Privacy Policy

1 Definitions

In this Privacy Policy, the following terms carry the meanings set out below unless context requires otherwise:

• "Platform" means the jkt89 website at https://jkt89.net, all associated subdomains, and any mobile-optimised version of the service.
• "jkt89", "We", "Us", or "Our" refers to the operator of the Platform and its affiliated entities.
• "Member" or "You" means any individual who has registered an account on the Platform or who otherwise interacts with the Platform.
• "Personal Data" means any information that identifies or could reasonably identify a living individual, including name, date of birth, email address, device identifiers, and financial account references.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
• "Third-Party Processor" means any external organisation engaged by jkt89 to process Personal Data on jkt89's behalf, such as payment processors, KYC verification providers, and game content studios.
• "KYC" (Know Your Customer) means the identity and address verification process required by jkt89's compliance programme.
• "Cookies" means small text files placed on your device by the Platform to support session management, security, and performance analytics.

2 Data We Collect

jkt89 collects the following categories of Personal Data in connection with your use of the Platform:

2.1 Registration Data

When you create an account, we collect your full legal name, date of birth, Indonesian residential address, email address, and mobile telephone number. This data is mandatory — without it, we cannot create or maintain your account.

2.2 Identity Verification (KYC) Data

To comply with our anti-money laundering (AML) obligations and to verify your eligibility (21+ years, Indonesian resident), we may collect copies of your Indonesian national identity card (KTP) or passport, proof of address documents, and proof of ownership of your nominated payment method.

2.3 Financial Data

We collect transaction records, deposit and withdrawal amounts, and payment method references (e.g., the last four digits of a bank account registered under your name at BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI, or OCBC NISP, or an e-wallet account reference for OVO, DANA, GoPay, ShopeePay, or LinkAja). We do not store full bank account numbers or e-wallet login credentials on our servers.

2.4 Gaming Activity Data

We record your wagering history, game session durations, bet amounts, wins and losses, and responsible gaming tool usage. This data is used to provide the service, settle disputes, detect fraud, and fulfil regulatory obligations.

2.5 Technical & Device Data

When you access the Platform, we automatically collect your IP address, browser type and version, operating system, device type, screen resolution, referring URL, and session timestamps. This data is used for security, fraud prevention, and platform performance.

2.6 Communications Data

If you contact our support team via live chat or email, we retain records of those interactions — including the content of messages, timestamps, and agent notes — for quality assurance, dispute resolution, and training purposes.

3 How We Collect Your Data

jkt89 collects your Personal Data through the following channels:

• Directly from you — during account registration, KYC submissions, deposit and withdrawal requests, and support interactions.
• Automatically — through server logs, cookies, and similar technologies when you browse or interact with the Platform.
• From third-party processors — KYC verification providers and payment processors may return supplementary verification data to us after processing your submission.
• From public sources — in limited circumstances, our compliance team may consult publicly available records (such as sanctions lists or publicly filed court documents) as part of due diligence on high-risk accounts.

4 How We Use Your Data

The table below summarises the primary purposes for which jkt89 uses your Personal Data and the corresponding data categories involved:

jkt89 does not use your Personal Data for automated decision-making that produces legal or similarly significant effects without human review, except where this is expressly required for real-time fraud prevention. In such cases, you have the right to request human review of any automated decision that materially affects your account.

5 Legal Basis for Processing

jkt89 processes your Personal Data on one or more of the following legal bases:

• Contractual necessity — Processing required to create and operate your account, process transactions, and deliver gaming products in accordance with our Terms & Conditions.
• Legal obligation — Processing required to comply with applicable AML, KYC, and regulatory reporting obligations under the laws of jkt89's licensing jurisdiction.
• Legitimate interests — Processing carried out for fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights.
• Consent — Processing for optional purposes such as promotional communications, where you have freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Sharing Your Data

jkt89 does not sell or rent your Personal Data. We share your data only in the following strictly defined circumstances:

6.1 Third-Party Processors

We engage certified third-party processors to perform specific functions on our behalf. These include payment processors handling IDR transactions via Indonesian bank transfer and e-wallets, KYC verification service providers, game content studios (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Pocket Games Soft, and Spribe) who receive the minimum data necessary to deliver their products, and cloud infrastructure providers hosting Platform data. All processors are bound by data processing agreements requiring them to handle your data in accordance with this policy and applicable law.

6.2 Legal and Regulatory Disclosures

jkt89 may disclose your Personal Data to competent authorities, regulators, or law enforcement agencies where required by law, court order, or a binding regulatory obligation. In such cases, we will disclose only the minimum data necessary to satisfy the legal requirement.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of jkt89's assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified via email and/or a prominent Platform notice before your data becomes subject to a materially different privacy policy.

7 Data Retention

jkt89 retains your Personal Data for as long as your account remains active and for a defined period following account closure, as required by our regulatory and legal obligations:

• Active account data — Retained for the duration of your account's active status plus five (5) years following permanent account closure, to satisfy AML record-keeping requirements.
• KYC documents — Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later.
• Financial transaction records — Retained for a minimum of five (5) years from the date of the transaction.
• Support communications — Retained for three (3) years from the date of the interaction.
• Technical and device logs — Retained for twelve (12) months on a rolling basis.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes without restriction, as it can no longer identify any individual.

8 Security Measures

jkt89 implements a layered set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure:

• Encryption in transit: All communications between your browser or device and jkt89 servers are encrypted using TLS 1.3.
• Encryption at rest: Sensitive personal data fields — including passwords (hashed with bcrypt), KYC documents, and financial references — are encrypted at rest using AES-256.
• Access controls: Access to Personal Data within jkt89 is restricted to authorised staff on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Intrusion detection: Our infrastructure is monitored 24/7 for anomalous access patterns, unauthorised login attempts, and data exfiltration indicators.
• Penetration testing: The Platform undergoes regular independent security assessments. Identified vulnerabilities are triaged and remediated according to their severity rating.

9 Cookies & Tracking Technologies

jkt89 uses the following categories of cookies and similar technologies on the Platform:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without breaking core Platform functionality.
• Performance cookies: Used to measure page load times, identify technical errors, and understand how Members navigate the Platform. Data collected is aggregated and anonymous.
• Functional cookies: Used to remember your preferences, such as your preferred language setting or your last-used game category.

jkt89 does not use advertising cookies, remarketing pixels, or any third-party tracking technology designed to build a profile of your behaviour across external websites. You can manage or delete cookies at any time through your browser settings. Disabling strictly necessary cookies will impair your ability to log in and use the Platform.

10 Your Rights as a Data Subject

Subject to applicable law and regulatory constraints, you hold the following rights in respect of your Personal Data processed by jkt89:

• Right of access: You may request a copy of the Personal Data we hold about you at any time.
• Right to rectification: You may ask us to correct any inaccurate or incomplete Personal Data we hold about you.
• Right to erasure: You may request deletion of your Personal Data where we no longer have a legal or regulatory basis to retain it. Note that data subject to AML retention obligations cannot be erased early.
• Right to restriction: You may ask us to restrict processing of your data in certain circumstances, for example while a correction request is being assessed.
• Right to data portability: You may request a machine-readable export of the Personal Data you have provided to us.
• Right to object: You may object to processing carried out on the basis of legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time with immediate effect for future processing.

To exercise any of these rights, contact the jkt89 data team at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within five (5) business days and provide a substantive response within 30 calendar days.

11 Minors

The jkt89 Platform is strictly for adults aged 21 and over. We do not knowingly collect Personal Data from individuals under the age of 21. If we become aware that Personal Data has been collected from a person under 21, we will immediately close the associated account, void any balance, and securely delete the data in question.

If you are a parent or guardian and believe that a minor has registered an account on jkt89 without your consent, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

12 Third-Party Links

The jkt89 Platform may contain links to third-party content or services — for example, links to game studio information pages or payment provider documentation. These third-party destinations operate under their own privacy policies, which are entirely outside jkt89's control. jkt89 is not responsible for the privacy practices, content, or security of any third-party website. We encourage you to review the privacy policy of any external site before providing your Personal Data.

13 International Data Transfers

jkt89 is operated from, and primarily serves Members in, Indonesia. Some of our third-party processors — including cloud infrastructure providers and game studios — may be located in jurisdictions outside Indonesia. Where Personal Data is transferred internationally, jkt89 ensures that appropriate safeguards are in place, including contractual clauses requiring the recipient to maintain data protection standards consistent with this policy.

By registering an account and providing your Personal Data, you acknowledge that your data may be transferred to and processed in jurisdictions other than Indonesia, subject to the safeguards described above.

14 Policy Amendments

jkt89 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When a material change is made, we will notify registered Members via the email address on file and/or display a prominent notice on the Platform before the change takes effect.

The "Last updated" date at the top of this page indicates when the current version came into effect. Continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Privacy Policy. If you do not agree with any changes, please cease using the Platform and close your account before the revision takes effect.

15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way jkt89 handles your Personal Data, please reach out using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the Platform after logging in to your Account
• Response Time Target: Live chat within 2 minutes; email and formal data rights requests within 5 business days
• Support Hours: 24 hours a day, 7 days a week, including Indonesian public holidays