Privacy Policy

1 Definitions

In this Privacy Policy, the following terms carry the meanings assigned below:

• "Personal Data" means any information that relates to an identified or identifiable natural person, including but not limited to name, date of birth, email address, mobile number, bank account details, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" means jnt138, 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 jnt138 under a binding data processing agreement.
• "Platform" means the jnt138 website at https://jnt138.cam and all associated services, tools, and interfaces.
• "User" / "you" means any individual who accesses the Platform, whether as a registered account holder or as a visitor.
• "KYC" means Know Your Customer — the identity verification process required for account activation and withdrawal processing.
• "Cookie" means a small text file placed on your device by the Platform for the purposes described in Clause 11.

2 Data Controller

The Data Controller responsible for your Personal Data in connection with the jnt138 Platform is jnt138, operating under its international gaming licence. For all data protection enquiries, requests, and complaints, please contact our data protection point of contact using the details in Clause 16.

Users in the Republic of Indonesia access jnt138 on an offshore basis. jnt138 applies data protection principles consistent with internationally recognised standards to all users regardless of their country of access.

3 Data We Collect

jnt138 collects the following categories of Personal Data, depending on your level of engagement with the Platform:

We do not collect Special Category data (as defined under international data protection frameworks, including health data, biometric data for identification purposes , racial or ethnic origin, political opinions, or religious beliefs) unless you voluntarily provide such information in a support communication, in which case we process it solely to address your enquiry.

4 How We Collect Data

jnt138 collects Personal Data through the following means:

• Direct submission. Information you provide when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or update your account settings.
• Automated technical collection. When you visit the Platform, our servers automatically record Technical Data such as your IP address, browser type, device identifiers, and session activity. This happens regardless of whether you are logged in to an account.
• Cookies and similar technologies. As described in Clause 11, jnt138 uses cookies and similar tracking technologies to maintain session state, analyse platform usage, and, where you have consented, serve relevant promotional content.
• Third-party payment processors. When you initiate a deposit or withdrawal via a local Indonesian bank (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) or an e-wallet provider (OVO, DANA, GoPay, ShopeePay, LinkAja), we receive transaction confirmation data from that provider, including the masked account identifier and transaction reference.
• Identity verification providers. Where jnt138 uses a third-party KYC verification service to cross-reference the documents you submit, that provider may share a verification result and confidence score with us.
• Fraud and risk screening tools. jnt138 uses automated screening to detect account fraud, money laundering, and bonus abuse. These tools may combine data you have provided with Technical Data to generate a risk assessment.

5 Purposes of Processing

jnt138 processes your Personal Data for the following purposes:

1. Account creation and management. To register your account, verify your identity through KYC, maintain your account settings, and communicate account-related information to you.
2. Transaction processing. To process deposits in IDR via local bank transfers and e-wallets, process withdrawal requests, and maintain accurate financial records.
3. Service delivery. To provide access to the sports betting, live casino, togel (Toto Gelap — Indonesia's traditional numbers-prediction lottery), slot, and other game products available on the Platform.
4. Customer support. To respond to your enquiries, resolve disputes, process complaints, and provide assistance in both English and Indonesian (Bahasa Indonesia).
5. Legal and regulatory compliance. To meet anti-money laundering (AML) obligations, fraud prevention duties, and record-keeping requirements under jnt138's international gaming licence, and to respond to lawful requests from regulatory or law enforcement authorities.
6. Responsible gaming. To monitor betting patterns that may indicate problem gambling, enforce deposit limits and self-exclusion orders, and deliver responsible gaming prompts where appropriate.
7. Security and fraud prevention. To detect and investigate suspected fraud, account takeovers, bonus abuse, and other prohibited conduct as defined in the jnt138 Terms & Conditions.
8. Platform improvement. To analyse aggregate usage patterns, diagnose technical issues, test new features, and improve the overall performance and user experience of the Platform.
9. Marketing communications. Where you have opted in, to send you promotional emails or SMS messages about bonuses, seasonal promotions (such as those tied to Idul Fitri, Ramadhan, or Indonesian Independence Day on 17 August), and platform updates. You may opt out at any time via your account settings or by contacting support.

6 Legal Basis for Processing

jnt138 processes your Personal Data on the following legal bases, consistent with internationally recognised data protection principles:

• Contractual necessity. Processing that is required to perform our contract with you — including account registration, KYC, transaction processing, and service delivery (Purposes 1, 2, 3, and 4 in Clause 5).
• Legal obligation. Processing required to comply with AML, fraud prevention, licensing, and record-keeping obligations (Purpose 5).
• Legitimate interests. Processing for responsible gaming monitoring, fraud and security screening, and platform improvement (Purposes 6, 7, and 8), where those interests are not overridden by your rights and interests.
• Consent. Marketing communications (Purpose 9) are sent only where you have given explicit opt-in consent. You may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7 Data Sharing

jnt138 does not sell, rent, or trade your Personal Data to third-party marketers under any circumstances. We may share your Personal Data with the following categories of recipients only to the extent necessary for the relevant purpose:

• Payment processors and banking partners. Local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction data necessary to execute deposits and withdrawals.
• KYC and identity verification providers. Third-party KYC services receive the identity documents you submit and return a verification result to jnt138. These providers are contractually bound to process your data only for KYC purposes.
• Game content providers. Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft operate the game engines you interact with. Technical session data (game outcomes, bet amounts, session duration) is shared with these providers to the extent required to operate the game and resolve disputes.
• Fraud and risk screening services. Automated risk tools may receive Technical Data and transaction patterns to generate fraud-risk scores. No raw identity documents are shared with these services.
• Legal and regulatory authorities. jnt138 will disclose Personal Data to regulatory bodies, law enforcement agencies, or courts when required to do so by a valid legal process, court order, or applicable law. Where legally permitted, jnt138 will notify you of such a disclosure.
• Professional advisers. Lawyers, auditors, and accountants acting in a professional capacity may have access to Personal Data under binding confidentiality obligations.
• Business successors. In the event of a merger, acquisition, or sale of all or part of jnt138's business, your Personal Data may be transferred to the successor entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

8 International Data Transfers

jnt138 operates internationally, and your Personal Data may be stored on servers or processed by service providers located outside the Republic of Indonesia. Whenever Personal Data is transferred internationally, jnt138 takes steps to ensure an adequate level of protection is applied, including:

• Transferring data only to countries or recipients that provide a level of data protection considered adequate under recognised international standards.
• Implementing contractual data protection clauses with Data Processors that receive your data outside your home jurisdiction.
• Applying technical and organisational security measures (described in Clause 10) consistently regardless of where data is stored or processed.

By using the jnt138 Platform, you acknowledge that your Personal Data may be transferred to and processed in countries outside Indonesia. jnt138 will not make such transfers unless the safeguards described above are in place.

9 Data Retention

jnt138 retains your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following standard retention periods apply:

When the applicable retention period expires, Personal Data is either securely deleted or irreversibly anonymised so that it can no longer be attributed to any individual. Anonymised aggregate data (e.g., platform usage statistics) may be retained indefinitely.

10 Data Security

jnt138 implements a layered set of technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport layer encryption. All data transmitted between your browser and the jnt138 Platform is encrypted using TLS 1.2 or higher. Our SSL certificate is visible in your browser's address bar.
• Data encryption at rest. Sensitive Personal Data — including KYC documents and financial records — is encrypted at rest using industry-standard algorithms.
• Access controls. Access to Personal Data is restricted on a need-to-know basis. Staff and contractors who handle Personal Data are subject to binding confidentiality obligations and receive regular data protection training.
• Two-factor authentication. Administrative access to systems containing Personal Data requires multi-factor authentication.
• Penetration testing. jnt138 commissions regular third-party security assessments and penetration tests to identify and remediate vulnerabilities before they can be exploited.
• Incident response. jnt138 maintains a documented data breach response procedure. In the event of a breach that is likely to result in a high risk to your rights and freedoms, you will be notified without undue delay in accordance with applicable obligations.

11 Cookies & Tracking Technologies

jnt138 uses cookies and similar technologies (including local storage and session storage) to operate the Platform effectively and to understand how users interact with it. The following categories of cookies are in use:

• Strictly necessary cookies. Required for the Platform to function. They maintain your login session, remember your account preferences, and enable secure page navigation. These cookies cannot be disabled without breaking core Platform functionality.
• Performance and analytics cookies. Used to measure page load times, identify technical errors, and understand aggregate traffic patterns. The data collected is anonymised and used solely to improve Platform performance.
• Functional cookies. Remember your language preference, display preferences, and other settings so you do not need to re-enter them on each visit.
• Marketing cookies. Used only where you have given explicit consent, to track whether you have engaged with a promotional communication and to avoid showing you duplicate offers. jnt138 does not use third-party advertising network cookies.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform. Disabling other categories of cookies will not prevent you from accessing core Platform features but may reduce personalisation.

jnt138 does not use cross-site tracking cookies or fingerprinting techniques for the purpose of building advertising profiles.

12 Your Data Rights

Subject to applicable law and jnt138's legal retention obligations, you have the following rights in respect of your Personal Data:

• Right of access. You may request a copy of the Personal Data that jnt138 holds about you, together with information about how it is being processed.
• Right to rectification. You may request correction of any inaccurate or incomplete Personal Data. For identity data, corrections must be supported by updated KYC documentation.
• Right to erasure. You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent (for consent-based processing). Erasure requests will be fulfilled unless jnt138 is required to retain the data under AML, licensing, or other legal obligations.
• Right to restrict processing. You may request that jnt138 limit the processing of your Personal Data to storage only, pending resolution of a dispute about its accuracy or the lawfulness of its processing.
• Right to data portability. Where processing is based on your consent or contractual necessity and is carried out by automated means, you may request a copy of your Personal Data in a structured, commonly used, machine-readable format.
• Right to object. You may object to processing based on legitimate interests at any time on grounds relating to your particular situation. You may also object to direct marketing communications at any time, without giving a reason.
• Right to withdraw consent. Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Rights Request". jnt138 will respond within 30 days of receiving a valid request. We may ask you to verify your identity before actioning your request.

13 Minors

The jnt138 Platform is strictly intended for adults aged 21 and over. jnt138 does not knowingly collect Personal Data from any person under the age of 21. If you believe that a person under 21 has registered an account or provided Personal Data to jnt138, please notify us immediately at [email protected]. Upon confirmation, jnt138 will suspend the relevant account, delete the associated Personal Data to the extent permitted by law, and report the matter to relevant authorities where required.

Age verification is a mandatory component of the jnt138 KYC process. No account may be activated for wagering purposes without satisfactory confirmation that the account holder is 21 or older.

14 Third-Party Services

The jnt138 Platform integrates third-party game content from studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft, as well as third-party payment infrastructure from local Indonesian banking and e-wallet partners. These third parties operate under their own privacy policies in respect of data processed within their own systems.

jnt138 does not control the data practices of third-party studios or payment providers beyond the contractual obligations described in Clause 7. jnt138 is not responsible for the privacy practices of any third party that is not acting as a Data Processor under a direct contractual arrangement with jnt138.

This Privacy Policy does not apply to any website or service that is not operated by jnt138, even if a link to that service appears on the Platform. jnt138 does not include external links on the Platform as a matter of policy.

15 Policy Amendments

jnt138 reserves the right to update or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. When material changes are made, jnt138 will notify registered users by email to the address on file and will display a prominent notice on the Platform for at least 7 days before the changes take effect.

The date of the most recent update is shown at the top of this page. We encourage you to review this Policy periodically. Your continued use of the Platform after the effective date of any updated Policy constitutes your acknowledgement of those changes. If you do not accept the updated Policy, you should cease using the Platform and may request withdrawal of your Real-Money Balance before the effective date.

16 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or your Personal Data, please contact the jnt138 data protection point of contact. Our support team is available 24 hours a day, 7 days a week in both English and Indonesian (Bahasa Indonesia).

If you are not satisfied with jnt138's response to a privacy complaint, you may escalate the matter to the data protection supervisory authority in the jurisdiction in which jnt138 holds its gaming licence, or to such other competent authority as may be applicable in your jurisdiction.