jin22 Privacy Policy

01 Introduction

jin22 ("we", "our", "us") is committed to protecting the privacy and personal information of every user who accesses or uses our online betting and casino platform. This Privacy Policy sets out how we collect, use, store, process, and protect the personal data of users ("you", "your") who register for an account or otherwise interact with the jin22 platform accessible at jin22.cam and associated sub-domains, mobile applications, and APIs.

This Privacy Policy should be read in conjunction with the jin22 Terms & Conditions, which govern your use of the platform. Both documents together form the complete legal agreement between you and jin22.

We comply with international data protection principles and apply industry best practices to ensure that your personal information is processed lawfully, fairly, and transparently. This includes adhering to standards equivalent to the EU General Data Protection Regulation (GDPR) framework, even though our primary user base is located in Indonesia.

If you have any questions or concerns about how your personal data is handled, please contact our Data Protection Officer using the contact details provided in Clause 15 of this Policy.

02 Data Controller

For the purposes of applicable data protection law, the data controller responsible for your personal information is the international entity operating jin22 under its gaming licence. The data controller determines the purposes for which, and the manner in which, your personal data is processed.

You can contact the data controller and our Data Protection Officer at:

• Email: [email protected] (plain text only — copy and paste into your email client)
• Subject Line: "Data Protection Inquiry – [Your Account Username]"

For general customer support inquiries not related to data protection, please use [email protected] (plain text).

03 Information We Collect

jin22 collects several categories of personal information to operate your account, process transactions, comply with legal obligations, and provide customer support. The information we collect includes:

3.1 Information You Provide Directly

• Registration Data: Full legal name, date of birth, gender, residential address, email address, mobile phone number, username, password, security questions.
• Identity Verification Documents: Copies of government-issued photo identification (Indonesian National Identity Card / KTP, Passport, Driving Licence), proof of address (utility bills, bank statements), proof of payment method ownership (bank account statements, e-wallet screenshots).
• Payment Information: Bank account numbers, e-wallet account identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja phone numbers), payment transaction history, deposit and withdrawal records.
• Communications: Content of emails, live chat messages, WhatsApp messages, and phone calls with customer support, including any documents or screenshots you provide during support interactions.

3.2 Information Collected Automatically

• Transaction Data: Complete history of deposits, withdrawals, bets placed, game sessions played, bonus claims, wagering activity, wins, losses, and account balance changes.
• Device & Session Data: IP addresses, device identifiers (IMEI, advertising IDs), browser type and version, operating system, screen resolution, language preferences, time zone, referring URLs, pages viewed, time spent on pages, click patterns.
• Geolocation Data: Approximate location derived from IP address to verify that you are accessing the platform from a permitted jurisdiction and to comply with geo-blocking requirements where applicable.
• Cookies & Similar Technologies: Session cookies, persistent cookies, local storage, and other tracking technologies used to maintain login state, remember preferences, and analyze platform usage patterns. See Clause 11 for full cookie policy details.

3.3 Information from Third-Party Sources

• KYC Verification Services: Identity verification results from third-party KYC providers who cross-reference your submitted documents against government databases and watchlists.
• Payment Processors: Transaction status updates, payment method validity checks, and fraud risk scores provided by banks, e-wallet providers, and payment gateway operators.
• Fraud Prevention Services: Device fingerprinting data, IP reputation scores, and behavioral analytics provided by third-party anti-fraud vendors to detect suspicious activity.

04 How We Use Your Data

jin22 processes your personal information for the following purposes:

• Account Management: To create, maintain, and administer your user account, including authentication, password resets, and account settings management.
• Transaction Processing: To process deposits, withdrawals, bets, game sessions, and bonus claims; to maintain accurate financial records; and to reconcile payment flows.
• Identity Verification & KYC Compliance: To verify your identity, age, and residential address in accordance with international anti-money-laundering (AML) and Know Your Customer (KYC) regulations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, duplicate accounts, bonus abuse, collusion, unauthorized access, and other violations of our Terms & Conditions.
• Customer Support: To respond to your inquiries, troubleshoot technical issues, resolve disputes, and provide assistance with account, payment, or game-related questions.
• Responsible Gaming: To enforce age restrictions, monitor for signs of problematic gambling behavior, implement self-exclusion requests, and apply deposit limits and session time controls. See our Responsible Gaming Policy for full details.
• Platform Analytics & Improvement: To analyze platform usage patterns, identify technical issues, optimize user experience, develop new features, and improve game offerings based on aggregated and anonymized data.
• Marketing Communications: To send promotional emails, SMS messages, and push notifications about bonuses, new games, special events, and platform updates — only if you have opted in to receive marketing communications. You may opt out at any time via your account settings.
• Legal & Regulatory Compliance: To comply with applicable laws, respond to lawful requests from government authorities, enforce our legal rights, and cooperate with regulatory investigations.

05 Legal Basis for Processing

Under international data protection law, we must have a lawful basis to process your personal information. jin22 relies on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and jin22 (i.e., to provide betting and gaming services as set out in our Terms & Conditions). This includes account registration, transaction processing, identity verification, and customer support.
• Legal Obligation: Processing is necessary to comply with legal obligations imposed on jin22, including anti-money-laundering regulations, tax reporting requirements, licensing conditions, and regulatory audits.
• Legitimate Interests: Processing is necessary for jin22's legitimate business interests, including fraud prevention, platform security, analytics, and product improvement — provided that these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where processing is based on your consent (e.g., receiving marketing communications, using optional features), you have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

06 Data Sharing & Disclosure

jin22 does not sell, rent, or trade your personal information to third parties for marketing purposes. We share personal data only in the following limited circumstances:

• Service Providers: We engage third-party vendors to perform functions on our behalf, including payment processing (banks, e-wallet providers, payment gateways), identity verification (KYC providers), fraud prevention (device fingerprinting, IP analysis), cloud hosting (data storage), customer support tools (live chat software, ticketing systems), and email delivery (transactional and promotional emails). These vendors are bound by strict data processing agreements and may access personal data only to the extent necessary to perform their contracted services.
• Game Studios & Data Providers: When you play slots, live casino games, or place sports bets, your betting activity is transmitted to the relevant game studio or odds provider (Pragmatic Play, Evolution Gaming, Pocket Games Soft, Spribe, etc.) to execute the game session. These providers are bound by their own privacy policies and are subject to licensing and audit requirements.
• Regulatory Authorities: We may disclose personal data to gaming regulators, licensing authorities, anti-money-laundering agencies, tax authorities, and law enforcement agencies when required by law or when we have a good-faith belief that disclosure is necessary to comply with a legal obligation or court order.
• Business Transfers: In the event of a merger, acquisition, asset sale, or other corporate restructuring, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified via email if such a transfer occurs, and the acquiring entity will be required to continue honoring this Privacy Policy.
• Legal Protection: We may disclose personal data if we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of jin22, our users, or the public; to enforce our Terms & Conditions; or to investigate suspected fraud, abuse, or security breaches.

07 International Data Transfers

jin22 operates under an international gaming licence and processes personal data across multiple jurisdictions. Your personal information may be transferred to, stored in, and processed in countries outside of Indonesia, including countries that may have data protection laws that differ from those in Indonesia.

When we transfer personal data internationally, we implement appropriate safeguards to ensure that your data remains protected to the same standard as required by this Privacy Policy, including:

• Using data processing agreements based on standard contractual clauses approved by international data protection authorities.
• Engaging only service providers that are certified under recognized data protection frameworks or that have implemented equivalent technical and organizational measures.
• Applying encryption to data in transit and at rest to protect against unauthorized access during international transfers.

By using the jin22 platform, you acknowledge and consent to the international transfer of your personal data as described in this clause.

08 Data Security

jin22 implements industry-leading technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Encryption: All personal data is encrypted at rest using AES-256 encryption and in transit using TLS 1.3 encryption. Payment card data (if processed) is handled in accordance with PCI DSS standards.
• Access Controls: Access to personal data is restricted to authorized personnel only on a strict need-to-know basis. Multi-factor authentication is required for all administrative access to production systems.
• Network Security: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, DDoS mitigation services, and continuous security monitoring.
• Regular Audits: We conduct regular internal security audits and engage third-party penetration testers to identify and remediate vulnerabilities.
• Data Minimization: We collect and retain only the personal data that is necessary for the purposes outlined in this Privacy Policy, and we securely delete data that is no longer required.
• Employee Training: All jin22 employees and contractors with access to personal data undergo mandatory data protection and security awareness training.

While we take every reasonable precaution to secure your personal information, no method of transmission over the internet or electronic storage is 100% secure. In the unlikely event of a data breach that affects your personal information, we will notify you within 72 hours in accordance with international best practice and take immediate steps to mitigate the impact.

09 Data Retention

jin22 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary by data type:

After the applicable retention period expires, personal data is securely deleted or anonymized such that it can no longer be associated with an identifiable individual. Anonymized data may be retained indefinitely for statistical and analytical purposes.

If you close your account and request data deletion, we will delete all personal data that is not subject to a legal retention obligation. However, we are required by law to retain certain financial and identity records for the periods specified above.

10 Your Privacy Rights

Under international data protection law, you have the following rights regarding your personal information:

• Right of Access: You have the right to request a copy of all personal data we hold about you. You may exercise this right at any time by logging into your account and navigating to Settings → Data Export, or by contacting our Data Protection Officer at [email protected] (plain text).
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to have it corrected. You may update most personal information directly from your account dashboard.
• Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of your personal data, subject to our legal obligations to retain certain records for AML, tax, and licensing compliance. Data deletion requests can be submitted via [email protected] (plain text).
• Right to Restriction of Processing: You have the right to request that we limit the processing of your personal data in certain circumstances, such as while we verify the accuracy of data you have contested.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another service provider where technically feasible.
• Right to Object: You have the right to object to processing based on legitimate interests, including profiling and direct marketing. You may opt out of marketing communications at any time via your account settings.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the data protection supervisory authority in the jurisdiction where the data controller is established.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] (plain text) with the subject line "Privacy Rights Request – [Your Account Username]". We will respond to your request within 30 days.

11 Cookies & Tracking Technologies

jin22 uses cookies, local storage, and similar tracking technologies to enhance your experience on our platform, maintain your login session, remember your preferences, and analyze platform usage patterns.

The types of cookies we use include:

• Essential Cookies: Required for the platform to function. These cookies maintain your login session, remember your language preference, and enable secure navigation. Essential cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as display settings, game filters, and notification preferences to provide a personalized experience.
• Analytics Cookies: Collect aggregated and anonymized data about how users interact with the platform, including pages viewed, click patterns, and session duration. This data is used to identify technical issues and improve user experience.
• Advertising Cookies: Track your activity across sessions to deliver personalized promotional offers and measure the effectiveness of marketing campaigns. These cookies are used only if you have opted in to receive marketing communications.

You can control cookie preferences through your browser settings. Most browsers allow you to refuse cookies or to alert you when cookies are being sent. However, please note that disabling essential cookies will prevent you from using key features of the platform, including logging into your account.

For detailed information on managing cookies in specific browsers, please refer to your browser's help documentation.

12 Third-Party Services

The jin22 platform integrates with third-party services including payment processors (banks, e-wallet providers), game studios (Pragmatic Play, Evolution Gaming, Pocket Games Soft, Spribe, NetEnt, Microgaming), identity verification providers, and customer support tools.

When you interact with these third-party services — for example, when you make a deposit via BCA online banking or play a Pragmatic Play slot game — your personal data is transmitted to the third party to execute the requested service. These third parties are bound by their own privacy policies and terms of service, which are independent of this Privacy Policy.

jin22 is not responsible for the privacy practices or content of third-party services. We encourage you to review the privacy policies of any third-party service you interact with. However, all third-party service providers integrated into the jin22 platform are vetted for compliance with international data protection standards and are required to implement appropriate security measures.

The jin22 platform may contain links to external websites for informational purposes (e.g., responsible gaming resources, regulatory information). jin22 is not responsible for the content or privacy practices of external websites.

13 Children's Privacy

The jin22 platform is intended exclusively for adults aged 21 years and above. We do not knowingly collect, process, or store personal information from individuals under the age of 21.

If we discover that we have inadvertently collected personal data from a person under the age of 21, we will delete that data immediately and close any associated account without prior notice.

If you believe that we may have collected personal information from a minor, please contact us immediately at [email protected] (plain text) with the subject line "Underage Account Report" so that we can investigate and take appropriate action.

Parents and guardians are encouraged to monitor their children's internet usage and to use parental control software to prevent minors from accessing age-restricted content, including online gambling platforms.

14 Changes to This Privacy Policy

jin22 reserves the right to amend, modify, or update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or operational requirements.

In the event of a material change to this Privacy Policy (defined as a change that significantly affects how we collect, use, or share your personal data), we will notify you via email to the registered email address on your account, or via a prominent in-platform notification upon your next login. The updated Privacy Policy will be published on this page with a revised "Last Updated" date displayed at the top of the document.

Your continued use of the jin22 platform following notification of a Privacy Policy amendment constitutes your acceptance of the revised Policy. If you do not agree to the amended Privacy Policy, you should cease using the platform and may request account closure and data deletion by contacting [email protected] (plain text).

We encourage you to review this Privacy Policy periodically to stay informed about how your personal data is protected.

15 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy, our data practices, or the exercise of your privacy rights, please contact our Data Protection Officer using the following details:

• Data Protection Officer Email: [email protected] (plain text only — copy and paste into your email client)
• Subject Line: "Privacy Inquiry – [Your Account Username]" or "Privacy Rights Request – [Type of Request]"
• Response Time: We aim to respond to all privacy-related inquiries within 30 days of receipt.

For general customer support inquiries not related to data protection, please use [email protected] (plain text) or contact us via live chat available 24/7 on the jin22 homepage.

If you are not satisfied with our response to a privacy complaint, you have the right to lodge a complaint with the data protection supervisory authority in the jurisdiction where jin22's data controller is established. We will provide contact details for the relevant supervisory authority upon request.