jin77 Privacy Policy

Definitions

The following definitions apply throughout this Privacy Policy:

• "Platform" — the jin77 website at jin77.app and all associated pages, services, and mobile-optimised interfaces.
• "Personal Data" — any information relating to an identified or identifiable natural person, including name, contact details, device identifiers, financial data, and behavioural data.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" — jin77, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" — a third party that processes Personal Data on jin77's behalf, subject to binding contractual obligations.
• "Player" / "You" — any individual who registers on, accesses, or uses the Platform.
• "KYC" — Know Your Customer identity verification processes required for regulatory compliance.
• "Cookie" — a small data file stored on your device by the Platform to support session management, analytics, and personalisation.

Scope & Data Controller

2.1 This Privacy Policy applies to all Personal Data collected by jin77 in connection with the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and use of the jin77 website.

2.2 jin77 is the Data Controller for all Personal Data collected through the Platform. jin77 operates under an international gaming licence and maintains data processing standards consistent with internationally recognised privacy frameworks.

2.3 The Platform is specifically designed to serve English-preference players residing in Indonesia. Indonesian residents' data is handled with consideration for Indonesia's applicable data protection regulations, including Law No. 27 of 2022 on Personal Data Protection (UU PDP).

2.4 This Policy does not apply to third-party websites or services that may be referenced on the Platform. jin77 is not responsible for the privacy practices of any third party.

Data We Collect

3.1 jin77 collects Personal Data across the following categories:

3.2 jin77 does not intentionally collect any special categories of sensitive personal data (such as racial or ethnic origin, religious beliefs, health data, or biometric data) unless specifically required for regulatory compliance purposes, in which case you will be notified separately.

How Data Is Collected

4.1 jin77 collects Personal Data through the following methods:

• Direct Submission: Data you provide when completing registration forms, KYC submission, deposit or withdrawal requests, or support enquiries.
• Automated Technologies: Technical and Usage Data collected automatically when you access the Platform, including via cookies, server logs, and similar tracking technologies.
• Third-Party Verification Providers: Identity and age verification data cross-referenced against third-party KYC databases to confirm the accuracy of information you have provided.
• Payment Processors: Transaction confirmation data received from payment partners including bank transfer intermediaries and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) when you make deposits or receive withdrawals.
• Game Providers: Game interaction data (including bet placement, game outcomes, and session activity) relayed from certified third-party game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) via secure API connections.

Purpose & Legal Basis for Processing

5.1 jin77 processes Personal Data only for defined, lawful purposes. The table below sets out the primary purposes and the corresponding legal basis for each:

5.2 Where jin77 relies on your consent as the legal basis for processing — specifically for promotional communications — you may withdraw that consent at any time by contacting the support team or by updating your communication preferences within your Account settings. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Data Sharing

6.1 jin77 does not sell, rent, or trade your Personal Data to any third party for their own commercial or marketing purposes. Personal Data is shared with third parties only in the following limited circumstances:

• Payment Partners: Bank transfer intermediaries and e-wallet providers (including OVO, DANA, GoPay, ShopeePay, LinkAja, and partner banks such as BCA, BRI, BNI, and Mandiri) receive the minimum financial data necessary to process your transactions.
• KYC & Identity Verification Providers: Authorised third-party verification services receive identity documents and personal details solely for the purpose of confirming your eligibility to use the Platform.
• Game Studio Providers: Certified studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) receive a player session token and relevant account identifiers to deliver game content. These providers are contractually prohibited from using this data for any purpose beyond game delivery.
• Regulatory and Law Enforcement Authorities: jin77 will disclose Personal Data to competent regulatory authorities, law enforcement agencies, or courts of law when required to do so by applicable law, a valid legal order, or where disclosure is necessary to protect the safety of any person.
• Professional Advisors: Lawyers, auditors, and compliance consultants who are bound by professional confidentiality obligations may access Personal Data to the extent necessary to provide their services to jin77.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of jin77's assets, your Personal Data may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections remaining in place.

6.2 All third-party Data Processors engaged by jin77 are subject to binding data processing agreements that require them to implement appropriate technical and organisational security measures and to process Personal Data only on jin77's documented instructions.

International Data Transfers

7.1 jin77 operates as an internationally licensed platform. Your Personal Data may be transferred to and processed in countries outside of Indonesia, including countries where the Data Controller and its service providers maintain operational infrastructure.

7.2 Where Personal Data is transferred internationally, jin77 ensures that appropriate safeguards are in place to protect your information. These safeguards may include:

• Standard contractual clauses requiring the recipient to maintain equivalent data protection standards.
• Processing only in jurisdictions that have been assessed as providing an adequate level of data protection.
• Binding corporate rules applicable to intra-group transfers where relevant.

7.3 By using the Platform and accepting this Privacy Policy, you acknowledge and consent to the international transfer of your Personal Data as described in this section.

Data Retention

8.1 jin77 retains your Personal Data for as long as your Account remains active and for a defined period thereafter, in accordance with the following general retention schedule:

• Account and Identity Data: Retained for the duration of the Account relationship plus a minimum of five (5) years following Account closure, to meet AML regulatory record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with standard financial record-keeping obligations.
• KYC Documents: Retained for the duration of the Account relationship plus five (5) years following Account closure. Physical or digital copies of identity documents are stored in encrypted format.
• Customer Support Records: Chat transcripts and email correspondence are retained for up to two (2) years from the date of the interaction, unless a longer period is required due to an open dispute or investigation.
• Technical and Usage Data: Aggregated analytics data is retained for up to twenty-four (24) months. Individual session logs are retained for up to twelve (12) months.
• Marketing Preferences: Records of your consent to receive or opt out of marketing communications are retained for the duration of the Account relationship plus three (3) years, to demonstrate compliance.

8.2 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.

Security Measures

9.1 jin77 implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the jin77 Platform is encrypted in transit using industry-standard SSL/TLS protocols.
• Encryption at Rest: Sensitive Personal Data stored on jin77 servers — including KYC documents, financial records, and authentication credentials — is encrypted at rest.
• Access Controls: Access to systems containing Personal Data is restricted to authorised personnel only, enforced through role-based access controls and multi-factor authentication requirements for administrative access.
• Regular Security Audits: jin77 conducts periodic internal and external security assessments, including penetration testing, to identify and remediate vulnerabilities proactively.
• Incident Response: jin77 maintains a documented data breach incident response plan. In the event of a confirmed data breach that poses a material risk to affected Players, jin77 will notify those Players without undue delay.

9.2 While jin77 employs robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the security of your account credentials. If you suspect your account has been compromised, contact the support team immediately via 24/7 live chat.

Cookies & Tracking Technologies

10.1 jin77 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management cookies that keep you logged in to your jin77 account during a visit, and security cookies that support fraud detection. These cookies cannot be disabled without materially impairing the Platform's functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised data about how Players interact with the Platform — such as which pages are visited most frequently and how long sessions last. This information helps jin77 improve the user experience.
• Functional Cookies: Used to remember your preferences, such as your selected language display setting, and to personalise your Platform experience.
• Marketing Cookies: Used only where you have given explicit consent, to deliver relevant promotional content about jin77 offers. jin77 does not use marketing cookies for cross-site advertising on third-party platforms.

10.2 You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to use core Platform features, including the jin77 login process.

10.3 jin77 does not use cross-site tracking technologies to follow your browsing activity outside of the jin77 Platform.

Your Rights

11.1 As a Player whose Personal Data is processed by jin77, you have the following rights with respect to your information:

• Right of Access: You have the right to request a copy of the Personal Data jin77 holds about you, along with information about how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data held about you. For straightforward corrections (e.g., updating your email address or mobile number), this can be done directly within your Account settings.
• Right to Erasure: You have the right to request deletion of your Personal Data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected. This right is subject to jin77's legal retention obligations, which may require us to retain certain data for a defined minimum period even after Account closure.
• Right to Restriction: You have the right to request that jin77 restrict the processing of your Personal Data in certain circumstances, for example while a correction request is being assessed.
• Right to Data Portability: Where processing is carried out by automated means and on the basis of contract or consent, you have the right to receive a structured, machine-readable copy of the Personal Data you have provided to jin77.
• Right to Object: You have the right to object to the processing of your Personal Data where jin77 relies on legitimate interest as the legal basis, including for direct marketing purposes.
• 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 that occurred prior to withdrawal.

11.2 To exercise any of these rights, contact the jin77 support team via 24/7 live chat or by email at [email protected]. jin77 will acknowledge all data rights requests within 5 business days and will aim to fulfil them within 30 calendar days of receipt.

11.3 jin77 will not charge a fee for processing reasonable data rights requests. In cases of manifestly unfounded or excessive requests, jin77 reserves the right to charge a reasonable administrative fee or to decline the request, with written explanation.

Minors

12.1 The jin77 Platform is strictly restricted to individuals aged 21 years or older. jin77 does not knowingly collect Personal Data from any person under the age of 21.

12.2 jin77 employs age verification controls at the point of registration and conducts additional KYC age checks where warranted. If jin77 becomes aware that Personal Data has been collected from a person under the age of 21, that Account will be immediately suspended, all associated Personal Data will be deleted, and any funds deposited will be returned to their source.

12.3 If you are a parent or guardian and believe your child may have registered on the jin77 Platform, please contact our support team immediately via 24/7 live chat or at [email protected]. We will investigate and act promptly.

Third-Party Links & Services

13.1 The jin77 Platform may contain references to third-party game studios and payment service providers in the context of delivering Platform services. jin77 does not embed external third-party advertising links or outbound navigation links to unaffiliated websites.

13.2 Third-party game studio interfaces embedded within the Platform (such as live dealer lobbies operated by Evolution Gaming or Pragmatic Play Live) are subject to those studios' own privacy and data handling practices, which are governed by their respective agreements with jin77 and not directly by this Policy. However, jin77 ensures through contractual obligations that these studios process Player data only for the purposes of game delivery and not for any independent commercial use.

13.3 jin77 bears no responsibility for the privacy practices of any independently operated third-party website or service that may be accessed outside of the jin77 Platform.

Policy Amendments

14.1 jin77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, new regulatory requirements, or operational updates to the Platform. All amendments will be published on this page with a revised "Last Updated" date.

14.2 Where amendments are material — meaning they significantly change how your Personal Data is used or what rights you have — jin77 will notify registered Players via email to their registered address or via a prominent notification within the Platform prior to the changes taking effect.

14.3 Your continued use of the Platform following the publication of an amended Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree with any amendment, you must stop using the Platform and may request Account closure and data deletion via the support team.

Contact & Data Protection Officer

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or jin77's handling of your Personal Data, please contact us through any of the following channels:

• 24/7 Live Chat: Available directly on every page of the jin77 Platform — the fastest channel for urgent data concerns.
• Email: [email protected] — for formal written data rights requests and privacy enquiries.
• WhatsApp: +62 811-0000-7777 — for Indonesian and English language support, available 00:00–24:00 WIB (UTC+7).

15.2 jin77 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection law. Formal data protection correspondence may be directed to the DPO via the email address above, clearly marked "Data Protection — DPO" in the subject line.

15.3 jin77 will acknowledge all privacy-related enquiries within 5 business days and will aim to provide a substantive response within 14 business days of receipt.