to138 Terms & Conditions

1Definitions

In these Terms & Conditions, the following definitions apply unless the context otherwise requires:

• "to138" / "the Platform" / "we" / "us" / "our" — refers to to138, the online betting and gaming platform accessible at https://to138.cam, operated by its internationally licensed operating entity.
• "User" / "Member" / "Player" / "you" / "your" — any individual who registers for, accesses, or uses the to138 platform in any capacity.
• "Account" — the individual registered user account created by a Member upon successful completion of the registration and KYC verification process.
• "Services" — the full suite of online betting, gaming, and associated services made available on to138, including the sportsbook, live casino, togel (numbers lottery), slot games, and any other wagering products.
• "Wallet" / "Account Balance" — the Rupiah (IDR) denominated credit balance held within a Member's Account, representing funds available for wagering or withdrawal.
• "Bonus Funds" — promotional credit awarded by to138 under specific promotional terms. Bonus funds are subject to wagering requirements before conversion to withdrawable balance.
• "KYC" — Know Your Customer; the identity and address verification process required for full account activation and withdrawal eligibility.
• "Wagering Requirement" — the minimum total wager amount that must be completed before bonus funds or bonus-derived winnings may be withdrawn.
• "Terms" — these Terms & Conditions as amended from time to time by to138.

2Eligibility & Registration

Access to and use of the to138 platform is subject to the following eligibility conditions:

1. You must be an individual natural person. Corporate entities may not register as Members.
2. You must be at least 21 years of age at the time of registration and at all times during your use of the Services. to138 enforces a strict 21+ policy in accordance with responsible gaming standards applicable to the Indonesian market .
3. You must be a resident of Indonesia at the time of registration. to138 is designed for and primarily serves the Indonesian market.
4. You must have the legal capacity to enter into a binding agreement. Persons who are legally incapacitated or under guardianship orders may not register.
5. You must not be a current or former employee, contractor, director, officer, or immediate family member of any such person associated with to138 or any of its affiliated technology or gaming suppliers.
6. You must not be registered on any self-exclusion list maintained by to138 or any responsible gaming body with which to138 cooperates.
7. You must not reside in, or access the platform from, any jurisdiction in which use of the Services is explicitly prohibited by applicable local law.

By completing the registration process, you represent and warrant that all eligibility requirements above are satisfied and that all information you provide is accurate, current, and complete.

3Account Management

The following rules apply to the creation and management of your to138 account:

1. One Account Per Person. Each individual may hold only one active account on to138. Opening duplicate accounts — whether under the same name, different names, or different payment details — is strictly prohibited and will result in the closure of all associated accounts and forfeiture of balances.
2. Accurate Information. You must provide accurate, complete, and up-to-date registration information at all times. You are responsible for updating your account details promptly if your circumstances change.
3. Account Security. You are solely responsible for maintaining the confidentiality of your login credentials. to138 will never ask for your password. If you suspect unauthorized access to your account, you must notify us immediately via live chat at [email protected].
4. Account Closure. You may request the closure of your account at any time by contacting our support team. Pending bets will be settled and any remaining verified balance will be processed for withdrawal to your registered payment method.
5. Inactive Accounts. Accounts that have been inactive for a continuous period of twelve (12) months with a positive balance may be subject to an inactivity fee of up to Rp 50.000 per month. to138 will provide prior notice before any such fee is applied.
6. Account Suspension. to138 reserves the right to suspend or restrict an account pending investigation where fraud, money laundering, or a breach of these Terms is suspected. Affected members will be notified unless doing so would compromise an ongoing investigation.

4Deposits

to138 accepts deposits via the following payment channels, all denominated in Indonesian Rupiah (IDR):

1. All deposits must originate from a payment account registered in your own name. Deposits from third-party accounts are not permitted and will be returned.
2. to138 does not charge a deposit fee. However, your bank or e-wallet provider may apply their own transaction fees.
3. Deposited funds become available in your account wallet immediately upon confirmed receipt by to138's payment gateway.
4. to138 reserves the right to impose deposit limits on any account at its discretion for responsible gaming or risk management purposes.
5. In the event of a failed deposit, funds not received by to138 within 24 hours of the attempted transfer will typically be returned to the originating account by your payment provider. Contact our support team if a deposit does not appear after 30 minutes.

5Withdrawals

1. Withdrawals are available only to Members who have completed the full KYC verification process. Unverified accounts may deposit and wager but cannot withdraw funds.
2. Withdrawals will only be processed to a payment method that is registered in the same name as the to138 account. No third-party transfers will be made under any circumstances.
3. The minimum withdrawal amount is Rp 50.000. There is no maximum single withdrawal limit for verified accounts in good standing, although large withdrawals may be subject to additional security review.
4. Standard withdrawal processing time is 5 to 15 minutes for verified accounts. During peak periods or where additional checks are required, processing may take up to 24 hours.
5. Withdrawal requests may be paused or reviewed if the account has an active bonus with an incomplete wagering requirement. Only the non-bonus portion of the balance may be withdrawn in such cases.
6. to138 reserves the right to request additional documentation before processing withdrawals above Rp 50.000.000 as part of its AML compliance obligations.
7. Repeated deposit-and-withdrawal activity without material wagering engagement may be interpreted as misuse and may result in account review.

6Bonuses & Promotions

to138 offers promotional bonuses from time to time, including welcome bonuses, reload bonuses, cashback offers, and tournament prizes. All bonuses are subject to the following general conditions unless a specific promotion's terms state otherwise:

1. Bonuses are credited as Bonus Funds and are held separately from your main withdrawable balance until the applicable wagering requirement is met.
2. The standard wagering requirement for deposit bonuses is ×10 (ten times) the combined deposit and bonus amount. Individual promotions may specify a different multiplier.
3. Only specific game categories contribute fully to wagering requirements. Sportsbook bets typically contribute 100%; live casino bets contribute 10%; togel (numbers lottery) bets contribute 50%. Slot contributions vary by title and are listed in the promotion details.
4. Bonus funds expire 14 days after the date of issue unless the individual promotion specifies a different validity period. Expired bonus funds are removed without compensation.
5. Bonuses are issued on a one-per-promotion, per-account, per-household, per-device, and per-IP address basis. Attempting to claim the same promotion multiple times via duplicate accounts constitutes bonus abuse.
6. to138 reserves the right to amend, suspend, or withdraw any promotion at any time. Promotions run during the holy month of Ramadhan or surrounding Idul Fitri are subject to adjusted terms published at the start of each relevant promotion period.
7. Any winnings arising from wagers placed with bonus funds that to138 has reasonable grounds to believe were obtained through fraudulent, collusive, or abusive activity will be void and forfeited.

7Betting & Gaming Rules

1. All bets placed on to138 are final once confirmed. A bet is confirmed when the system displays a bet reference number and the amount has been deducted from your wallet balance.
2. to138 reserves the right to void any bet that was placed at an erroneous price resulting from a technical error, data feed failure, or human input mistake. Affected members will be notified and their stakes refunded promptly.
3. In-play (live) betting odds are updated in real time. Bets are accepted at the odds displayed at the moment the bet confirmation is processed by our servers, not the odds displayed at the moment you clicked "Place Bet".
4. For football markets — including bandar bola (football bookmaker) lines and voor bola (Asian handicap) — all bets are settled in accordance with the official result at the end of regulation time (90 minutes plus injury time) unless otherwise specified in the market description. Extra time and penalty shootouts do not count unless the market explicitly states "Including Extra Time".
5. Togel (Indonesia's traditional numbers lottery) draws follow the official published draw schedule. Results are final upon official publication. to138 is not responsible for delays caused by the draw organiser.
6. For live casino games powered by Evolution Gaming and Pragmatic Play Live, the rules displayed within each individual game interface govern the outcome. In the event of a disconnection during a live game round, the round will be settled based on the outcome recorded by the game server.
7. Slot games are governed by their published RTP (Return to Player) percentages and paytable rules from the originating studio. to138 does not modify the RNG behaviour of any third-party game.
8. Maximum win limits per single bet or spin may apply depending on the game or market. These limits are displayed within the relevant game or market interface before the bet is placed.

8Prohibited Conduct

The following actions are strictly prohibited on to138 and constitute a material breach of these Terms:

• Registering more than one account on the platform, whether under the same or different identity details.
• Providing false, misleading, or fraudulent information during registration, KYC, or any interaction with to138.
• Using the platform for money laundering, terrorist financing, or any other activity that violates applicable financial crime laws.
• Employing automated scripts, bots, AI-assisted betting tools, or any software that interacts with the platform in a manner not intended for human use.
• Exploiting software bugs, technical errors, or pricing mistakes for financial gain. Any winnings resulting from such exploitation are void and will be forfeited.
• Engaging in collusive betting, match-fixing, or any form of coordinated wagering strategy designed to circumvent the platform's risk controls.
• Using a Virtual Private Network (VPN) or proxy service to mask your true geographic location or to access the platform from a prohibited jurisdiction.
• Sharing your account credentials with any third party or allowing any other person to access or operate your account on your behalf.
• Engaging in abusive, threatening, discriminatory, or harassing conduct toward to138 staff, live casino dealers, or other members.
• Attempting to reverse-engineer, decompile, or otherwise access the platform's source code or underlying infrastructure.

9KYC & Identity Verification

to138 operates a robust Know Your Customer (KYC) framework to comply with international anti-money laundering standards and to protect all platform users.

1. Standard KYC Documents. To complete verification and unlock withdrawals, members must submit: (a) a clear photograph of a valid government-issued ID (KTP for Indonesian citizens is strongly preferred; a valid passport is also accepted); and (b) a selfie photograph of the account holder holding the submitted ID document.
2. Enhanced Due Diligence. For accounts with cumulative deposits or withdrawals exceeding Rp 100.000.000, to138 may request additional documentation, including proof of source of funds, before processing further transactions.
3. Verification Timeframe. Standard KYC review is completed within 24 hours of submission during business hours (WIB, Monday to Friday). Identity documents submitted outside of business hours will be reviewed on the next working day.
4. Name Matching. The name on your KYC documents must exactly match the name on the payment method used for deposits and withdrawals. Discrepancies will delay processing until resolved.
5. Document Retention. to138 retains KYC documents in accordance with its Privacy Policy. Documents are stored on encrypted servers and are accessible only to authorised compliance staff.
6. Refusal of Verification. to138 reserves the right to refuse verification and close an account if submitted documents cannot be authenticated, if documents are suspected to be fraudulent, or if the account holder's identity cannot be confirmed to the required standard.

10Responsible Gaming

to138 is committed to providing a safe, controlled, and enjoyable betting environment. We take our responsible gaming obligations seriously and provide the following player protection tools:

• Deposit Limits: Members may set daily, weekly, or monthly deposit limits via their account settings or by contacting live chat support.
• Loss Limits: Members may request a maximum loss threshold for a defined period. Once the threshold is reached, no further wagers may be placed until the period resets.
• Session Time Limits & Reality Checks: Members may configure reminders that appear at set intervals during gaming sessions to encourage awareness of time and spending.
• Cooling-Off Periods: A temporary account restriction of 24 hours, 7 days, 30 days, or a custom duration may be requested at any time. During a cooling-off period, the account cannot be used for wagering.
• Self-Exclusion: Permanent self-exclusion may be requested via live chat at any time. Self-excluded accounts are closed immediately and cannot be reopened for a minimum of six months. Any remaining verified balance will be returned.

For comprehensive guidance on recognising and managing gambling-related harm, please visit our dedicated Responsible Gaming page.

11Intellectual Property

1. All content on the to138 platform — including but not limited to the to138 brand name, logo, domain, website design, software, text, graphics, data compilations, game interfaces, odds data, and promotional materials — is the exclusive property of to138 or its licensed content suppliers and is protected by applicable intellectual property laws.
2. You are granted a limited, non-exclusive, non-transferable, revocable licence to access and use the platform solely for personal entertainment purposes in accordance with these Terms.
3. You may not copy, reproduce, republish, upload, broadcast, transmit, distribute, modify, or create derivative works from any platform content without the prior written consent of to138.
4. Game content (including graphics, audio, and game logic) made available through third-party studios such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Pocket Games Soft, and Spribe remains the intellectual property of the respective studio. to138 licences these games for presentation on the platform under agreements with those studios.
5. Any feedback, suggestions, or ideas submitted by Members regarding the platform may be used by to138 without obligation, compensation, or attribution to the submitting Member.

12Limitation of Liability

1. to138 provides the platform on an "as is" and "as available" basis. While we maintain a 99.9% uptime SLA, we do not warrant that the platform will be uninterrupted, error-free, or entirely free from technical faults at all times.
2. to138 shall not be liable for any loss or damage arising from: (a) system downtime, network outages, or scheduled maintenance periods; (b) data transmission errors caused by your internet service provider or device; (c) third-party payment processor delays outside to138's direct control; (d) events constituting force majeure, including but not limited to natural disasters, governmental actions, or cyberattacks on third-party infrastructure.
3. to138's total aggregate liability to any Member for any single claim or series of related claims shall not exceed the total net deposits made by that Member in the thirty (30) days immediately preceding the event giving rise to the claim.
4. Nothing in these Terms limits or excludes liability for death, personal injury, or fraud caused by to138's wilful misconduct or gross negligence.
5. to138 is not responsible for any tax obligations that may arise from your winnings under applicable Indonesian tax law. Members are solely responsible for reporting and paying any applicable taxes on gambling winnings.

13Privacy & Data

The collection, storage, and use of your personal data by to138 is governed by our Privacy Policy, which forms an integral part of these Terms and is incorporated herein by reference. By registering with to138, you acknowledge that you have read and understood the Privacy Policy.

Our Privacy Policy covers: the categories of personal data we collect; the lawful bases for processing; how and where data is stored; your data subject rights; cookies and tracking; and how to contact us regarding data-related queries. Please read the full policy at our Privacy Policy page.

14Amendments to These Terms

1. to138 reserves the right to modify, update, or replace these Terms at any time. Changes will be effective immediately upon publication of the revised Terms on the platform unless a specific future effective date is stated.
2. Where a material change to the Terms is made, to138 will provide reasonable notice to Members via an in-platform notification or email to the registered address on file.
3. Your continued use of the platform after any amendment constitutes your acceptance of the revised Terms. If you do not agree to the amended Terms, you must stop using the platform and may request account closure.
4. to138 will maintain an archive of prior versions of the Terms upon request by contacting our support team.

15Governing Law & Dispute Resolution

1. These Terms are governed by and construed in accordance with the laws of the jurisdiction in which to138's operating entity is incorporated and licensed, without regard to conflict-of-law principles.
2. In the event of a dispute arising from or related to these Terms or your use of the platform, the parties agree to first attempt resolution through good-faith negotiation. Disputes should be raised in the first instance by contacting our customer support team.
3. If a dispute cannot be resolved through negotiation within thirty (30) days of written notice, it shall be submitted to binding arbitration under the rules of the internationally recognised arbitration body specified by to138 at the time the dispute is lodged.
4. Notwithstanding the above, to138 reserves the right to seek injunctive relief or other equitable remedy in any court of competent jurisdiction where necessary to protect its intellectual property rights or to prevent irreparable harm.
5. These Terms are written in English. In the event of any conflict between an English version and any translated version provided for convenience, the English version shall prevail.

16Contact

If you have any questions, concerns, or complaints regarding these Terms & Conditions, please contact the to138 support team through the following channel:

For responsible gaming assistance, account restrictions, or self-exclusion requests, please also visit our Responsible Gaming page or raise the matter directly in live chat for immediate action.

For queries about how your personal data is handled, please refer to our Privacy Policy.