customer — the process of verifying the identity of a Member using government-issued identification documents and proof of address.

Data We Collect

dor123 collects the following categories of Personal Data in the course of providing its services:

dor123 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information, except where strictly required by applicable AML regulations and only to the extent necessary for compliance purposes.

How Data Is Collected

dor123 collects Personal Data through the following channels:

• Direct Submissions: Data you actively provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting our support team, or participating in promotions.
• Automated Technologies: Data collected automatically when you access the platform, including through cookies, web beacons, server logs, and analytics tools. This includes Technical Data such as IP addresses, browser fingerprints, and session activity.
• Third-Party Sources: Data received from payment processors (such as BCA, OVO, and GoPay) to confirm transaction status; from identity verification service providers used to support KYC checks; and from fraud-detection partners who help dor123 identify suspicious account activity.
• Publicly Available Sources: In limited circumstances, dor123 may cross-reference publicly available information — such as sanctions lists or politically exposed persons (PEP) registers — as part of our AML compliance obligations.

Purpose of Processing

dor123 processes your Personal Data for the following clearly defined purposes:

• Account Management: To create, maintain, and manage your Member account, including authentication, security monitoring, and account recovery.
• Service Delivery: To provide sports betting, live casino, slot gaming, togel (Indonesia's traditional numbers lottery), and other platform services that you access as a registered Member.
• Financial Transactions: To process deposits and withdrawals via Indonesian Rupiah (IDR) payment channels including local bank transfers and e-wallets, and to maintain accurate financial records.
• KYC and AML Compliance: To verify Member identity and age in accordance with international anti-money-laundering regulations and responsible gaming obligations, including the 21+ age restriction enforced by dor123.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, multi-accounting, and other policy violations.
• Customer Support: To respond to support enquiries, resolve disputes, and maintain records of communications for quality assurance and compliance purposes.
• Responsible Gaming: To monitor betting patterns for signs of problem gambling and to implement self-exclusion, deposit limits, and time-out features as requested or as proactively applied under our responsible gaming obligations.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to Members who have opted in to receive marketing communications. Marketing consent can be withdrawn at any time.
• Platform Improvement: To analyze aggregated usage data for the purpose of improving platform performance, user experience, and product development.
• Legal Compliance: To comply with applicable laws, regulatory requirements, court orders, and lawful requests from competent authorities.

Legal Basis for Processing

dor123 processes Personal Data only where a valid legal basis exists under applicable international data protection standards. The legal bases we rely upon are as follows:

• Contract Performance: Processing necessary to fulfill the Member agreement — including account management, transaction processing, and service delivery — is conducted on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with KYC, AML, and other regulatory obligations is conducted on the basis of legal compliance. dor123 cannot waive these obligations at a Member's request.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics is conducted on the basis of dor123's legitimate interests, provided those interests do not override the fundamental rights and freedoms of Members.
• Consent: Process ing for marketing communications and non-essential cookies is conducted on the basis of your explicit consent, which may be freely withdrawn at any time without affecting the lawfulness of processing conducted prior to withdrawal.

Data Sharing and Disclosure

dor123 does not sell, rent, or trade your Personal Data to third parties for marketing purposes. However, we may share your Personal Data with the following categories of recipients in order to operate the platform and fulfill our legal obligations:

• Payment Service Providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals. These providers process data in accordance with their own privacy policies and applicable Indonesian banking regulations.
• Game Providers: Third-party studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive limited session data to deliver game content. Game providers do not receive Member financial data or identity documents.
• Identity Verification Partners: Specialized service providers that assist with KYC document verification and identity authentication under strict data processing agreements.
• Fraud Detection and Security Services: Partners that provide fraud monitoring, IP reputation analysis, and device fingerprinting services to protect Members and the platform from unauthorized activity.
• Customer Support Tools: Cloud-based live chat platforms and ticketing systems used to deliver 24/7 customer support. All such platforms are bound by contractual confidentiality obligations.
• Legal and Regulatory Authorities: In limited circumstances, dor123 may disclose Personal Data to law enforcement agencies, courts, regulatory bodies, or other competent authorities where required by law or where reasonably necessary to enforce our rights or protect the safety of Members or the public.
• Professional Advisors: Lawyers, auditors, and compliance consultants who assist dor123 in meeting its legal and regulatory obligations, under professional confidentiality duties.

All Data Processors engaged by dor123 are contractually bound to process Personal Data only on our documented instructions, to implement appropriate security measures, and not to use Personal Data for their own purposes.

International Data Transfers

As an international platform serving Indonesian Members, some of your Personal Data may be transferred to and stored on servers located outside Indonesia. This includes transfers to jurisdictions where dor123 infrastructure partners, payment processors, and game providers operate.

Where Personal Data is transferred internationally, dor123 ensures that appropriate safeguards are in place to protect your data, including:

• Data Processing Agreements incorporating Standard Contractual Clauses recognized by international data protection frameworks;
• Transfers to jurisdictions recognized as providing adequate protection for personal data under applicable Indonesian data protection law;
• Implementation of technical and organizational security measures equivalent to those mandated for domestic processing.

Members have the right to request further information regarding the safeguards applied to international data transfers by contacting [email protected].

Data Retention

dor123 retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal and regulatory requirements. Retention periods vary by data category:

At the end of the applicable retention period, Personal Data is securely deleted or anonymized such that it can no longer be attributed to an individual. Members who request account closure are advised that certain data will be retained for the periods set out above to meet dor123's legal and regulatory obligations.

Security Measures

dor123 implements robust technical and organizational security measures to protect Personal Data against unauthorized access, accidental loss, disclosure, or destruction. Key measures include:

• Encryption: All data transmitted between your device and dor123 servers is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data such as KYC documents and financial records are encrypted at rest using AES-256 encryption.
• Access Controls: Personal Data is accessible only to authorized personnel who require access to perform their duties. All staff undergo background checks and are bound by contractual confidentiality obligations.
• Multi-Factor Authentication: dor123 supports two-factor authentication (2FA) for Member accounts to reduce the risk of unauthorized access resulting from credential theft.
• Firewall and Intrusion Detection: The dor123 platform is protected by advanced firewall configurations and real-time intrusion detection systems that monitor for suspicious activity and attempted cyberattacks.
• Regular Security Audits: dor123 conducts periodic internal and third-party security audits, penetration testing, and vulnerability assessments to identify and remediate security weaknesses.
• Secure Data Centers: Personal Data is hosted in secure, SOC 2 Type II certified data centers with physical security controls including biometric access, surveillance, and 24/7 monitoring.
• Incident Response: dor123 maintains a documented data breach response plan. In the event of a security incident affecting Personal Data, affected Members and relevant regulatory authorities will be notified in accordance with applicable breach notification requirements.

While dor123 employs industry-leading security measures, no online system can be guaranteed to be 100% secure. Members are reminded to maintain the confidentiality of their login credentials and to report any suspected unauthorized account access immediately.

Cookies and Tracking Technologies

dor123 uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and deliver personalized content. A cookie is a small text file placed on your device that enables dor123 to recognize your browser across sessions.

The following categories of cookies are used on the dor123 platform:

• Essential Cookies: Required for the platform to function correctly — including session management, security authentication, and load balancing. These cookies cannot be disabled without severely impairing platform functionality.
• Performance Cookies: Collect aggregated analytics data on how visitors use the platform, including page views, session duration, and bounce rate. This data is used to improve platform performance and user experience. These cookies do not identify you personally.
• Functional Cookies: Remember your preferences such as language selection, display settings, and recent game history to provide a more personalized experience across sessions.
• Marketing Cookies: Track your activity across the platform to deliver targeted promotional offers and bonus notifications. Marketing cookies require your explicit consent and can be disabled through your browser settings or account preferences.

You can control cookie preferences through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive a warning before a cookie is stored. Please note that disabling essential cookies will prevent you from accessing key platform features including account login and transaction processing.

In addition to cookies, dor123 may use web beacons (transparent pixel images) and device fingerprinting technologies for fraud detection and security purposes.

Your Rights Over Personal Data

As a data subject, you have the following rights with respect to your Personal Data processed by dor123. These rights are subject to certain legal limitations and exceptions:

To exercise any of these rights, please contact dor123 customer support at [email protected]. We will respond to your request within 30 calendar days. In complex cases, this period may be extended by a further 60 days, in which case you will be informed of the extension and the reasons for it.

Protection of Minors

dor123 strictly prohibits any individual under the age of 21 from registering an account, depositing funds, or placing bets on the platform. The dor123 platform is designed exclusively for adults aged 21 years and above, in accordance with Indonesian gambling age restrictions and international responsible gaming standards.

dor123 does not knowingly collect Personal Data from individuals under the age of 21. KYC verification procedures — including government-issued ID checks — are mandatory for all Members to ensure age compliance.

If dor123 becomes aware that a Member is under the age of 21, the following actions will be taken immediately:

• The account will be suspended and permanently closed.
• All funds, deposits, and winnings will be forfeited.
• The account holder's parent or legal guardian will be notified where contact details are available.
• All Personal Data associated with the account will be deleted in accordance with our retention obligations.

Third-Party Links and Services

The dor123 platform may contain links to external websites operated by third parties, such as payment providers, game studios, and responsible gaming resources. This Privacy Policy applies only to Personal Data processed by dor123 directly.

dor123 is not responsible for the privacy practices, content, or security of third-party websites. When you follow a link to an external site, you leave the dor123 platform and become subject to that third party's privacy policy and terms of use.

We encourage Members to review the privacy policies of any third-party service before providing Personal Data or financial information. dor123 does not endorse, control, or assume liability for third-party practices.

Amendments to This Privacy Policy

dor123 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our processing practices, legal obligations, or platform functionality. When material changes are made, the following process applies:

• The revised Privacy Policy will be published on this page with an updated "Last Updated" date displayed at the top of the document.
• Where changes materially affect your rights or the ways in which dor123 processes your Personal Data, we will provide advance notice via email to the address registered on your account and/or via prominent notice on the platform.
• Continued use of the dor123 platform following publication of an amended Privacy Policy constitutes acceptance of the revised terms.
• If you do not agree to the amended Privacy Policy, you must immediately cease using the platform and contact customer support to request account closure and data deletion (subject to our regulatory retention obligations).

Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by dor123, please contact our customer support team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly through the dor123 platform. Average response time is under 2 minutes.
• Support Hours: Customer support — including native Indonesian-speaking agents — is available around the clock, 7 days a week, including Indonesian public holidays.

If you believe dor123 has processed your Personal Data unlawfully or in breach of this Privacy Policy, you have the right to lodge a formal complaint with a supervisory data protection authority in your jurisdiction. dor123 encourages you to contact us first so that we can attempt to resolve your concern directly.

For general enquiries about account management, deposits, withdrawals, or bonus terms that do not relate specifically to data protection, please visit our FAQ page or contact our standard customer support channels.