Privacy Policy

1. Introduction

This Privacy Policy applies to all personal data collected by koko11 through the website located at https://koko11.cam, any associated mobile applications, and all related gaming services (collectively, the "Platform"). This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of the Platform and establish the contractual relationship between koko11 and registered users.

koko11 operates as an internationally licensed online gaming platform serving primarily Indonesian users. We recognize that online gaming requires collection and processing of sensitive personal and financial data, and we take our data protection responsibilities seriously. This Privacy Policy reflects our commitment to transparent data practices and compliance with internationally recognized data protection principles, including lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.

When we refer to "personal data" or "personal information" in this Privacy Policy, we mean any information relating to an identified or identifiable natural person — specifically, information that can be used, alone or in combination with other data, to identify you as an individual. This includes but is not limited to your name, email address, telephone number, date of birth, residential address, government identification numbers, financial account details, IP address, device identifiers, and gaming activity records.

2. Data Controller

koko11, the operator of the gaming platform accessible at https://koko11.cam, is the data controller responsible for your personal data collected through the Platform. As data controller, koko11 determines the purposes for which and the manner in which your personal data is processed. We are accountable for compliance with applicable data protection laws and for responding to requests regarding your personal data rights.

For all inquiries related to data protection, privacy concerns, or requests to exercise your data subject rights, you may contact our Data Protection team via email at [email protected] (plain text — not a clickable link). Please include "Privacy Inquiry" in the subject line and provide your registered account username to facilitate efficient processing of your request. We commit to acknowledging all privacy-related inquiries within 72 hours and providing substantive responses within 30 calendar days, as required by international data protection standards.

3. Personal Data We Collect

koko11 collects several categories of personal data throughout your relationship with our Platform. The specific data elements we collect depend on how you interact with our services, but generally include the following categories:

3.1 Identity and Contact Data

• Full legal name (as it appears on government-issued identification)
• Date of birth and age verification information
• Gender
• Nationality and country of residence
• Email address
• Mobile phone number (including country code)
• Residential address (street, city, postal code, province)
• Government-issued identification documents (KTP, SIM, passport) including document number, issue date, and expiry date
• Photograph or selfie submitted for identity verification purposes

3.2 Financial Data

• Bank account details (bank name, account number, account holder name) for Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, and others
• E-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja) where applicable
• Transaction history including deposits, withdrawals, wagers placed, winnings, and bonus credits
• Payment method verification documents (bank book front page, e-wallet screenshots)
• Currency preference and transaction amounts in Indonesian Rupiah (IDR)

3.3 Account and Gaming Activity Data

• Username and encrypted password
• Account registration date and registration IP address
• Account balance (Real Money Balance and Bonus Balance)
• Gaming history including games played, bets placed, outcomes, timestamps, and stake amounts
• Sports betting activity including markets selected, odds accepted, match results
• Togel lottery bets including draw selection, numbers chosen, stake amounts, and results
• Bonus claims, wagering progress, and promotional participation records
• Responsible gaming settings including deposit limits, session reminders, and self-exclusion requests
• Customer support interaction history including live chat transcripts, email correspondence, and complaint records

3.4 Technical and Device Data

• IP address and geolocation data (country, region, city-level)
• Device type, operating system, browser type and version
• Device identifiers (IMEI, advertising ID where applicable)
• Screen resolution and display settings
• Referring website or source of traffic to the Platform
• Pages viewed, features used, time spent on pages, and click behavior
• Session duration and frequency of Platform access
• Technical logs including error messages, crash reports, and performance metrics

3.5 Marketing and Communications Preferences

• Your preferences for receiving promotional communications via email, SMS, WhatsApp, or in-platform notifications
• Language preference (Indonesian or English)
• Communication history regarding promotions, bonuses, and marketing campaigns
• Opt-out or unsubscribe records

4. How We Collect Your Personal Data

koko11 collects personal data through various methods during your use of the Platform:

4.1 Direct Collection from You

Most personal data is collected directly from you when you voluntarily provide it during account registration, when completing the KYC (Know Your Customer) identity verification process, when making deposits or requesting withdrawals, when contacting customer support, when claiming bonuses or participating in promotions, when updating your account profile or responsible gaming settings, and when communicating with koko11 through any channel including email, live chat, or WhatsApp.

4.2 Automatic Collection Through Technology

Technical and device data, gaming activity records, and behavioral analytics are collected automatically through cookies, web beacons, server logs, and similar tracking technologies embedded in the Platform. This automatic collection begins when you access the Platform and continues throughout your session. For more information on cookies and tracking technologies, please refer to Section 11 of this Privacy Policy.

4.3 Third-Party Sources

In limited circumstances, koko11 receives personal data from third-party service providers including payment processors who confirm successful deposit or withdrawal transactions, identity verification services that validate the authenticity of government-issued documents you submit during KYC, fraud detection services that provide risk assessment scores based on behavioral analysis, and gaming software providers who record gameplay outcomes and technical performance metrics for games hosted on their platforms but accessed through koko11.

5. How We Use Your Personal Data

koko11 processes your personal data for the following specific purposes, each of which is necessary for the operation of a legitimate and secure online gaming platform:

5.1 Account Management and Service Delivery

• Creating and maintaining your registered account on the Platform
• Authenticating your identity when you log in
• Processing your deposits, tracking your account balance, and executing withdrawal requests
• Delivering gaming services including access to live casino games, sports betting markets, slot machines, and togel lottery draws
• Recording game outcomes, calculating winnings, and settling bets
• Administering bonuses and promotions you opt into, including tracking wagering requirements
• Providing customer support and responding to your inquiries, complaints, or technical issues
• Implementing responsible gaming tools including deposit limits, session reminders, and self-exclusion requests

5.2 Compliance and Legal Obligations

• Verifying your age and confirming you are at least 21 years old (strict age verification requirement)
• Conducting KYC identity verification to comply with anti-money-laundering (AML) regulations and prevent financial crime
• Detecting and preventing fraud, bonus abuse, multiple account creation, and other prohibited conduct
• Maintaining transaction records for financial auditing and regulatory reporting purposes
• Complying with legal obligations imposed by gaming licensing authorities
• Responding to lawful requests from governmental authorities, law enforcement, or regulatory bodies
• Enforcing our Terms & Conditions and investigating breaches

5.3 Platform Security and Technical Operations

• Monitoring for unusual login activity, unauthorized account access, or security threats
• Detecting and preventing hacking attempts, DDoS attacks, or malicious software
• Maintaining system logs for troubleshooting technical issues and improving Platform stability
• Analyzing Platform performance metrics to optimize loading times, reduce errors, and enhance user experience
• Testing new features and game integrations in controlled environments before public release

5.4 Marketing and Communications (with Your Consent)

• Sending promotional emails, SMS messages, or WhatsApp notifications about new games, bonuses, or special offers — only if you have opted in to receive marketing communications
• Personalizing promotional content based on your gaming preferences and activity history
• Informing you of important Platform updates, new features, or changes to policies
• Conducting user satisfaction surveys to gather feedback on Platform experience

5.5 Business Analytics and Improvement

• Analyzing aggregate user behavior patterns to understand which games are most popular among Indonesian players
• Evaluating the effectiveness of marketing campaigns and bonus promotions
• Identifying opportunities to improve user experience, navigation, and feature design
• Conducting risk management analysis to set responsible betting limits and detect problem gambling behaviors
• Forecasting server capacity needs based on traffic patterns and peak usage times

6. Legal Basis for Processing

Under internationally recognized data protection principles, koko11 must have a lawful basis for processing your personal data. Our processing activities rely on the following legal bases:

6.1 Contractual Necessity

Much of our data processing is necessary to fulfill our contractual obligations to you under the Terms & Conditions you accepted when registering your account. Without processing your identity, financial, and gaming activity data, we cannot deliver the gaming services you request, process your transactions, or maintain your account. This legal basis covers account registration, deposit/withdrawal processing, game delivery, bonus administration, and customer support.

6.2 Legal Obligation

koko11 processes certain personal data to comply with legal and regulatory obligations imposed by our gaming licenses and anti-money-laundering regulations. This includes age verification to enforce the 21+ requirement, KYC identity verification, transaction record-keeping, fraud detection, and cooperation with lawful requests from authorities. We have no discretion to avoid this processing — it is mandated by law.

6.3 Legitimate Interests

koko11 has legitimate business interests in maintaining platform security, preventing fraud, improving user experience, and conducting business analytics. We process personal data for these purposes where our interests are not overridden by your fundamental rights and freedoms. For example, analyzing aggregate gaming trends to decide which new games to add serves our business interest in offering popular content while having minimal privacy impact on individual users.

6.4 Consent

For marketing communications and non-essential cookies (such as analytics cookies that track detailed behavioral patterns), koko11 processes personal data based on your explicit consent. You have the right to withdraw consent at any time by updating your communication preferences in your account settings or by contacting customer support. Withdrawing consent does not affect the lawfulness of processing that occurred before withdrawal.

7. When We Share Your Personal Data

koko11 does not sell your personal data to third parties for their own commercial purposes. However, we do share personal data with selected third-party service providers and entities in the following limited circumstances:

7.1 Payment Processors

We share financial data (bank account details, transaction amounts, account holder name) with payment processing partners who facilitate deposit and withdrawal transactions through Indonesian banking channels including BCA, BRI, BNI, and Mandiri. These processors act as data processors under our instruction and are contractually bound to use your data only for transaction processing purposes, subject to appropriate data security obligations.

7.2 Identity Verification Services

During KYC verification, we share identity documents (KTP, SIM, passport) and selfie photographs with specialized identity verification service providers who validate document authenticity, check for forgeries, and confirm that the person in the selfie matches the person on the ID document. These services return a verification result (pass or fail) to koko11 and are prohibited from retaining your documents longer than necessary for verification purposes.

7.3 Gaming Software Providers

When you play games on koko11, certain gameplay data (username, bet amounts, game outcomes, session timestamps) is shared with the licensed third-party providers who supply the games — including Evolution Gaming, Pragmatic Play, PG Soft, Microgaming, NetEnt, and others. This sharing is necessary because the games themselves run on the providers' servers and require your gaming activity data to function. These providers process your data according to their own privacy policies, which you can access through their respective websites.

7.4 Fraud Detection and Security Services

We share technical data (IP addresses, device fingerprints, login patterns, transaction histories) with fraud detection and cybersecurity service providers who analyze this information to identify suspicious activity, detect bonus abuse, prevent account takeovers, and protect the Platform from security threats. These services provide risk assessment scores and threat alerts to koko11.

7.5 Regulatory Authorities

koko11 may share personal data with gaming licensing authorities, financial regulators, or law enforcement agencies when required by law, when responding to valid legal requests or court orders, when investigating suspected illegal activity, or when necessary to protect koko11's legal rights or the safety of our users. We will notify affected users of such disclosures where legally permitted to do so.

7.6 Business Transfers

In the event that koko11 undergoes a merger, acquisition, corporate restructuring, or sale of assets, your personal data may be transferred to the acquiring entity as part of the business transaction. We will notify users via email and Platform notice before any such transfer occurs, and the acquiring entity will be bound to protect your personal data in accordance with this Privacy Policy or provide you with notice of any changes.

7.7 Data Transfer Outside Indonesia

Some of the third-party service providers mentioned above are located outside Indonesia, which means your personal data may be transferred to, stored in, or processed in other countries. koko11 ensures that any international data transfers are subject to appropriate safeguards, such as contractual data protection clauses modeled on international standards, to ensure your personal data receives an equivalent level of protection regardless of where it is processed.

8. How We Protect Your Personal Data

koko11 implements technical, organizational, and administrative security measures designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security framework includes the following key protections:

8.1 Encryption Technologies

• SSL/TLS Encryption: All data transmitted between your device and the koko11 Platform is encrypted using industry-standard SSL/TLS protocols (minimum 256-bit encryption). This ensures that sensitive information such as passwords, financial data, and personal details cannot be intercepted or read by third parties during transmission.
• Data-at-Rest Encryption: Personal data stored in our databases is encrypted using AES-256 encryption standards. Financial information and identity documents are stored in encrypted formats that require secure decryption keys held only by authorized koko11 personnel.
• Password Hashing: User passwords are never stored in plain text. Instead, we use one-way cryptographic hashing algorithms (bcrypt with salt) that make it computationally infeasible to reverse-engineer the original password even if the database were compromised.

8.2 Access Controls

Access to personal data within koko11 is restricted on a strict need-to-know basis. Only authorized employees and contractors who require access to perform their job functions (such as customer support agents resolving account inquiries or compliance officers conducting KYC reviews) are granted access to personal data. All personnel with data access are subject to confidentiality obligations and receive regular data protection training. Access privileges are reviewed quarterly and revoked immediately upon termination of employment or contract.

8.3 Infrastructure Security

The koko11 Platform is hosted on secure servers protected by firewalls, intrusion detection systems, and DDoS mitigation services. We conduct regular vulnerability assessments and penetration testing to identify and remediate security weaknesses. Software patches and security updates are applied promptly. Database backups are performed daily and stored in geographically separate secure locations to ensure data recovery capability in the event of system failure or disaster.

8.4 Fraud Monitoring

koko11 employs automated fraud detection systems that analyze transaction patterns, login behavior, and gameplay activity in real-time to identify suspicious activity indicative of account compromise, bonus abuse, or financial fraud. Accounts flagged by these systems are subject to enhanced review and may be temporarily suspended pending investigation.

8.5 Third-Party Security

All third-party service providers with whom we share personal data are carefully vetted for their data security practices. We require service providers to maintain security standards equivalent to or exceeding our own, as documented in contractual data processing agreements. We conduct periodic audits and request evidence of compliance with security obligations.

8.6 Limitations and Disclaimer

While koko11 implements robust security measures, no digital system can guarantee absolute security against all potential threats. Cybersecurity is an evolving field, and determined attackers with sufficient resources may be able to breach defenses despite best efforts. koko11 cannot guarantee that unauthorized third parties will never be able to defeat our security measures or misuse your personal data. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you promptly in accordance with applicable data breach notification laws.

Your Role in Security: You also play a critical role in protecting your personal data. You must maintain the confidentiality of your account credentials, use strong passwords that are not shared across multiple sites, avoid accessing your koko11 account on public or shared computers, and be vigilant against phishing attempts or fraudulent communications claiming to be from koko11. If you suspect your account has been compromised, contact customer support immediately.

9. How Long We Retain Your Personal Data

koko11 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests. Specific retention periods vary depending on the category of data and the purpose for which it is processed:

When personal data is no longer required for the purposes outlined above, koko11 will securely delete or anonymize the data in accordance with our data retention and destruction policies. Anonymized data (data that can no longer be used to identify an individual, even with additional information) may be retained indefinitely for statistical analysis and business intelligence purposes.

If you request account closure, your account will be deactivated immediately and you will no longer be able to access gaming services. However, as explained above, certain personal data must be retained for extended periods to comply with legal obligations. We will retain only the minimum data necessary for compliance purposes and will delete or anonymize additional data that is no longer required.

10. Your Data Protection Rights

As a user whose personal data is processed by koko11, you have the following rights regarding your personal information. These rights are subject to certain legal limitations and exceptions, but koko11 is committed to honoring your rights to the fullest extent permitted by applicable law:

10.1 Right of Access

You have the right to request confirmation of whether koko11 is processing your personal data and, if so, to request access to that data. You may request a copy of the personal data we hold about you in a commonly used electronic format. This right allows you to understand what data we have collected and how we are using it.

10.2 Right to Rectification

If you believe any of your personal data held by koko11 is inaccurate, incomplete, or outdated, you have the right to request that we correct or update it. You can update certain information directly through your account settings (such as email address, phone number, or residential address). For changes to identity information or financial data, you may need to contact customer support and provide supporting documentation.

10.3 Right to Erasure ("Right to be Forgotten")

Under certain circumstances, you have the right to request deletion of your personal data. However, this right is not absolute. koko11 may be legally required to retain certain data for compliance purposes (such as transaction records and KYC documents) even after you request deletion. We will delete all personal data that is not subject to legal retention requirements.

10.4 Right to Restriction of Processing

You have the right to request that koko11 restricts processing of your personal data in certain situations — for example, if you contest the accuracy of the data and we need time to verify it, or if you need us to retain data for legal claims even though we no longer need it for our original purposes. During a restriction period, we will store the data but not actively use it unless you provide consent or other limited exceptions apply.

10.5 Right to Data Portability

Where technically feasible, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another service provider without hindrance from koko11. This right applies to data you provided to us with your consent or for contractual performance, and where our processing is carried out by automated means.

10.6 Right to Object

You have the right to object to processing of your personal data where that processing is based on our legitimate interests. For example, you may object to use of your data for marketing purposes or for business analytics. If you exercise this right, koko11 will cease the processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless the processing is necessary for legal claims.

10.7 Right to Withdraw Consent

Where processing is based on your consent (such as marketing communications), you have the right to withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing that occurred before withdrawal. To withdraw consent for marketing, use the unsubscribe link in promotional emails or update your communication preferences in account settings.

10.8 Right to Lodge a Complaint

If you believe koko11 has violated your data protection rights or applicable privacy laws, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. For Indonesian residents, this may be the Ministry of Communication and Information Technology or other applicable regulatory body with jurisdiction over privacy matters.

How to Exercise Your Rights

To exercise any of the rights described above, please contact koko11's Data Protection team via email at [email protected] (plain text — not a clickable link) with "Data Subject Rights Request" in the subject line. Include your registered account username and clearly state which right you wish to exercise. We may need to verify your identity before processing your request to protect against fraudulent or unauthorized access to your personal data. We will respond to all valid requests within 30 calendar days or explain why additional time is needed, up to a maximum of 90 days for complex requests.

11. Cookies and Tracking Technologies

koko11 uses cookies, web beacons, and similar tracking technologies to collect information about your use of the Platform, enhance user experience, maintain session continuity, and analyze Platform performance. A cookie is a small text file placed on your device by a web server when you access a website. Cookies serve various functions depending on their type and purpose.

11.1 Types of Cookies We Use

Essential Cookies: These cookies are strictly necessary for the Platform to function and cannot be disabled in our systems. They enable core functionality such as maintaining your logged-in session, remembering items in your account balance, and providing secure areas of the Platform. Without these cookies, services you have requested (such as accessing your account or making deposits) cannot be provided.

Performance and Analytics Cookies: These cookies collect aggregated information about how visitors use the Platform, such as which pages are visited most frequently, how long users spend on each page, and which features are most popular. This data helps us identify areas for improvement and optimize Platform performance. These cookies do not collect personally identifiable information unless combined with other data. Third-party analytics services such as Google Analytics may be used, subject to their own privacy policies.

Functionality Cookies: These cookies allow the Platform to remember choices you make (such as language preference, time zone settings, or previously selected betting markets) to provide enhanced, personalized features and to remember your preferences when you return to the Platform.

Advertising and Marketing Cookies: These cookies track your browsing activity to deliver personalized promotional offers and measure the effectiveness of marketing campaigns. They may be set by koko11 or by third-party advertising partners. You can control these cookies through your browser settings or cookie consent preferences.

11.2 Managing Cookies

Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer. However, blocking or deleting cookies may prevent you from accessing certain Platform features or may require you to re-enter login credentials more frequently. To manage cookies, access your browser's settings menu and look for privacy or cookie management options. Please note that disabling essential cookies will prevent you from using the Platform.

11.3 Do Not Track Signals

Some browsers support "Do Not Track" (DNT) signals that allow users to express a preference not to be tracked. Currently, there is no universal standard for how websites should respond to DNT signals. koko11 does not currently respond to DNT signals, but we respect your right to manage cookies through your browser settings as described above.

12. Third-Party Websites and Services

The koko11 Platform may contain links to third-party websites, services, or resources that are not operated or controlled by koko11. This includes links to gaming software provider websites, payment processor sites, social media platforms, and other external resources. This Privacy Policy applies only to information collected by koko11 through the Platform located at https://koko11.cam.

When you click on a third-party link or access a third-party service, you will be subject to that third party's own privacy policy and terms of service. koko11 is not responsible for the privacy practices, data protection standards, or content of third-party websites. We encourage you to review the privacy policies of any third-party websites you visit to understand how they collect, use, and protect your personal information.

In particular, games hosted on the koko11 Platform are provided by third-party gaming software providers such as Evolution Gaming, Pragmatic Play, PG Soft, and others. When you play these games, certain gameplay data is processed by the respective provider according to their own privacy policies. koko11 selects providers with reputable data protection practices, but we cannot control or guarantee their data handling once your data leaves the koko11 Platform.

13. Children's Privacy

koko11 is an online gaming platform that provides real-money gambling services exclusively to adults. The Platform is not intended for use by anyone under 21 years of age. We do not knowingly collect, use, or maintain personal data from individuals under 21 years old. Our Terms & Conditions explicitly prohibit account registration by anyone under the age of 21.

If you are under 21 years of age, you must not access or use the koko11 Platform, create an account, provide any personal information to us, or attempt to gamble or wager real money through our services. If you are a parent or guardian and believe your child under 21 has provided personal information to koko11, please contact our customer support team immediately at [email protected] (plain text — not a clickable link). Upon verification, we will promptly delete any personal data belonging to the minor, close the account, and forfeit any associated funds as required by our underage gambling policy.

koko11 implements age verification measures during the KYC process to confirm that all registered users are at least 21 years old before granting full access to gaming services. We encourage parents and guardians to use parental control software and to monitor their children's internet usage to prevent unauthorized access to adult-oriented websites including online gaming platforms.

14. Changes to This Privacy Policy

koko11 reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, business operations, or technological capabilities. When material changes are made to this Privacy Policy, we will notify registered users via email to the address associated with their account and/or by displaying a prominent notice on the Platform homepage.

The "Last Updated" date at the top of this Privacy Policy reflects the effective date of the most recent version. We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal data. Your continued use of the Platform after notification of Privacy Policy changes constitutes your acknowledgment and acceptance of the updated Privacy Policy.

If you do not agree with any changes made to this Privacy Policy, you have the right to close your account by contacting customer support. However, closure of your account does not affect koko11's right to retain personal data as required by applicable legal obligations, as described in the Data Retention section of this Privacy Policy.

15. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy, our data processing practices, or your data protection rights, please contact koko11's Data Protection team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please include "Privacy Policy Inquiry" or "Data Subject Rights Request" in your email subject line to facilitate efficient routing to the appropriate team
• Required Information: Include your registered account username and a clear description of your inquiry or request
• Response Time: We commit to acknowledging all privacy-related inquiries within 72 hours and providing substantive responses within 30 calendar days, or explaining why additional time is needed for complex requests
• Live Chat: For general privacy questions (not formal data subject rights requests), you may also contact our 24/7 customer support team via the live chat widget on the Platform
• Languages Supported: Privacy inquiries may be submitted in Indonesian (Bahasa Indonesia) or English

koko11 values your privacy and is committed to handling all inquiries with professionalism, confidentiality, and respect for your data protection rights. We take all privacy concerns seriously and will work diligently to address your questions or resolve any issues that arise.