Privacy Policy

Definitions

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

• "jktwim", "we", "us", "our" — the online gaming platform operated under the jktwim brand, serving Indonesian and international players with sports betting, live casino, slots, and togel (traditional numbers lottery) markets.
• "User", "you", "your" — any individual who visits, registers, or holds an account on the jktwim platform, regardless of whether they have made a deposit or placed a wager.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, national identity card (KTP) number, residential address, email address, telephone number, bank account details, IP address, device identifiers, and browsing behavior on our platform.
• "Processing" — any operation or set of operations performed on Personal Data, whether automated or manual, including collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure by transmission, dissemination, restriction, erasure, or destruction.
• "KYC" — Know Your Customer, the identity verification process required by jktwim to comply with anti-money laundering (AML) and counter-terrorist financing (CTF) obligations imposed by our international licensing authority.
• "Platform" — the jktwim website, mobile-optimized web interface, and any associated software applications through which our services are delivered.
• "Cookies" — small text files placed on your device by our web server to store preferences, track session state, and support fraud prevention.

Data We Collect

jktwim collects several categories of Personal Data from Users, depending on the nature and stage of your interaction with our platform. The following table summarises the main data types we collect and the primary purpose for each collection:

How We Collect Data

Personal Data is collected through the following channels and methods:

• Direct provision: You provide Personal Data directly when you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact customer support, or update your account details.
• Automated collection: Technical and behavioral data is collected automatically through cookies, log files, and server analytics as you navigate and interact with the jktwim platform.
• Third-party sources: We may receive limited Personal Data from third-party payment processors (to confirm your bank account ownership), fraud prevention services (to verify IP address reputation), and identity verification providers (to cross-check KYC documents against public records).
• Public sources: In cases where KYC raises compliance concerns, we may consult publicly available databases, sanction lists, and adverse media reports to fulfill our AML/CTF obligations.

jktwim does not purchase consumer data from data brokers for marketing purposes. All data collection is limited to the operational and regulatory requirements of running a licensed online gaming platform.

Purposes of Processing

jktwim processes your Personal Data for the following specific purposes, each of which is necessary for the operation of our platform or required by law:

• Account Management: To create and maintain your jktwim account, authenticate your login sessions, and allow you to access the full range of gaming services available on the platform.
• Identity Verification (KYC): To verify your identity, confirm you are at least 21 years of age, and ensure compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations imposed by our licensing jurisdiction.
• Payment Processing: To process deposits into your account and withdrawals to your verified bank account or e-wallet, and to reconcile payment transactions with Indonesian banks (BCA, BRI, BNI, Mandiri, etc.) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Fraud Prevention & Security: To detect and prevent fraudulent activity, multi-accounting, bonus abuse, money laundering, and unauthorized access to user accounts through monitoring of IP addresses, device fingerprints, and behavioral patterns.
• Responsible Gaming: To monitor betting patterns and identify potential signs of problem gambling, to enforce deposit limits and self-exclusion requests, and to provide targeted responsible gaming interventions where appropriate.
• Customer Support: To respond to your inquiries, resolve disputes, investigate complaints, and provide technical assistance through live chat, email, and support ticket systems.
• Service Improvement: To analyze aggregated, anonymized usage data to improve platform performance, optimize user experience, develop new features, and tailor our game selection to player preferences.
• Marketing Communications: To send promotional emails about new bonuses, game releases, and special offers to users who have opted in to marketing communications. You may opt out at any time via the unsubscribe link in each email.
• Legal Compliance: To respond to lawful requests from courts, regulators, or law enforcement agencies, and to comply with applicable gambling, financial crime, and data protection laws in our licensing jurisdiction and in Indonesia where relevant.

Legal Basis for Processing

Under internationally recognized data protection principles (including those established by the EU General Data Protection Regulation, which jktwim uses as a global benchmark), Personal Data may only be processed where a lawful basis exists. jktwim relies on the following legal bases:

• Contractual Necessity: Processing your Personal Data is necessary to perform our contract with you (the Terms & Conditions you accepted upon registration) and to deliver the gaming services you requested. This applies to account management, payment processing, and customer support.
• Legal Obligation: Processing is required to comply with legal and regulatory obligations imposed on jktwim, including KYC, AML/CTF checks, age verification (21+ enforcement), record-keeping requirements, and responses to lawful authority requests.
• Legitimate Interests: Processing is necessary for jktwim's legitimate business interests — fraud prevention, security monitoring, service improvement, and aggregated analytics — provided these interests do not override your fundamental privacy rights. We conduct regular balancing tests to ensure our use of this basis is proportionate.
• Consent: Where required by law, we obtain your explicit consent before processing certain data — for example, consent to receive promotional marketing emails, consent to place non-essential cookies, and consent to use your image in promotional materials (if applicable). You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

Data Sharing & Disclosure

jktwim does not sell your Personal Data to third-party marketers or data brokers. However, we do share Personal Data with selected third parties in the following limited circumstances, always subject to contractual data protection clauses:

• Payment Processors: We share your bank account details and transaction information with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to the extent necessary to process deposits and withdrawals.
• KYC & Identity Verification Services: We share identity documents and personal details with third-party KYC providers who perform document verification, biometric checks, and database cross-referencing on our behalf.
• Fraud Prevention Services: We share IP addresses, device fingerprints, and transaction metadata with fraud detection platforms that help us identify multi-accounting, bonus abuse, and financial crime.
• Game Providers: Aggregated, anonymized gameplay data (not Personal Data) is shared with game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft for the purpose of game performance analytics and RNG certification.
• Customer Support Platforms: Live chat transcripts and support ticket data are processed through third-party customer service software providers, all of whom are contractually bound to protect your data.
• Regulatory Authorities: We disclose Personal Data to our licensing authority and to law enforcement agencies where required by law, court order, or regulatory directive.
• Legal Advisors & Auditors: We may share Personal Data with external legal counsel, compliance auditors, and accountants under strict confidentiality agreements when necessary for legal proceedings or regulatory audits.

International Data Transfers

jktwim operates a globally distributed platform. Your Personal Data may be transferred to, stored, and processed in jurisdictions outside Indonesia, including but not limited to the jurisdiction in which jktwim holds its primary gaming license, and data center locations in Europe, Asia, and North America.

Where we transfer Personal Data to countries that do not provide an equivalent level of data protection to internationally recognized standards, we implement appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission as a mechanism for lawful data transfers.
• Binding Corporate Rules (where transfers occur within the jktwim corporate group).
• Contractual clauses requiring third-party processors to implement technical and organizational measures equivalent to those required by the EU GDPR.

By using the jktwim platform, you acknowledge and consent to the international transfer of your Personal Data as described in this section. If you have concerns about cross-border data transfers, please contact our Data Protection Officer at the email address listed in Section 15.

Data Retention Periods

jktwim retains your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized such that it can no longer be linked to an identifiable individual.

Cookies & Tracking Technologies

jktwim uses cookies and similar tracking technologies to enhance your experience, secure the platform, and analyze usage patterns. A cookie is a small text file stored on your device that allows our server to recognize you on subsequent visits.

We use the following categories of cookies:

• Essential Cookies: Required for core platform functionality including user authentication, session management, security verification, and fraud prevention. These cookies cannot be disabled without breaking critical site features.
• Functional Cookies: Used to remember your preferences (language, currency display, odds format), game history, and collapsed/expanded UI elements for a more personalized experience. These cookies improve convenience but are not strictly essential.
• Performance/Analytics Cookies: Used to collect aggregated, anonymized data about how visitors interact with jktwim — which pages are most popular, which features are used most often, where users encounter errors. This data helps us optimize the platform.
• Security Cookies: Used for fraud detection and to identify suspicious login patterns, device fingerprinting, and bot activity. These cookies are critical for protecting your account and the platform from abuse.

You can control cookie preferences through your browser settings. However, disabling essential cookies will prevent you from logging in or using core platform features. For detailed instructions on managing cookies in major browsers, visit aboutcookies.org.

Security Measures

jktwim takes the security of your Personal Data extremely seriously and employs a multi-layered approach to protect against unauthorized access, disclosure, alteration, and destruction. Our security framework includes:

• TLS/SSL Encryption: All data transmitted between your device and our servers is encrypted using Transport Layer Security (TLS) with 256-bit encryption, the same standard used by banks and financial institutions worldwide.
• Database Encryption: Personal Data stored at rest is encrypted using AES-256 encryption, with encryption keys stored separately from the data they protect and rotated on a regular schedule.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. Only authorized personnel with legitimate operational reasons (customer support, compliance, finance, technical administration) can access customer records, and all access is logged and audited.
• Two-Factor Authentication (2FA): jktwim supports optional 2FA for user accounts, and 2FA is mandatory for all staff members with access to backend systems.
• Firewall & Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) that monitor network traffic in real time and block malicious activity.
• Regular Security Audits: jktwim undergoes periodic third-party security audits and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Staff Training: All employees with access to Personal Data receive mandatory training on data protection principles, security best practices, and their obligations under this Privacy Policy.
• Incident Response Plan: In the unlikely event of a data breach, jktwim maintains a comprehensive incident response plan to contain the breach, assess the impact, notify affected users, and report to relevant authorities as required by law.

While we implement industry-standard security measures, no online platform can guarantee absolute security. You play a critical role in protecting your own data by using a strong, unique password for your jktwim account, enabling 2FA, and never sharing your login credentials with anyone.

Your Privacy Rights

Under internationally recognized data protection principles, you have the following rights with respect to your Personal Data held by jktwim. These rights are subject to certain legal limitations and exceptions, but jktwim is committed to facilitating their exercise wherever possible:

• Right of Access: You have the right to request a copy of the Personal Data jktwim holds about you, including information about the purposes of processing, the categories of data held, the recipients to whom it has been disclosed, and the retention period. We will provide this information free of charge within one (1) month of a verified request.
• Right to Rectification: If any of your Personal Data is inaccurate or incomplete, you have the right to request that it be corrected or updated. You can update most details directly through your account dashboard, or contact support for assistance.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may request deletion of your Personal Data — for example, if it is no longer necessary for the purposes for which it was collected, or if you withdraw consent and no other legal basis exists. This right is subject to our legal retention obligations (see Section 8).
• Right to Restriction of Processing: You may request that we temporarily restrict processing of your Personal Data while we verify its accuracy, assess the lawfulness of processing, or fulfill a legitimate interest objection.
• Right to Data Portability: Where processing is based on consent or contractual necessity and carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format (e.g., CSV or JSON) and to transmit that data to another controller.
• Right to Object: You may object to processing of your Personal Data where the legal basis is legitimate interests or where the processing is for direct marketing purposes. jktwim will cease the processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), you have the right to withdraw that consent at any time by clicking the unsubscribe link in marketing emails or contacting support. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Right to Lodge a Complaint: If you believe jktwim has failed to comply with applicable data protection laws, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction or in the jurisdiction where jktwim operates.

To exercise any of the above rights, please submit a request to [email protected] with the subject line "Privacy Rights Request." We will respond within one (1) month and may request additional identification verification to ensure we release data only to the legitimate account holder.

Children's Privacy (21+ Policy)

jktwim is an adult-only platform. Use of our services is strictly prohibited to anyone under the age of 21. We do not knowingly collect Personal Data from individuals under 21 years of age, and we actively screen registrations to enforce this age restriction.

If we discover that we have inadvertently collected Personal Data from a person under 21, we will:

• Immediately suspend the account;
• Delete all associated Personal Data from our systems;
• Return any deposited funds to the verified payment source; and
• Notify the account holder (or their parent/guardian if contact details are available) of the closure and the reason.

Third-Party Links & Services

The jktwim platform may contain links to external websites operated by game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft), payment providers, or other third parties. jktwim is not responsible for the privacy practices or content of these external sites.

When you click a link that takes you away from the jktwim domain, the privacy policy and terms of the destination site apply. We encourage you to review the privacy policies of any third-party sites you visit. jktwim has no control over and assumes no responsibility for third-party data collection practices.

Amendments to This Privacy Policy

jktwim reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or operational requirements. When material changes are made, we will notify registered users via email to the address on file at least seven (7) calendar days before the updated policy takes effect.

The "Last Updated" date at the top of this page indicates when the policy was last revised. Continued use of the jktwim platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you must cease using the platform and contact support to close your account before the amendment's effective date.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

Contact Information & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or jktwim's data practices, or if you wish to exercise any of the privacy rights outlined in Section 11, please contact us through the following channel:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Privacy Requests: "Privacy Rights Request" or "Data Protection Inquiry"
• Response Time: We aim to acknowledge privacy-related requests within 48 hours and provide a substantive response within one (1) month. Complex requests may take longer, and we will notify you if an extension is necessary.

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 your jurisdiction of residence or in the jurisdiction where jktwim operates. We will provide the relevant contact details upon request.