jin138 Privacy Policy

jin138 ("we", "us", "our") operates the online betting Platform accessible at https://jin138.cam. As part of delivering our services — which include sports betting, live casino games, togel (Indonesia's traditional numbers lottery) markets, and slot games — we necessarily process certain personal information about our members and website visitors.

This Privacy Policy explains how jin138 collects, processes, stores, shares, and protects personal data. It applies to all individuals who visit the Platform, register an account, use our services, or interact with our customer support team, regardless of the device or network used to access the Platform.

This policy should be read alongside our Terms & Conditions. By registering an account or continuing to use the Platform after this policy has been made available to you, you acknowledge that you have read and understood its contents. If you disagree with any aspect of this policy, please discontinue use of the Platform and contact us to arrange account closure and data handling.

jin138 primarily serves English-preference players across Indonesia — including members in Jakarta, Surabaya, Bandung, Medan, Bali, and other cities. References to "applicable law" in this policy refer to internationally recognized data protection standards, as jin138 is operated internationally and does not make specific claims regarding compliance with Indonesian domestic legislation beyond what is required by our operational jurisdiction.

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

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"). This includes, but is not limited to, name, date of birth, email address, phone number, payment details, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transfer, and deletion.
• "Data Controller" means jin138, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of jin138, such as payment processors and KYC verification providers.
• "KYC" means Know Your Customer — the identity and age verification process required before withdrawals are processed.
• "Platform" means the jin138 website at https://jin138.cam and all associated services, dashboards, and support channels.
• "Cookie" means a small text file placed on your device by the Platform for purposes described in Clause 8.
• "AML" means Anti-Money Laundering — the regulatory framework and internal procedures jin138 applies to detect and prevent financial crime.

jin138 collects Personal Data through multiple channels. The table below summarizes the categories of data we collect and their source:

jin138 does not intentionally collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health data. If such data is incidentally included in a document you submit (for example, a national ID card that indicates religion), it will not be extracted or stored as a separate data field.

We do not collect personal data about third parties from our members. Please do not submit personal data belonging to another individual unless you have obtained their explicit consent to do so.

jin138 processes your Personal Data only for the purposes listed below. We do not use your data in ways that are incompatible with these stated purposes without first notifying you and, where required, obtaining your consent.

• Account Management: To create, maintain, and administer your member account, including authentication, password recovery, and account-setting changes.
• Service Delivery: To provide sports betting markets, casino games, togel lottery, and slot services; to calculate and settle wagers; to credit winnings to your account balance.
• Identity & Age Verification (KYC): To verify that you are who you claim to be and that you are at least 21 years of age, in compliance with our regulatory obligations and responsible-gaming commitments.
• Payment Processing: To process deposits and withdrawals via local Indonesian bank transfers (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and to reconcile transaction records.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, money laundering, collus ion, account takeover attempts, and other prohibited activities as defined in our Terms & Conditions.
• Regulatory Compliance: To meet our AML obligations, respond to lawful requests from regulatory or law enforcement authorities, and maintain records required by our operating licence conditions.
• Customer Support: To respond to your queries, complaints, and support requests in a timely and effective manner, and to maintain records of support interactions for quality-assurance purposes.
• Responsible Gaming: To monitor betting patterns for indicators of problem gambling, to apply limits and restrictions requested through our Responsible Gaming Tools, and to action self-exclusion requests.
• Platform Improvement: To analyse aggregated, anonymized usage data to improve the Platform's performance, user interface, and game offering. Individual behavioural data is not used for this purpose without anonymization.
• Marketing Communications: To send you promotional offers, bonus notifications, and Platform updates, but only where you have given explicit consent to receive such communications. You may withdraw this consent at any time by updating your communication preferences within your Account dashboard or by contacting support.

jin138 relies on one or more of the following legal bases when processing your Personal Data:

• Contractual Necessity: Processing is necessary to perform the contract between you and jin138 — specifically, to operate your account, settle bets, and facilitate deposits and withdrawals. Without this processing, we cannot provide our services to you.
• Legal Obligation: Processing is required to comply with applicable AML regulations, age-verification mandates, record-keeping obligations, and lawful requests from competent authorities.
• Legitimate Interests: Processing is necessary for jin138's legitimate business interests, including fraud prevention, platform security, responsible-gaming monitoring, and improving service quality — provided those interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and certain non-essential cookie categories, we rely on your freely given, informed, and specific consent. You may withdraw consent at any time without affecting the legality of processing that occurred prior to withdrawal.

Where we rely on legitimate interests as our legal basis, we conduct a balancing assessment to confirm that our interests do not disproportionately impact your privacy rights. Records of these assessments are maintained by jin138's data governance team.

jin138 does not sell your Personal Data to any third party. We may share your data with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment Processors & Banking Partners: Indonesian bank partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the financial data necessary to execute your deposit and withdrawal instructions. These entities are subject to their own regulatory obligations and privacy frameworks.
• KYC & Identity Verification Providers: Specialized third-party KYC service providers process identity documents and liveness checks on our behalf. These providers act as Data Processors under binding data processing agreements that restrict their use of your data to KYC verification only.
• Game Content Providers: Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive anonymized session identifiers to facilitate game delivery. These providers do not receive your identity or financial data.
• IT Infrastructure & Cloud Providers: jin138's hosting, server, and cloud infrastructure providers process data on our behalf under strict data processing agreements. Physical and logical security controls govern all data stored in these environments.
• Regulatory & Law Enforcement Authorities: jin138 will disclose Personal Data to competent regulatory bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or regulatory instruction. Where permitted by law, jin138 will notify you of such disclosure.
• Professional Advisers: Lawyers, auditors, and compliance consultants engaged by jin138 may access Personal Data to the minimum extent necessary to provide their professional services, subject to strict confidentiality obligations.

In all cases where data is shared with third parties, jin138 implements contractual safeguards — including data processing agreements — to ensure that recipients process your data only for the specified purpose, maintain appropriate security standards, and do not onward-transfer your data without authorisation.

jin138 is operated internationally, and your Personal Data may be transferred to and processed in countries outside Indonesia. Where such transfers occur, jin138 implements appropriate safeguards to ensure that your data receives a level of protection consistent with internationally recognized data protection principles.

Safeguards applied to international transfers include:

• Standard contractual clauses incorporated into data processing agreements with third-party recipients.
• Transfer only to jurisdictions that maintain adequate data protection frameworks as assessed by jin138's compliance team.
• Technical measures including end-to-end encryption of data in transit and at rest during any cross-border transfer.

By using the Platform, you acknowledge that your Personal Data may be transferred internationally as described in this clause. If you have concerns about specific transfer arrangements, please contact us at the address in Clause 14 and we will provide further information.

jin138 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are in use:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cookies cannot be disabled without breaking core Platform functionality.
• Analytical / Performance Cookies: Used to collect aggregated, anonymized data about how visitors interact with the Platform — including pages visited, session duration, and error events. This data helps jin138 identify and resolve performance issues. Individual users are not identifiable from this data.
• Functional Cookies: Used to remember your Platform preferences such as language setting, odds format, and display options. These cookies improve your user experience but are not essential.

jin138 does not use third-party advertising cookies, retargeting pixels, or social media tracking scripts. No cookie data collected on the Platform is shared with advertising networks.

You can manage cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies will prevent you from logging into your Account. For guidance on managing cookies in your specific browser, refer to the browser's official help documentation.

jin138 retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and our regulatory obligations. The following retention periods apply as a general guide:

• Account & Identity Data: Retained for the duration of your active account plus a minimum of 5 years following account closure, in compliance with standard AML record-keeping requirements.
• KYC Verification Documents: Retained for the duration of your active account plus 5 years, or longer if required by a specific regulatory instruction or ongoing investigation.
• Financial & Transaction Records: Retained for a minimum of 5 years following the date of each transaction, consistent with AML compliance obligations.
• Support Communications: Retained for 3 years from the date of the most recent interaction, for quality-assurance and dispute-resolution purposes.
• Marketing Consent Records: Retained until you withdraw consent and for 2 years thereafter as evidence of the consent previously given.
• Technical & Log Data: Retained for 12 months on a rolling basis, after which it is automatically purged or anonymized.

At the end of the applicable retention period, Personal Data is securely deleted or anonymized so that it can no longer be associated with any identifiable individual. Anonymized data may be retained indefinitely for statistical and analytical purposes.

Jin138 recognizes and respects the following rights with respect to your Personal Data. To exercise any of these rights, please contact us at the details provided in Clause 14. We will respond within 30 days of receiving a valid request.

• Right of Access: You may request a copy of the Personal Data jin138 holds about you, along with information about how it is processed.
• Right to Rectification: If any of your Personal Data is inaccurate or incomplete, you may request that we correct or update it. Minor details such as contact information can be updated directly through your Account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data. This right is subject to overriding legal obligations — we may be required to retain certain data for AML compliance even after account closure.
• Right to Restrict Processing: In certain circumstances, you may request that jin138 limit the processing of your data while a dispute about its accuracy or lawfulness is resolved.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, and is carried out by automated means, you may request a machine-readable copy of your data for transfer to another service provider.
• Right to Object: You may object to processing carried out on the basis of legitimate interests. jin138 will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), you may withdraw your consent at any time without affecting the lawfulness of prior processing.

To submit a data subject request, please email support@jin138.cam with the subject line "Data Subject Request" and include your full name, registered email address, and a description of the right you wish to exercise. We may need to verify your identity before processing the request.

The Platform is strictly intended for adults aged 21 and over. jin138 does not knowingly collect Personal Data from any individual under the age of 21. Our registration process includes an age declaration step, and KYC verification is used to confirm that all members meet the minimum age requirement before withdrawals are processed.

If jin138 discovers or is notified that a member is under the age of 21, that account will be immediately suspended, all associated data will be reviewed by our compliance team, and any balance will be handled in accordance with our regulatory obligations. Winnings generated by an underage account will be forfeited.

If you believe that a person under 21 has registered an account on the Platform, please contact us immediately at support@jin138.cam. We treat such reports as urgent compliance matters and will investigate and act without delay.

jin138 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data in transit between your device and the Platform is encrypted using industry-standard SSL/TLS protocols.
• Encryption at Rest: Sensitive data fields — including financial data, KYC documents, and authentication credentials — are encrypted at rest using AES-256 or equivalent standards.
• Access Controls: Access to systems containing Personal Data is restricted on a need-to-know basis. All staff with data access undergo background screening and regular data-security training.
• Two-Factor Authentication (2FA): Members are encouraged to enable 2FA on their accounts. jin138's internal administrative systems require 2FA for all staff access.
• Penetration Testing: jin138 commissions regular independent penetration tests to identify and remediate vulnerabilities in Platform infrastructure.
• Intrusion Detection: Automated intrusion-detection and anomaly-monitoring systems operate continuously across jin138's server infrastructure.
• Incident Response: jin138 maintains a formal data-breach incident response procedure. In the event of a breach that poses a risk to your rights and freedoms, we will notify affected individuals within 72 hours of becoming aware of the breach, to the extent practicable.

While jin138 takes all reasonable precautions to protect your data, no online service can guarantee absolute security. You are responsible for maintaining the confidentiality of your own Account login credentials and for reporting any suspected unauthorized access to your Account immediately.

jin138 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, Platform features, or applicable regulatory requirements. When material changes are made, jin138 will notify registered members via a prominent notice on the Platform and, where practicable, via email to the address registered to your Account.

The "Last Updated" date at the top of this policy will be revised whenever changes are made. We encourage you to review this page periodically to stay informed about how we protect your Personal Data. For minor, non-material clarifications, jin138 may update the policy without separate notification, relying on the periodic-review expectation.

Continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of and agreement to the updated version. If you disagree with the revised policy, please cease use of the Platform and contact us to arrange account closure.

If you have any questions, concerns, or complaints about this Privacy Policy or about how jin138 handles your Personal Data, please contact our dedicated data privacy team using the details below:

If you are unsatisfied with our response to a privacy complaint, you may have the right to escalate the matter to a relevant data protection supervisory authority in your jurisdiction. jin138 will cooperate fully with any such supervisory investigation.

For responsible gaming concerns or self-exclusion requests, please visit our Responsible Gaming page. For questions about your account or financial transactions, please refer to our FAQ page or contact live chat support directly through the Platform.