jnt138 Privacy Policy

1 Introduction

jnt138 ("the Platform", "we", "us", "our") operates the online casino and sportsbook platform accessible at jnt138.bet, serving players primarily in Indonesia. We take the protection of your personal data seriously and are committed to processing it in a manner consistent with applicable data protection principles — including purpose limitation, data minimisation, accuracy, integrity, and confidentiality.

This Privacy Policy applies to all personal data collected from individuals ("you", "your", "Member") who interact with the jnt138 platform, including through account registration, deposits and withdrawals, gameplay, live chat support, and any promotional activity. It should be read alongside our Terms & Conditions, which govern the overall relationship between jnt138 and its Members.

If you have any questions about how jnt138 handles your personal data, or if you wish to exercise any of your rights outlined in Section 12, please contact our Data Protection team at the details provided in Section 16.

2 Definitions

• "Personal Data" means any information that identifies or can be used to identify a specific natural person, directly or indirectly. This includes name, email address, national identity number, IP address, device identifiers, and financial transaction records.
• "Processing" means any operation performed on personal data — including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" means jnt138, the entity that determines the purposes and means of processing personal data collected through the platform.
• "Data Processor" means a third party that processes personal data on behalf of jnt138, pursuant to a written data processing agreement.
• "KYC" means Know Your Customer — the identity and age verification process required before a Member's first withdrawal is processed.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement to the processing of personal data for a stated purpose.
• "IDR" means Indonesian Rupiah, the sole transactional currency of the jnt138 platform.

3 Data We Collect

jnt138 collects the following categories of personal data:

Category	Examples	When Collected
Identity Data	Full name, date of birth, nationality, KTP number or passport number	Registration & KYC verification
Contact Data	Email address, mobile phone number	Registration
Financial Data	Bank account numbers (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata), e-wallet identifiers (GoPay, OVO, DANA, ShopeePay, LinkAja), transaction amounts in IDR	Deposits & withdrawals
Verification Data	Scanned KTP, passport, selfie with document, proof of address	KYC verification
Technical Data	IP address, browser type and version, device type, operating system, session duration, login timestamps	Platform access
Usage Data	Pages visited, games played, bets placed, wager amounts, game outcomes, bonus activity	Ongoing platform use
Communications Data	Live chat transcripts, support email exchanges, survey responses	Support interactions
Marketing Preferences	Opt-in / opt-out status for promotional emails and push notifications	Registration & account settings

jnt138 does not intentionally collect sensitive personal data — such as racial or ethnic origin, religious beliefs, health data, or sexual orientation — unless explicitly required by a regulatory obligation (for example, to process a responsible gaming self-exclusion referral to a third-party support organisation).

4 How We Collect Data

4.1 Directly from You

The majority of personal data jnt138 holds is provided directly by you during account registration, KYC verification, deposit and withdrawal transactions, or when you contact jnt138 support via live chat or email. You are not required by law to provide this data, but we are unable to open or maintain an account for you without it.

4.2 Automatically During Platform Use

Technical and usage data is collected automatically as you interact with the jnt138 platform, primarily through server logs, session tracking, and first-party cookies. This data is used for fraud prevention, security monitoring, platform performance analysis, and responsible gaming pattern detection.

4.3 From Third Parties

jnt138 may receive data about you from third-party partners in specific circumstances, including:

• Payment processors (to confirm the status and ownership of your deposit or withdrawal transaction).
• KYC and identity verification providers (to verify the authenticity of your submitted identity documents).
• Fraud detection and AML (Anti-Money Laundering) screening providers.
• Self-exclusion registers or responsible gaming networks, if you have registered an exclusion that applies to jnt138.

5 Purposes of Processing

jnt138 processes your personal data for the following clearly defined purposes:

• Account creation and management: To register your account, authenticate your identity, and manage your membership status throughout your relationship with jnt138.
• Payment processing: To process deposits in IDR via Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallets (GoPay, OVO, DANA, ShopeePay, LinkAja), and to process withdrawal requests back to your verified payment method.
• KYC and age verification: To verify that you are at least 21 years of age and are who you claim to be, as required before processing your first withdrawal.
• Regulatory compliance and AML: To comply with applicable anti-money laundering (AML), counter-terrorism financing (CTF), and fraud prevention obligations under applicable international regulations.
• Responsible gaming: To monitor gameplay patterns that may indicate problem gambling behaviour, to enforce deposit limits and session caps you have set, and to maintain self-exclusion records.
• Customer support: To respond to your queries, complaints, and requests through live chat and email.
• Platform security: To detect and prevent unauthorised account access, fraud, collusion, multi-accounting, and other prohibited conduct described in the jnt138 Terms & Conditions.
• Product improvement: To analyse aggregated usage patterns, optimise the game lobby layout, improve transaction processing speeds, and enhance the overall player experience.
• Direct marketing: To send you promotional offers, bonus notifications, and seasonal campaign communications — but only where you have opted in to receive such communications and only through your registered email address or account notification centre.

6 Legal Basis for Processing

jnt138 relies on the following legal bases for processing personal data:

• Contract performance: Processing necessary to register your account, process transactions, and deliver the platform services you have contracted for.
• Legal obligation: Processing required to comply with KYC, AML, CTF, and other applicable regulatory requirements.
• Legitimate interests: Processing for fraud prevention, security monitoring, responsible gaming oversight, and product analytics — where our legitimate interests are not overridden by your rights.
• Consent: Processing for direct marketing communications, where you have explicitly opted in via your account settings. You may withdraw this 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 parties for their own marketing purposes. We share personal data only in the following circumstances and only to the extent strictly necessary:

7.1 Service Providers (Data Processors)

jnt138 engages trusted third-party service providers who process personal data on our behalf under binding data processing agreements that require them to apply the same level of data protection as jnt138. These providers include:

• Payment processing partners handling IDR transactions via local Indonesian banks and e-wallets.
• KYC and identity verification technology providers.
• Fraud detection, AML screening, and risk management platforms.
• Cloud hosting and data centre infrastructure providers.
• Customer support platform providers (live chat software).
• Email delivery service providers used to send transactional and promotional communications.

7.2 Game Content Partners

Certain technical data (such as session tokens and game round identifiers) is shared with game studio partners — including Evolution Gaming, Pragmatic Play, PG Soft, Microgaming, NetEnt, and Spribe — solely to the extent necessary to deliver their game content within the jnt138 platform environment. These partners do not receive your full identity profile or financial transaction data.

7.3 Legal and Regulatory Disclosure

jnt138 may disclose personal data to law enforcement agencies, regulatory bodies, courts, or other public authorities when required to do so by a legally binding order, warrant, or regulatory directive. Where permitted by law, jnt138 will notify the affected Member before complying with such a request.

7.4 Business Transfers

In the event of a merger, acquisition, asset sale, or restructuring involving jnt138's operating entity, personal data held by jnt138 may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and of any material change to how your data is processed as a result.

8 International Data Transfers

Because jnt138 operates as an internationally licensed platform and uses global technology service providers, your personal data may be transferred to and processed in countries outside Indonesia. Where such transfers occur, jnt138 ensures that appropriate safeguards are in place — including contractual clauses that require the recipient to protect your data to a standard equivalent to that applied by jnt138 — before any transfer takes place.

If you have concerns about specific international transfers of your personal data, please contact our Data Protection team using the details in Section 16.

9 Data Retention

jnt138 retains 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 retention periods apply as a general guideline:

Data Category	Retention Period	Basis
Account identity and contact data	Duration of membership + 5 years after account closure	Legal obligation (AML/KYC record-keeping)
Financial transaction records	Duration of membership + 7 years after account closure	Legal obligation (financial record-keeping)
KYC verification documents	Duration of membership + 5 years after account closure	Legal obligation (AML/KYC)
Technical and usage logs	13 months from the date of collection	Legitimate interests (security, fraud prevention)
Customer support communications	3 years from the date of the interaction	Legitimate interests (dispute resolution)
Marketing preference records	Until opt-out or account closure, whichever is earlier	Consent
Self-exclusion records	Duration of exclusion + 5 years minimum	Legal obligation (responsible gaming)

At the end of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual.

10 Security Measures

jnt138 applies technical and organisational security measures proportionate to the sensitivity of the personal data it holds. These measures include:

• Encryption in transit: All data transmitted between your browser or app and the jnt138 platform is encrypted using TLS 1.2 or higher (256-bit SSL).
• Encryption at rest: Sensitive personal data stored on jnt138 infrastructure is encrypted at rest using industry-standard algorithms.
• Access controls: Access to personal data is restricted to jnt138 personnel and authorised service providers on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication for administrative systems.
• Password protection: Member account passwords are stored as salted cryptographic hashes — jnt138 staff cannot read your password in plaintext.
• Penetration testing: jnt138's infrastructure undergoes regular third-party security assessments 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 risk to your rights, we will notify affected Members without undue delay.

11 Cookies & Tracking Technologies

11.1 What Are Cookies

Cookies are small text files placed on your device when you visit the jnt138 platform. They allow the platform to remember your session state, preferences, and interaction history across page loads and visits. jnt138 uses only first-party cookies — we do not deploy third-party advertising or behavioural tracking cookies from ad networks.

11.2 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function — including session authentication tokens, CSRF protection tokens, and load balancer routing cookies. These cannot be disabled without breaking core platform functionality.
• Performance Cookies: Used to collect anonymised analytics on page load times, error rates, and navigation paths — helping the jnt138 technical team identify and resolve performance bottlenecks. No personally identifiable data leaves jnt138's own infrastructure via these cookies.
• Preference Cookies: Remember your display preferences such as language setting, game lobby sort order, and notification preferences across sessions.
• Responsible Gaming Cookies: Store session timer state and deposit limit progress locally on your device to support the responsible gaming tools available on the platform.

11.3 Managing Cookies

You can control cookie behaviour through your browser settings. Blocking strictly necessary cookies will impair or prevent access to the jnt138 platform. Blocking performance or preference cookies will not prevent platform access but may degrade your experience. Detailed browser-specific cookie management instructions are available through your browser's help documentation.

12 Your Rights

As a data subject, you hold the following rights in relation to personal data that jnt138 holds about you. To exercise any of these rights, please submit a written request to the contact details in Section 16. jnt138 will respond within 30 days of receiving a valid request.

• Right of Access: You may request a copy of the personal data jnt138 holds about you, along with information about how it is processed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct it.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where processing is unlawful — subject to overiding legal retention obligations.
• Right to Restriction: You may request that jnt138 restrict (pause) the processing of your personal data in certain circumstances, such as while rectification request is being resolved.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request that your personal data be provided to you in a structured, 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 also have an unconditional right to object to direct marketing processing at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

Please note that some rights are subject to limitations — for example, jnt138 cannot erase data that it is legally required to retain under AML or financial record-keeping regulations. Where a request cannot be fulfilled in full, jnt138 will explain the specific reason in writing.

13 Minors

The jnt138 platform is strictly intended for individuals who are at least 21 years of age. jnt138 does not knowingly collect personal data from individuals under 21. If jnt138 discovers or is notified that personal data has been collected from an individual under 21, that account will be closed immediately, the data will be deleted without undue delay (subject to any AML reporting obligations), and any winings will be forfeited.

If you are a parent or guardian and believe that a minor has registered a jnt138 account, please contact us immediately at the details provided in Section 16 so that appropriate action can be taken without delay.

14 Third-Party Links

The jnt138 platform does not contain links to external third-party websites as a general rule. In the event that any third-party content or reference appears on the platform, jnt138 has no control over the privacy practices of those third parties and accepts no responsibility for their data handling. If you navigate away from jnt138 to a third-party site by any means, we strongly recommend reviewing that site's own privacy policy before submitting any personal information.

15 Amendments to This Policy

jnt138 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform functionality. When material changes are made, jnt138 will notify registered Members by email to their registered address and/or by displaying a prominent notice on the platform for a minimum of 7 days before the updated policy takes effect. The "Last updated" date at the top of this page will always reflect the most recent revision. Your continued use of the jnt138 platform after the effective date of any revision constitutes acceptance of the updated Privacy Policy.

16 Contact

For all privacy-related enquiries, data subject access requests, or complaints regarding jnt138's handling of your personal data, please contact our Data Protection team through the following channel:

• Email: [email protected] (plain text — not a clickable link). Please include "Privacy Request" or "Data Subject Access Request" in your subject line to ensure prompt routing to the correct team.
• Live Chat: Available 24/7 on the jnt138 platform. For data protection matters, our support agents will escalate your request to the Data Protection team within one business day.

jnt138 aims to acknowledge all privacy-related requests within 5 business days (WIB) and to provide a substantive response within 30 days. For complex requests — such as a full Subject Access Request involving large volumes of historical data — the response period may be extended by an additional 30 days, in which case jnt138 will inform you of the extension and the reason for it before the initial30-day period expires.