Privacy Policy — jin3

1 Definitions

For the purposes of this Policy, the following terms shall carry the meanings set out below:

• "Personal Data" means any information that can identify you directly or indirectly as an individual, including your name, date of birth, email address, phone number, residential address, IP address, device identifiers, and payment account details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "Data Controller" means jin3, as the entity that determines the purposes and means of processing Personal Data collected via the Platform.
• "Data Processor" means any third-party service provider that processes Personal Data on jin3's behalf in accordance with written contractual instructions.
• "KYC Data" means identity verification documents submitted by a Member as part of the Know Your Customer process, including government-issued identification, proof of address, and payment method verification.
• "Transaction Data" means records of all financial activity conducted through a Member's Account, including deposit amounts, withdrawal requests, payment channels used (e.g., BCA, Mandiri, OVO, GoPay), timestamps, and reference numbers.
• "Usage Data" means information collected automatically regarding how you interact with the Platform, including pages visited, games played, betting history, session duration, and device and browser metadata.

2 Scope & Application

This Policy applies to all Personal Data collected by jin3 in connection with the operation of the Platform and related services. It applies to all Members who have registered an Account on jin3, as well as to visitors who browse the Platform without registering.

This Policy should be read in conjunction with jin3's Terms & Conditions, which set out the contractual relationship between jin3 and its Members. In the event of any conflict between this Policy and the Terms & Conditions with respect to data handling, this Policy shall prevail.

3 Personal Data We Collect

jin3 collects the following categories of Personal Data:

3.1 Registration Data

When you create an Account on jin3, we collect the following information:

• Full legal name (as it appears on your government-issued identification);
• Date of birth (required to verify that you are at least 21 years of age);
• Email address;
• Mobile phone number;
• Residential address (city, province, postal code — Indonesia);
• Preferred username and a hashed (never plain-text) version of your chosen password.

3.2 KYC Verification Data

To comply with our Know Your Customer obligations and to enable withdrawal processing, we collect:

• Copies of government-issued photo identification (Indonesian KTP, passport, or SIM);
• Proof of residential address (bank statement or utility bill dated within 90 days);
• Payment method verification (screenshot or statement confirming ownership of the bank account or e-wallet used for deposits).

3.3 Transaction Data

We maintain complete records of all financial transactions conducted through your Account, including:

• Deposit amounts and timestamps;
• Payment channels used (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja);
• Withdrawal requests, amounts, destination accounts, and processing status;
• Bonus credits and wagering activity records.

3.4 Usage & Technical Data

When you use the Platform, we automatically collect technical data, including:

• IP address and approximate geographic location (city/region level);
• Device type, operating system, and browser type;
• Session start/end times and session duration;
• Pages visited, games accessed (including sports bets, togel draws, and live casino sessions), and click-stream data;
• Betting history and wagering patterns.

3.5 Communication Data

If you contact our support team, we retain records of those communications, including the content of support tickets, live chat transcripts, and any documentation you provide in connection with a support query or complaint.

4 How We Collect Your Data

jin3 collects Personal Data through the following channels:

• Directly from you: when you register an Account, complete KYC verification, make a deposit or withdrawal, contact our support team, or respond to a promotional communication;
• Automatically: through cookies, server logs, and analytics tools that record your interaction with the Platform's pages and features;
• From payment providers: transaction confirmation data received from BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja when you initiate a deposit or withdrawal;
• From identity verification partners: when applicable, data received from third-party KYC verification service providers engaged by jin3 to validate identity documents.

5 How We Use Your Personal Data

jin3 uses the Personal Data it collects for the following specific purposes:

Purpose	Data Categories Used
Account creation and management	Registration Data
Age and identity verification (KYC)	Registration Data, KYC Data
Processing deposits and withdrawals	Registration Data, KYC Data, Transaction Data
Fraud detection and prevention	All categories
Responsible gaming monitoring	Usage Data, Transaction Data
Customer support and dispute resolution	Registration Data, Communication Data, Transaction Data
Platform improvement and analytics	Usage & Technical Data (anonymized where possible)
Promotional communications (where consent given)	Registration Data, Usage Data
Legal and regulatory compliance	All categories

jin3 does not use your Personal Data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for the new processing activity.

6 Legal Basis for Processing

jin3 processes your Personal Data on the basis of one or more of the following lawful grounds:

• Contractual necessity: processing is required to perform our obligations under the Terms & Conditions, including operating your Account, processing transactions, and providing access to Platform features;
• Legitimate interests: processing is necessary for jin3's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided those interests are not overridden by your own data protection rights;
• Legal obligation: processing is required to comply with applicable legal and regulatory requirements, including anti-money laundering obligations and age verification requirements;
• Consent: where jin3 relies on your consent as the lawful basis (for example, for sending promotional communications), you may withdraw that consent at any time by contacting our support team. Withdrawal of consent does not affect the lawfulness of processing conducted before the withdrawal.

7 Data Sharing & Disclosure

jin3 does not sell, rent, or trade your Personal Data to third parties. We may share your Personal Data with the following categories of recipients, strictly on a need-to-know basis:

7.1 Payment Service Providers

To process your deposits and withdrawals, jin3 shares the minimum necessary transaction data with the relevant payment provider — which may include BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, or LinkAja. These providers are independent data controllers governed by their own privacy policies and are contractually required to handle your data securely.

7.2 KYC and Identity Verification Partners

jin3 may engage third-party identity verification service providers to assist with document validation during the KYC process. These providers act as Data Processors under written contracts and are strictly prohibited from using your KYC Data for any purpose other than completing the verification task assigned by jin3.

7.3 Technology and Infrastructure Providers

jin3 uses third-party cloud infrastructure, hosting, and platform technology providers to operate the Platform. These providers may technically have access to Personal Data stored on jin3's infrastructure in the course of providing their services. All such providers are bound by data processing agreements requiring them to maintain appropriate technical and organizational security measures.

7.4 Legal and Regulatory Disclosure

jin3 may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where required to do so by applicable law, a valid court order, or a legally mandated regulatory request. jin3 will, where legally permitted, notify the affected Member of such a disclosure request before complying.

8 Data Retention

jin3 retains Personal Data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and Registration Data: retained for the duration of your Account's active status, plus a minimum of 5 years following Account closure, to satisfy legal and regulatory obligations;
• KYC Documents: retained for a minimum of 5 years from the date of submission, or longer if required by applicable anti-money laundering regulations;
• Transaction Data: retained for a minimum of 5 years from the date of each transaction, in accordance with standard financial record-keeping requirements;
• Communication Data: support tickets and correspondence are retained for 3 years from the date of the interaction, unless the communication relates to an unresolved dispute, in which case records are retained until the dispute is fully resolved;
• Usage and Technical Data: retained for a maximum of 24 months, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized in a manner that prevents reconstruction of the original data.

9 Data Security

jin3 implements a comprehensive suite of technical and organizational security measures designed to protect your Personal Data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption in transit: all data transmitted between your device and jin3's servers is encrypted using TLS 1.2 or higher (256-bit SSL);
• Encryption at rest: sensitive Personal Data, including KYC documents and payment account details, is encrypted at rest on jin3's servers using AES-256 encryption;
• Access controls: access to Personal Data is restricted to authorized jin3 personnel on a strict need-to-know basis. All internal data access is logged and subject to regular access reviews;
• Intrusion detection: jin3's infrastructure is monitored continuously for suspicious activity, unauthorized access attempts, and anomalous data access patterns;
• Penetration testing: jin3 conducts regular third-party security audits and penetration tests to identify and remediate vulnerabilities before they can be exploited;
• Incident response: jin3 maintains a documented data breach response plan. In the event of a data breach that is likely to result in a risk to your rights or freedoms, we will notify affected Members without undue delay.

10 Cookies & Tracking Technologies

jin3 uses a limited set of cookies and similar technologies to operate the Platform effectively. We do not use third-party advertising cookies or cross-site tracking scripts.

10.1 Types of Cookies We Use

• Strictly Necessary Cookies: these cookies are required for the Platform to function. They include session authentication tokens that keep you logged in during an active session and security cookies that protect against cross-site request forgery. These cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies: these cookies remember your preferences, such as your selected language display settings, and ensure that Platform features operate as expected across pages within a single session.
• Analytics Cookies: jin3 uses first-party analytics cookies to understand how Members interact with the Platform — which pages are visited most frequently, how long sessions last, and where navigation drop-offs occur. This information is used exclusively to improve the Platform and is not shared with third-party analytics platforms.

10.2 Managing Cookies

You may configure your browser to refuse or delete cookies at any time. Note that disabling strictly necessary cookies will prevent you from logging in to your Account and using the Platform's core features. Instructions for managing cookies are available in your browser's help documentation.

11 Your Data Rights

As a Member of jin3, you hold the following rights with respect to your Personal Data. To exercise any of these rights, submit a written request to our support team at [email protected] (plain text — not a clickable link). We will respond to all valid requests within 30 days of receipt.

• Right of Access: you have the right to request a copy of the Personal Data jin3 holds about you, along with information about how it is processed;
• Right to Rectification: you have the right to request correction of any Personal Data that is inaccurate or incomplete. You may update basic profile information directly via your Account settings panel;
• Right to Erasure ("Right to be Forgotten"): you have the right to 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 and no other lawful basis for processing exists. This right is subject to jin3's legal obligations to retain certain data for minimum periods as set out in Section 8;
• Right to Restriction of Processing: you have the right to request that jin3 restrict the processing of your Personal Data in certain circumstances, for example while the accuracy of the data is being contested;
• Right to Data Portability: you have the right to receive a copy of the Personal Data you have provided to jin3 in a structured, commonly used, machine-readable format;
• Right to Object: you have the right to object to the processing of your Personal Data where jin3 relies on legitimate interests as the lawful basis for processing. jin3 will cease processing unless it can demonstrate compelling legitimate grounds that override your interests;
• 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 conducted prior to withdrawal.

12 Children's Privacy

jin3 strictly prohibits access to and use of the Platform by any person under the age of 21. The Platform is not directed at, and does not knowingly collect Personal Data from, individuals under 21 years of age. If jin3 becomes aware that Personal Data has been collected from a person under the age of 21, that data will be immediately deleted and the associated Account will be closed without notice.

If you are a parent or guardian and believe that your child under 21 has registered an Account on jin3, please contact our support team immediately so that the Account can be reviewed and closed, and all associated data can be securely deleted.

13 International Data Transfers

jin3 operates as an internationally licensed platform. In the course of providing its services, your Personal Data may be transferred to and processed in countries outside Indonesia where jin3's servers, infrastructure providers, or KYC partners are located. jin3 ensures that all such international transfers are conducted under appropriate safeguards, including standard contractual clauses or equivalent data transfer mechanisms, to ensure that your Personal Data receives a level of protection consistent with internationally recognized standards.

By using the Platform, you acknowledge and consent to the transfer of your Personal Data to jin3's server infrastructure and authorized service providers as described in this section, subject at all times to the protections described in this Policy.

14 Third-Party Links

The jin3 Platform does not contain links to third-party websites. In the event that any third-party content or reference is encountered in connection with Platform use, jin3 is not responsible for the privacy practices or data handling of any third party. This Policy applies solely to data collected and processed by jin3 in connection with the Platform at https://jin3.cam.

15 Amendments to This Policy

jin3 reserves the right to update or amend this Privacy Policy at any time. Material changes to this Policy will be communicated to registered Members via the email address on file at least 7 days before the changes take effect. The most current version of this Policy will always be available on this page, with the "Last Updated" date revised accordingly.

Your continued use of the Platform after any amendment to this Policy takes effect constitutes your acceptance of the revised Policy. If you do not accept the amended Policy, you must close your Account and cease using the Platform prior to the amendment's effective date.

16 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or jin3's data handling practices, please contact our Data Protection team. Our support team is available 24 hours a day, 7 days a week, and includes Indonesian-speaking agents covering all Indonesian time zones (WIB UTC+7, WITA UTC+8, and WIT UTC+9).

Contact us by email at: [email protected] (plain text — not a clickable link). Please include your registered Account username, a clear description of your query or complaint, and — where relevant — the specific data right you wish to exercise. We aim to acknowledge all privacy-related requests within 5 business days and to provide a full response within 30 days.

If you are not satisfied with jin3's response to your privacy complaint, you may have the right to escalate your complaint to the relevant data protection authority in your jurisdiction.