At tum123, your privacy is treated with the same seriousness as your account security. This Privacy Policy explains exactly what personal data we collect, why we collect it, how we use and protect it, and what rights you hold as a tum123 member based in Indonesia.
Privacy at a Glance
These cards summarize tum123's core privacy commitments. They are provided for convenience only — the full binding policy is set out in the clauses below.
tum123 collects only the personal data that is strictly necessary to operate your account, process IDR transactions, comply with KYC requirements, and deliver our gaming services. We do not collect data speculatively.
tum123 does not sell, rent, or trade your personal information to third-party marketers under any circumstances. Your data is used solely to operate and improve the tum123 platform for your benefit.
Every data exchange between your device and tum123's servers is encrypted using TLS 1.3 — the current industry standard. Sensitive fields such as passwords are hashed using strong one-way algorithms and are never stored in plaintext.
As a tum123 member, you have the right to access, correct, and request deletion of your personal data at any time. Submit a request through our 24/7 live chat or by emailing our support team directly.
Financial transactions — including BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and ShopeePay payments — are routed through encrypted payment rails operated by licensed processors. Raw payment credentials are never stored on tum123's servers.
tum123 retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable regulation. Data no longer required is securely deleted or anonymized.
Throughout this Privacy Policy, the following terms carry the meanings set out below.
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person — including name, national identity number (NIK), mobile number, email address, device identifiers, and financial account details. |
| "Processing" | Any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, restriction, erasure, or destruction. |
| "Controller" | tum123 — the entity that determines the purposes and means of processing your Personal Data. |
| "Processor" | A third party that processes Personal Data on behalf of tum123 under a data processing agreement — for example, a payment gateway or cloud hosting provider. |
| "Member" / "You" | Any individual who registers a tum123 account or accesses any part of the tum123 platform. |
| "Platform" | The tum123 website at https://tum123.app and all associated sub-pages, services, and applications. |
| "KYC" | Know Your Customer — the identity and age verification process applied to tum123 members before withdrawal rights are granted or at any other time deemed necessary. |
| "Cookies" | Small text files placed on your device by the Platform to enable functionality, remember preferences, and support analytics. |
tum123 collects Personal Data across the following categories. We collect only what is necessary for the purposes described in this policy.
tum123 collects Personal Data through the following channels:
| Collection Channel | Data Collected |
|---|---|
| Account registration form | Name, date of birth, mobile number, email address, city of residence. |
| KYC submission process | NIK, KTP photograph, selfie/liveness image, bank account or e-wallet details. |
| Deposit and withdrawal transactions | Bank account number, e-wallet identifier, transaction amounts, dates, and references. |
| Platform usage (automated) | IP address, device fingerprint, browser data, session timestamps, game activity logs. |
| Cookies and tracking technologies | Session identifiers, preference settings, analytics data — see Clause 7 for full details. |
| Customer support interactions | Live chat logs, email content, WhatsApp correspondence, and any documents you provide. |
| Third-party fraud and verification services | Risk scores, device reputation data, and identity match results returned by external KYC or anti-fraud providers. |
tum123 processes your Personal Data for the following specific, legitimate purposes:
tum123 processes your Personal Data under one or more of the following legal bases:
| Legal Basis | When It Applies |
|---|---|
| Contractual necessity | Processing required to perform the contract between you and tum123 — including account management, game delivery, and payment processing. |
| Legal obligation | Processing required to comply with KYC, anti-money-laundering, and other applicable regulatory requirements. |
| Legitimate interests | Processing necessary for fraud prevention, platform security, abuse detection, and internal analytics — where these interests are not overridden by your rights. |
| Consent | Processing for optional purposes — specifically, marketing communications — where you have given explicit, freely withdrawable consent. |
tum123 does not sell or rent your Personal Data to any third party. We share data only in the following limited circumstances, and only to the extent strictly necessary:
Your bank account or e-wallet details are transmitted to licensed Indonesian payment processors to execute deposit crediting and withdrawal disbursements. These processors are contractually bound to handle your data only for payment execution and are prohibited from using it for any other purpose.
Identity documents and liveness images submitted during KYC may be shared with third-party identity verification services. These providers operate under strict data processing agreements and are used solely to confirm your identity and age on tum123's behalf.
Third-party game studios — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — may receive your account identifier and session token to deliver their game content. These providers receive only the minimum data necessary to run the game session and are not authorized to use it for independent marketing or profiling.
Device fingerprint data and IP addresses may be shared with anti-fraud technology providers to detect prohibited conduct and protect the integrity of the Platform. These providers process data only for the purpose of generating risk assessments returned to tum123.
tum123 may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where required to do so by a valid legal obligation, court order, or regulatory directive. In such cases, tum123 will disclose only the minimum data required and, where legally permitted, will notify you of the disclosure.
tum123 uses cookies and similar tracking technologies on the Platform for the purposes described below. By continuing to use the Platform after reviewing this policy, you acknowledge the use of cookies as described.
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly necessary | Maintain your authenticated session, remember your login state, and enable core site functionality. | Session / up to 30 days |
| Functional | Remember your preferences such as last game visited, responsible gaming settings, and display language. | Up to 12 months |
| Analytics | Collect aggregated, anonymized data on page visits, game category popularity, and technical performance to improve the Platform. | Up to 13 months |
| Security / fraud prevention | Contribute to device fingerprinting used to detect duplicate accounts and unauthorized access attempts. | Up to 24 months |
You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent core site functionality — including login — from operating correctly. tum123 does not use third-party advertising cookies or cross-site tracking pixels.
tum123 implements a layered security architecture to protect your Personal Data against unauthorized access, accidental loss, alteration, or disclosure. Our key security measures include:
Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that poses a material risk to your rights, tum123 will notify affected Members promptly and take immediate remediation steps.
tum123 retains your Personal Data for as long as is necessary to fulfill the purposes for which it was collected, taking into account applicable legal, regulatory, and operational requirements.
| Data Category | Retention Period |
|---|---|
| Account and identity data | Duration of account plus 5 years following account closure, to comply with financial record-keeping obligations. |
| KYC documents (KTP, selfies) | Duration of account plus 5 years following account closure. |
| Transaction records | 7 years from the date of the transaction — consistent with standard financial audit requirements. |
| Gaming activity logs | 5 years from the date of the gaming session, for dispute resolution and regulatory compliance purposes. |
| Support communications | 3 years from the date of the last interaction, for quality assurance and dispute evidence purposes. |
| Marketing opt-in records | Until consent is withdrawn, plus 1 year thereafter as evidence of compliance. |
| Analytics cookies | Up to 13 months — see Clause 7. |
When Personal Data is no longer required within any applicable retention period, it is securely deleted or irreversibly anonymized so that it can no longer be linked to you as an individual.
As a tum123 Member, you hold the following rights in relation to your Personal Data. To exercise any of these rights, contact our support team via live chat or at the email address listed in Clause 14.
The tum123 Platform is strictly for adults aged 21 and over. tum123 does not knowingly collect Personal Data from individuals under the age of 21. Age verification is a mandatory step in the registration and KYC processes, and accounts found to belong to individuals under the age of 21 will be immediately suspended and all associated data reviewed.
If you are a parent or guardian and believe that a minor in your care has registered a tum123 account, please contact our support team immediately. We will investigate promptly, close the account, and securely delete the minor's data to the extent permitted by our retention obligations.
For further information on how tum123 enforces its age policy and promotes safe gaming practices, please refer to our Responsible Gaming page.
tum123 operates globally and may process or store your Personal Data on servers located outside Indonesia, including in jurisdictions that may not provide the same level of data protection as Indonesian law. Where such transfers occur, tum123 ensures that appropriate safeguards are in place, including:
By registering an account on tum123 and accepting these terms, you acknowledge that your Personal Data may be transferred to and processed in jurisdictions outside Indonesia as described in this clause.
tum123 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable regulations, or Platform features. When we make material changes, we will notify you by email to your registered address at least 7 days before the changes take effect. Minor clarifications or corrections may be published without advance notice.
The "Last Updated" date at the top of this page indicates when the current version was published. We encourage you to review this policy periodically. Your continued use of the Platform after the effective date of any revision constitutes your acknowledgment of the updated policy. If you do not agree with the revised terms, you should close your account before the effective date.
If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to raise a complaint about how tum123 has handled your Personal Data, please contact us through one of the channels below. All contact details are displayed as plain text and are not clickable links.
tum123 aims to resolve all privacy-related complaints internally within 30 days. If you are not satisfied with our response, you retain the right to escalate the matter to the relevant data protection authority in your jurisdiction.
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