Privacy Policy

Section 1

Definitions

In this Privacy Policy, the following terms carry the meanings defined below:

• "jin11", "we", "us", or "our" refers to the jin11 platform and its operating entity, which holds an international gaming licence and operates the website at https://jin11.pro.
• "Personal Data" means any information that identifies or could reasonably identify you as a natural person, including your name, date of birth, email address, Indonesian phone number, national identity number, IP address, and financial account identifiers.
• "Processing" means any operation performed on Personal Data — including collection, storage, use, transmission, access, deletion, and anonymisation.
• "Member", "you", or "your" refers to any individual who has registered an Account on the jin11 Platform or who visits the Platform without an Account.
• "Controller" means the entity that determines the purposes and means of processing Personal Data — that is, jin11 for the purposes of this Policy.
• "Processor" means a third party that processes Personal Data on jin11's behalf and under jin11's documented instructions — for example, payment processors and game studios.
• "KYC" (Know Your Customer) refers to identity and age verification procedures performed in accordance with international anti-money-laundering standards.
• "IDR" or "Rupiah" means Indonesian Rupiah, the currency used for all transactions on the Platform.

Section 2

Scope & Data Controller

This Privacy Policy applies to all Personal Data collected by jin11 through the Platform at https://jin11.pro, including all sub-pages, game interfaces, payment flows, customer support interactions (live chat and email), and any marketing communications sent by jin11.

jin11 is the data controller for all Personal Data processed under this Policy. This means jin11 determines why and how your Personal Data is used. Where jin11 engages third-party processors — such as payment gateways or game studios — jin11 remains responsible for ensuring those processors handle your data in accordance with this Policy and applicable data protection law.

This Policy is directed at residents of Indonesia and is written in accordance with Indonesian data protection principles, including those contained in Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions (PP No. 71 Tahun 2019) and the Personal Data Protection Law (Undang-Undang Perlindungan Data Pribadi), to the extent these apply to international platform operators serving Indonesian users.

Section 3

Personal Data We Collect

jin11 collects Personal Data through three primary channels: information you provide directly, information generated automatically as you use the Platform, and information received from third parties.

3.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, email address, Indonesian mobile phone number, and chosen username.
• KYC Documents: Scanned or photographed copies of your Indonesian National Identity Card (KTP), passport, or other government-issued photo ID; proof of address documents; and payment method ownership evidence.
• Payment Data: Bank account numbers (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja) registered to your Account. jin11 does not store full card numbers or CVV codes.
• Support Communications: The content of live chat transcripts, emails, and any attachments you send to the jin11 support team.
• Preferences & Settings: Responsible gaming limits you set, communication preferences, and any optional profile information you choose to add.

3.2 Data Collected Automatically

• Device & Technical Data: IP address, browser type and version, operating system, device model, screen resolution, and time zone.
• Usage Data: Pages visited, game sessions started and completed, wagers placed, odds viewed, navigation paths, session duration, and click-stream data.
• Transaction Data: Deposit and withdrawal amounts, timestamps, payment method used, transaction reference numbers, and balance history.
• Cookie & Tracking Data: Session tokens, login state cookies, analytics identifiers, and performance tracking pixels (see Section 9 for full details).

3.3 Data Received from Third Parties

• Payment Processors: Transaction status confirmations, bank verification results, and fraud screening signals from BCA, BRI, and partner e-wallet providers.
• KYC Verification Partners: Identity confirmation results and watchlist screening outcomes from our certified KYC technology partners.
• Game Studios: Gameplay outcome logs, RNG certification data, and game session records from studios such as Pragmatic Play, Evolution Gaming, and Pocket Games Soft.

Section 4

Legal Basis for Processing

jin11 processes your Personal Data on one or more of the following legal bases:

Section 5

How We Use Your Personal Data

jin11 uses the Personal Data we collect solely for the purposes described in this Policy. Specifically, we use your data to:

• Create, maintain, and administer your jin11 Account, including verifying your identity (21+ and Indonesia residency) at registration and before processing withdrawals.
• Process deposits from and withdrawals to your verified Indonesian bank account or e-wallet, and maintain an accurate transaction history on your Account dashboard.
• Perform KYC and AML checks, including screening your identity against international sanctions lists and politically exposed persons (PEP) databases, as required by our licensing obligations.
• Detect, investigate, and prevent fraudulent activity, bonus abuse, multi-accounting, and other prohibited conduct as defined in our Terms & Conditions.
• Monitor gameplay patterns for responsible gaming indicators and, where appropriate, proactively contact Members who may be showing signs of problem gambling.
• Provide 24/7 customer support in English and Indonesian, including responding to account queries, payment disputes, and technical issues.
• Personalise your experience on the Platform — for example, displaying games relevant to your play history or surfacing promotions relevant to upcoming events such as BRI Liga 1 fixtures, Idul Fitri, or Ramadhan bonus campaigns.
• Send you transactional notifications (deposit confirmations, withdrawal approvals, KYC status updates) and, where consented, marketing communications about new games, promotions, and platform features.
• Comply with all applicable legal, regulatory, and licensing obligations, including responding to lawful requests from regulatory or law enforcement authorities.
• Improve the performance, security, and functionality of the Platform through aggregated analytics and A/B testing.

Section 6

Sharing Your Personal Data

jin11 does not sell, rent, or trade your Personal Data to any third party for commercial purposes. We share your data only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose.

6.1 Payment Processors

To execute deposits and withdrawals, jin11 shares your name, registered payment account details, and transaction amount with your chosen payment provider. Current payment partners include bank channels for BCA, BRI, BNI, Mandiri, and CIMB Niaga, and e-wallet channels for OVO, DANA, GoPay, ShopeePay, and LinkAja. Each processor operates under a data processing agreement with jin11 and is bound by confidentiality obligations.

6.2 KYC & AML Technology Partners

jin11 uses certified third-party technology partners to perform identity verification, document authentication, and sanctions screening. Your KYC documents and identity data are transmitted to these partners over encrypted channels and are not stored by them beyond the period required to complete the verification check.

6.3 Game Studios

Game studios such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft receive a pseudonymised player identifier and gameplay session data necessary to deliver their games and certify RNG outcomes. Studios do not receive your full name, bank details, or KYC documents.

6.4 Regulatory & Law Enforcement Authorities

jin11 will disclose Personal Data to regulatory bodies, law enforcement agencies, or courts where required to do so by law or by a valid legal order. jin11 will, where legally permitted, notify affected Members of such disclosures.

6.5 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of jin11's assets, your Personal Data may be transferred to the successor entity. jin11 will notify affected Members by email at least 30 days before any such transfer and will ensure the successor entity is bound by privacy obligations no less protective than those in this Policy.

Section 7

Data Retention

jin11 retains your Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and licensing obligations. The following retention periods apply as a general guide:

After the applicable retention period expires, Personal Data is securely deleted or irreversibly anonymised. Where deletion is not immediately technically feasible (for example, data in backup archives), the data is isolated and protected from further active processing until deletion is completed.

Section 8

Security Measures

jin11 implements a layered, defence-in-depth security architecture to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• Encryption in Transit: All data exchanged between your browser and the jin11 Platform is protected by TLS 1.2 or higher (256-bit encryption). Our SSL certificate is issued by a globally trusted certificate authority and is renewed automatically.
• Encryption at Rest: Personal Data stored on jin11 servers — including KYC documents, payment identifiers, and account records — is encrypted using AES-256.
• Access Controls: Access to Personal Data is granted on a strict need-to-know basis. All staff with data access undergo background screening and are bound by confidentiality agreements. Access is logged and audited quarterly.
• Infrastructure Security: jin11 servers are hosted in ISO 27001-certified data centres with 24/7 physical security, redundant power supplies, and intrusion detection systems.
• Penetration Testing: The Platform undergoes regular penetration testing by independent security firms. Critical findings are remediated within 48 hours; non-critical findings within 30 days.
• Incident Response: jin11 maintains a formal data breach response plan. In the event of a breach that is likely to result in a risk to your rights and freedoms, jin11 will notify affected Members within 72 hours of becoming aware of the breach, with details of the nature of the incident and the steps taken to mitigate it.

Section 9

Cookies & Tracking Technologies

jin11 uses cookies and similar technologies (local storage, session tokens, and tracking pixels) to operate the Platform and, where consented, to analyse and improve it. The categories of cookies we use are as follows:

jin11 does not use third-party advertising cookies, retargeting pixels, or behavioural advertising tracking technologies. You can manage or disable non-essential cookies at any time through your browser settings. Disabling strictly necessary cookies will prevent you from logging in or using payment features.

Section 10

International Data Transfers

jin11 is an internationally operated platform, and as such your Personal Data may be transferred to and processed in countries outside Indonesia — for example, to our server infrastructure, game studio partners, or KYC technology providers located in other jurisdictions.

Where Personal Data is transferred internationally, jin11 ensures appropriate safeguards are in place, including:

• Contractual clauses equivalent to internationally recognised standard contractual clauses for data transfers.
• Ensuring recipient countries offer an adequate level of data protection, or applying binding supplementary measures where they do not.
• Conducting transfer impact assessments for high-risk processing activities involving sensitive Personal Data.

By creating an Account and using the jin11 Platform, you acknowledge that your Personal Data may be processed outside Indonesia in the manner described in this section.

Section 11

Your Data Rights

As a jin11 Member, you have the following rights in relation to your Personal Data. To exercise any of these rights, contact jin11 at [email protected] with the subject line "Data Rights Request". jin11 will respond within 30 days. Identity verification may be required before the request is actioned.

• Right of Access: You may request a copy of the Personal Data jin11 holds about you, together with information about how it is used and with whom it is shared.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or completed.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been unlawfully processed. Note that certain data — such as transaction records required for AML compliance — cannot be deleted within legally mandated retention periods.
• Right to Restriction of Processing: You may request that jin11 restrict processing of your data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: You may request a copy of your Personal Data in a structured, machine-readable format (JSON or CSV) for transfer to another service provider, where technically feasible.
• Right to Object: You have the right to object to processing based on jin11's legitimate interests, including direct marketing. Where you object to marketing, jin11 will cease that processing immediately.
• 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 prior to withdrawal.

Section 12

Minors

The jin11 Platform is strictly intended for adults aged 21 years and over. jin11 does not knowingly collect Personal Data from individuals under 21. Age is verified as part of the KYC process for all Members.

If jin11 becomes aware that Personal Data has been collected from a person under 21 — for example, through a fraudulent registration — the Account will be immediately suspended, all collected data will be deleted, and any deposited funds will be returned to the originating payment source.

If you believe a person under 21 has registered on jin11, please contact us immediately at [email protected]. We take child protection extremely seriously and will act on all credible reports without delay.

Section 13

Third-Party Services & Links

The jin11 Platform may contain references to third-party game studios and payment providers. While jin11 carefully selects its partners, jin11 is not responsible for the privacy practices of third-party entities. Once your data is passed to a payment processor or game studio under a data processing agreement, that entity's own privacy notice governs their internal processing beyond what is contracted with jin11.

jin11 does not embed third-party advertising networks or social media tracking widgets on the Platform. Any social media platforms referenced in jin11 marketing materials operate their own independent privacy policies over which jin11 has no control.

Section 14

Marketing Communications

With your consent, jin11 may contact you by email or push notification with information about new games, promotions, seasonal bonuses (such as Idul Fitri and Ramadhan campaigns), and platform updates. You may withdraw consent at any time by:

• Clicking the "Unsubscribe" link at the bottom of any jin11 marketing email.
• Updating your communication preferences in the Account Settings section of the Platform.
• Emailing [email protected] with the subject line "Unsubscribe" from your registered email address.

Withdrawal of marketing consent does not affect transactional notifications — such as deposit confirmations and withdrawal updates — which are necessary for the operation of your Account and cannot be turned off while your Account is active.

jin11 does not engage in SMS marketing, automated telephone marketing calls, or postal direct mail campaigns.

Section 15

Changes to This Privacy Policy

jin11 reviews this Privacy Policy at least annually and whenever a material change in our data practices occurs. Where a change is material — for example, a new category of data being collected, a new third-party processor being engaged, or a change in how long we retain transaction records — jin11 will notify you by email to your registered address at least 14 days before the change takes effect.

For minor, non-material changes (such as clarifications, corrections to typographical errors, or updated contact details), jin11 may update the Policy without prior notice. The "Last Reviewed" date at the top of this page will always reflect the most recent update.

Your continued use of the jin11 Platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the updated terms. If you disagree with a material change, you may close your Account in accordance with the Account Termination provisions in our Terms & Conditions.

Section 16

Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data, please contact the jin11 Data Privacy team using the details below:

• Email: [email protected] — use the subject line "Privacy Enquiry" for general questions or "Data Rights Request" when exercising a specific data right.
• Live Chat: Available 24/7 via the chat icon on the jin11 Platform. For data rights requests, our support agents will escalate your query to the Data Privacy team within one business day (WIB).

jin11 aims to resolve all Privacy Policy enquiries within 30 calendar days. For complex requests — such as large-scale data export or erasure requests — jin11 may extend this period by a further 30 days, in which case you will be notified in advance.