Privacy

Scope and Data Controller

This Privacy Policy describes how Toto Prayogo Alpha (the "Site"), accessible at totoprayogo.com, collects, uses, discloses, and safeguards personal information in the United States of America and, where indicated, internationally. The data controller responsible for your information is Cambrielle Montero, 4001 N Lamar Blvd, Austin, TX 78756, USA.

By accessing or using the Site, subscribing to communications, or otherwise providing personal information, you acknowledge this Privacy Policy. If you do not agree, please discontinue use of the Site.

Effective date: September 30, 2025

Definitions

For purposes of this Policy: "Personal Information" means information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked with an individual or household. "Sensitive Personal Information" includes certain data such as account log-in with password, precise geolocation, and government identifiers. "Sell" has the meaning under applicable state privacy laws and generally refers to sharing personal information for monetary or other valuable consideration. "Share" means disclosing personal information for cross-context behavioral advertising. "Targeted Advertising" means displaying ads to you based on personal information obtained from your activities across nonaffiliated websites or online applications. "De-identified Data" means data that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual.

Information We Collect

Information You Provide to Us

Identifiers and contact details (e.g., name, email address, postal address, telephone number) when you subscribe to newsletters, create an account, or contact us.
Account credentials (e.g., username and password) if you create an account.
Professional or educational information if you choose to provide it in forms or correspondence.
Preferences, feedback, survey responses, and any other information you choose to submit.
Payment-related information if you purchase services; payment card data is processed by our third-party payment processors, and we do not store full card numbers.

Information Collected Automatically

Device and technical data (e.g., IP address, device identifiers, browser type, operating system, screen resolution).
Usage data (e.g., pages viewed, referring/exit pages, clicks, scrolling, time on page, downloads).
Approximate geolocation derived from IP address.
Cookie, pixel, and similar tracking identifiers for analytics, performance, and advertising.

Information from Third Parties

Analytics providers that supply aggregate or pseudonymous engagement metrics.
Advertising and marketing partners that provide audience, interest, and campaign performance data.
Payment processors that confirm transaction status (e.g., success/failure, fraud indicators).

How We Use Personal Information

Operate, maintain, and improve the Site, services, and user experience.
Provide content, features, newsletters, alerts, and customer support.
Conduct analytics, research, and performance measurement.
Personalize content and, where permitted, deliver advertising or marketing communications.
Detect, prevent, and address security incidents, fraud, and abuse.
Comply with legal obligations and enforce terms and policies.
Support corporate transactions (e.g., merger, acquisition, reorganization, or asset sale) as permitted by law.

Legal Bases for Processing (EEA/UK/Switzerland)

Where applicable, we process personal information under the following legal bases: (i) consent (e.g., for certain marketing or cookies), (ii) performance of a contract (e.g., to provide requested services), (iii) legitimate interests (e.g., to secure and improve our services), and (iv) compliance with legal obligations. You may withdraw consent at any time where processing is based on consent.

Disclosure of Personal Information

We disclose personal information to the following categories of recipients for the purposes described above:

Service providers and processors (e.g., hosting, analytics, security, customer support, payment processing) bound by contractual confidentiality and data protection obligations.
Advertising and marketing partners to support measurement, attribution, and, where permitted, targeted advertising.
Professional advisors (e.g., legal, accounting) and auditors.
Authorities or other parties when required by law, legal process, or to protect rights, safety, and property.
Successors or affiliates in connection with a corporate transaction, subject to this Policy or substantially similar protections.

We do not sell personal information for money. We may "share" personal information (as that term is defined under California law) to support cross-context behavioral or targeted advertising. You may opt out of such sharing as described in the Your Privacy Rights and State-Specific Notices sections.

Cookies and Tracking Technologies

We and our partners use cookies, pixels, SDKs, and similar technologies to operate the Site, remember preferences, perform analytics, and, where permitted, personalize content and advertising. You can manage cookies through your browser settings, device settings, or our on-site cookie preferences (where available). Disabling certain cookies may affect Site functionality. We honor applicable opt-out signals as required by law.

Your Privacy Rights

Depending on your jurisdiction, you may have rights to:

Know/Access: Request confirmation of whether we process your personal information and access to it.
Delete: Request deletion of personal information, subject to legal exceptions.
Correct/Rectify: Request correction of inaccurate personal information.
Portability: Request a portable copy of certain personal information.
Opt Out: Opt out of sale/share of personal information and targeted advertising, and in some jurisdictions, certain profiling.
Limit: In California, request to limit the use and disclosure of sensitive personal information where applicable.

How to Exercise Your Rights

You may submit requests or questions by emailing [email protected]. To help protect privacy, we may verify your identity (e.g., by matching information you provide with data we maintain). We will respond within the timelines required by applicable law.

Appeals

If we deny your request, you may appeal by replying to our decision email or by emailing [email protected] with the subject line "Privacy Request Appeal". If your appeal is denied, you may contact your state attorney general as permitted by law.

Authorized Agents

Where permitted, you may use an authorized agent to submit a request. We may require proof of authorization and verification of your identity.

Non-Discrimination

We will not discriminate against you for exercising privacy rights granted by applicable law.

California Notice at Collection

We collect, use, and may share the following categories of personal information for the purposes described in this Policy:

Identifiers (e.g., name, email, IP address, device IDs).
Customer records (e.g., billing address if you purchase services).
Commercial information (e.g., subscription status, purchase history).
Internet or similar activity (e.g., browsing history, interaction data, analytics).
Geolocation (approximate, derived from IP address).
Professional information (if voluntarily provided).
Inferences (e.g., preferences or interests derived from usage, where permitted).
Sensitive personal information (account login and password, if you create an account). We use sensitive personal information only as reasonably necessary to provide the requested services, ensure security and integrity, and comply with law. We do not use sensitive personal information to infer characteristics.

Sources: Directly from you, automatically from your device, and from service providers/partners. Purposes: Provide and improve services; analytics; security; communications; compliance; and advertising/marketing where permitted. Disclosures: Service providers, advertising/marketing partners (for measurement and, where allowed, targeted advertising), professional advisors, authorities, and in connection with corporate transactions.

Selling/Sharing: We do not sell personal information for money. We may "share" personal information for cross-context behavioral advertising. You may opt out by adjusting cookie preferences (where available), enabling an applicable opt-out signal in your browser, or emailing [email protected] with the subject line "Do Not Sell or Share My Personal Information".

Retention: We retain personal information for as long as needed to fulfill the purposes described or as required by law, typically: account identifiers and contact details for the life of the account and up to three (3) years after the last interaction; analytics and log data for approximately twelve (12) to twenty-four (24) months; transaction records for at least seven (7) years or as required by tax, audit, or regulatory rules; and security records for as long as necessary to investigate or remediate issues. Actual retention may vary based on business needs and legal obligations.

State Privacy Notices (CO, CT, VA, UT and Others)

Residents of certain U.S. states may have additional rights, including to opt out of targeted advertising, sale, and certain profiling, and to appeal decisions. We process personal information for targeted advertising only where permitted. To exercise rights or opt out, contact [email protected]. We will honor applicable universal opt-out mechanisms where required by law.

Nevada

Nevada residents may submit a request to opt out of the sale of covered information by emailing [email protected]. We do not currently sell covered information as defined by Nevada law.

International Data Transfers

We are based in the United States. If you access the Site from outside the U.S., your information may be transferred to, stored, and processed in the U.S. and other countries that may have data protection laws different from those in your jurisdiction. Where required, we implement appropriate safeguards (e.g., standard contractual clauses) for cross-border transfers.

Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. No method of transmission or storage is completely secure; we cannot guarantee absolute security.

Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy, to comply with legal, accounting, or reporting requirements, to resolve disputes, and to enforce agreements. When retention is no longer necessary, we will delete, de-identify, or anonymize the information in accordance with applicable law.

Children’s Privacy

The Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information, please contact us at [email protected] so we can take appropriate action.

Financial Information and Payments

If you purchase services, payments are processed by third-party payment processors. We receive limited information related to the transaction (e.g., confirmation, status) and do not store full payment card numbers. Payment processors’ use of your information is governed by their policies.

De-Identified and Aggregated Data

We may create, use, and disclose aggregated or de-identified information for any lawful purpose. We commit to maintaining and using de-identified data without attempting to re-identify it, except as permitted by law.

Third-Party Links and Services

The Site may reference or integrate third-party content or services. We are not responsible for the privacy practices of third parties. We encourage you to review their privacy policies before engaging with them.

Do Not Track

Some browsers transmit "Do Not Track" signals. Because there is no industry consensus on how to respond, we do not respond to such signals. We will, however, honor legally required opt-out preference signals where applicable.

Accessibility

We are committed to making our privacy practices accessible. If you need this Policy in an alternative format or have accessibility-related requests, please contact us at [email protected].

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the effective date above and take additional steps as required by law.

Contact Us

Owner and Data Controller: Cambrielle Montero

Postal Address: 4001 N Lamar Blvd, Austin, TX 78756, USA

Email: [email protected]