Privacy Policy
How jin110 Handles Your Personal Data

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

jin110 collects only the Personal Data that is necessary for the specific purposes described in this Policy. The categories of Personal Data we collect are as follows:

2.1 Registration Data. When you create an Account, we collect:

• Full legal name as it appears on your Indonesian National ID (KTP).
• Date of birth (used to verify that you are at least 21 years of age).
• Personal email address.
• Indonesian mobile phone number.
• Preferred username and password (password is stored as a one-way cryptographic hash — not in plain text).

2.2 KYC Verification Data. To comply with our age verification and anti-fraud obligations, we collect:

• A photograph or scan of your Indonesian National ID (KTP), including the full name, date of birth, address, and national ID number displayed thereon.
• A face-match selfie photograph taken at the time of KYC submission.
• Bank account details (account holder name, bank name, and account number) used for deposit and withdrawal processing.

2.3 Financial Transaction Data. For each deposit or withdrawal transaction, we record:

• Transaction amount in IDR.
• Payment method used (e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja).
• Transaction reference number and timestamp.
• Running account balance before and after the transaction.

2.4 Gameplay & Betting Data. We record all bets placed through the Platform, including:

• Bet type, market, selection, and stake amount.
• Bet outcome and settlement amount.
• Game titles accessed and session duration for casino and togel (Indonesia's traditional numbers lottery) products.
• Timestamps for all gaming activity.

2.5 Technical & Device Data. We automatically collect certain technical data when you access the Platform:

• IP address and approximate geolocation derived from IP.
• Browser type, version, and operating system.
• Device type (desktop, mobile, tablet) and screen resolution.
• Pages visited, time on page, and click-through behaviour (via first-party analytics).
• Session cookies and persistent preference cookies (see Section 9).

2.6 Support Interaction Data. When you contact our support team via live chat or email, we retain a record of:

• The communication channel used and the date and time of contact.
• The content of the communication, including any attachments you provide.
• The resolution provided and the support agent who handled your query.

jin110 collects Personal Data through the following channels:

• Directly from you: When you complete the Account registration form, submit KYC documents, make a deposit or withdrawal request, or contact our support team.
• Automatically: Via server logs, session cookies, and first-party analytics tools that record your interactions with the Platform when you browse or play.
• From payment providers: When your bank or e-wallet (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, etc.) transmits transaction confirmation data to jin110's payment gateway.
• From identity verification services: Where jin110 uses a third-party KYC verification tool to cross-check the authenticity of submitted ID documents, that provider may return a verification result and confidence score.

jin110 does not purchase Personal Data from data brokers or third-party marketing lists. We do not collect data from your social media profiles unless you explicitly choose to share such information with our support team.

jin110 processes your Personal Data only for the specific, legitimate purposes listed below. We do not process Personal Data for any purpose that is incompatible with the purpose for which it was originally collected.

jin110 processes your Personal Data on one or more of the following legal bases, depending on the specific processing activity involved:

• Contractual necessity: Processing that is required to perform the contract between you and jin110 — that is, to operate your Account, process transactions, and deliver the Platform's services. Without this processing, jin110 cannot provide the service.
• Legal obligation: Processing that is required to comply with applicable international gaming regulations, anti-money-laundering (AML) requirements, and age verification obligations — including the mandatory retention of KYC records and financial transaction logs.
• Legitimate interests: Processing undertaken to protect the integrity of the Platform, detect fraud and bonus abuse, improve Platform performance, and maintain the security of all Players' accounts — provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where jin110 relies on your consent as the legal basis for a specific processing activity (for example, sending you promotional communications about bonuses and seasonal offers), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. Consent withdrawal requests should be directed to [email protected].

jin110 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. Personal Data is shared only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

6.1 Payment Service Providers. To process your deposits and withdrawals, jin110 shares the minimum necessary transaction data with the relevant payment gateway and the Indonesian bank or e-wallet provider involved (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, or LinkAja). These providers act as independent data controllers for their own payment processing activities and are governed by their own privacy policies.

6.2 Identity Verification Providers. Your KYC documentation may be processed by a third-party identity verification service engaged by jin110. Such providers operate as Data Processors under binding data-processing agreements that restrict their use of your data to KYC verification purposes only.

6.3 Game Content Providers. Game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive a Player session token and anonymised Player identifier to deliver their game content within the Platform. These providers do not receive your full name, KTP number, or financial account details.

6.4 Infrastructure & Hosting Providers. jin110 uses internationally recognised cloud infrastructure providers to host the Platform. These providers act as Data Processors and are contractually bound to process data only on jin110's documented instructions.

6.5 Legal & Regulatory Disclosures. jin110 may disclose Personal Data to law enforcement authorities, regulatory bodies, or courts if required to do so by applicable law, valid legal process, or a binding order from a competent authority. Where permitted, jin110 will notify you of any such disclosure request.

6.6 Business Transfers. In the event of a merger, acquisition, asset sale, or corporate restructuring involving jin110, your Personal Data may be transferred to the successor entity, subject to that entity providing equivalent privacy protections. You will be notified of any such transfer.

jin110 retains your Personal Data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law. The standard retention periods applied to each data category are as follows:

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised in accordance with jin110's data disposal procedures. Anonymised, aggregated data that can no longer identify any individual may be retained indefinitely for analytical purposes.

jin110 implements a layered security architecture designed to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. Our technical and organisational security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform — the same standard used by major Indonesian banks and financial institutions.
• Encryption at rest for all sensitive Personal Data stored on jin110's servers, including KYC documents and payment account details.
• One-way password hashing using a modern cryptographic algorithm — your password is never stored in a recoverable plain-text format.
• Role-based access controls (RBAC) limiting access to Personal Data to only those jin110 employees and contractors whose role requires it, on a strict need-to-know basis.
• Multi-factor authentication (MFA) for all jin110 staff accessing backend administrative systems that contain Player data.
• Regular penetration testing by independent security professionals to identify and remediate vulnerabilities before they can be exploited.
• Intrusion detection and monitoring systems that generate real-time alerts for anomalous access patterns or potential data breach indicators.

Despite these measures, no internet-connected system can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, jin110 will notify affected Players without undue delay via the email address registered on their Account, and will take all reasonable steps to contain the breach and mitigate its impact.

You are responsible for maintaining the security of your own Account login credentials. If you suspect your Account has been compromised, contact jin110 Support immediately at [email protected].

jin110 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, maintain your login session, and analyse how the Platform is used. We do not use third-party advertising cookies or retargeting pixels.

9.1 Types of Cookies We Use.

9.2 Cookie Management. You may control or delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will prevent you from logging into your Account and will significantly impair Platform functionality. Instructions for managing cookies in the most common browsers are available in your browser's help documentation.

9.3 No Third-Party Advertising Cookies. jin110 does not permit third-party advertising networks, social media platforms, or data management platforms to set cookies on the jin110 Platform. We do not engage in behavioural advertising or retargeting based on Platform usage data.

jin110 respects your rights over your own Personal Data. Subject to applicable legal limitations, you hold the following rights with respect to the Personal Data that jin110 processes about you:

10.1 Right of Access. You may request a copy of the Personal Data that jin110 holds about you, along with information about how it is being processed. We will provide this information within 30 days of receiving a valid request.

10.2 Right to Rectification. If any Personal Data that jin110 holds about you is inaccurate or incomplete, you may request that it be corrected. For data that you can update directly within your Account dashboard (such as email address or mobile number), you are encouraged to do so directly. For KYC data corrections, you must submit a formal request to our support team.

10.3 Right to Erasure. You may request the deletion of your Personal Data where: (a) the data is no longer necessary for the purpose for which it was collected; (b) you withdraw consent and there is no other lawful basis for processing; or (c) the data has been processed unlawfully. Please note that jin110 is required by law to retain certain categories of data — particularly KYC and financial transaction records — for a minimum of 5 years following Account closure, and these categories cannot be deleted on request during the mandatory retention period.

10.4 Right to Restrict Processing. You may request that jin110 restrict the processing of your Personal Data in certain circumstances — for example, while a dispute about data accuracy is being resolved.

10.5 Right to Data Portability. Where processing is based on your consent or on 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 (e.g., CSV).

10.6 Right to Object. You may object to processing of your Personal Data where that processing is based on jin110's legitimate interests. jin110 will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

10.7 Right to Withdraw Consent. Where jin110 relies on your consent as the legal basis for processing (for example, for promotional communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

The jin110 Platform is strictly intended for adults aged 21 years or older. jin110 does not knowingly collect Personal Data from persons under the age of 21. Age is verified through mandatory KYC documentation as part of the Account registration and withdrawal process.

In the event that jin110 becomes aware that it has inadvertently collected Personal Data from a person under the age of 21, that Account will be immediately closed, all funds will be returned to the depositing payment method, and all associated Personal Data will be securely deleted within 72 hours of discovery, subject to any overriding legal obligations.

If you are a parent or guardian and have reason to believe that a minor in your care has registered an Account on jin110, please contact our support team immediately at [email protected].

jin110 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform functionality. The "Last Updated" date at the top of this page will be revised whenever a substantive change is made.

Where a proposed change materially affects how we process your Personal Data or reduces your privacy protections, jin110 will provide at least 7 days' advance notice via a Platform notification and/or an email to the address registered on your Account before the change takes effect.

Your continued use of the Platform following the effective date of any amendment to this Privacy Policy constitutes your acknowledgement of the revised terms. If you do not accept the revised Privacy Policy, you must cease using the Platform and may request Account closure and withdrawal of any remaining funds.

For any questions, concerns, or requests relating to this Privacy Policy or to the processing of your Personal Data by jin110, please contact our Data Protection team through the following channel:

Our Indonesian-speaking support agents are available 24/7 via live chat within the Platform. Live chat is recommended for urgent account-security queries. All formal privacy rights requests must be submitted in writing via email to the address above to ensure a documented audit trail.