Privacy Policy — jnt110 Data Protection & Security

1.1 This Privacy Policy ("Policy") describes how jnt110 ("we", "us", "our", "the Company") collects, uses, stores, and protects personal information obtained from users ("you", "your", "Member") of the jnt110 platform, including the website at https://jnt110.cam, all associated mobile interfaces, and any related services.

1.2 By creating an account, accessing the platform, or using any jnt110 service, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with any part of this Policy, you must immediately cease using jnt110 services.

1.3 This Policy is incorporated into and forms part of jnt110's Terms & Conditions. Where conflicts arise, the Terms & Conditions shall take precedence on matters of contract; this Policy shall take precedence on matters of data protection and privacy.

1.4 jnt110 is committed to compliance with applicable data protection laws, including but not limited to Indonesia's Law No. 27 of 2022 on Personal Data Protection (UU PDP), and international standards such as the General Data Protection Regulation (GDPR) principles where relevant to our operations.

2.1 For the purposes of this Policy and applicable data protection law, jnt110 is the data controller responsible for your personal information. This means we determine how and why your personal data is processed.

2.2 If you have any questions, concerns, or requests regarding the processing of your personal data, you may contact our Data Protection Officer at [email protected] with the subject line "Data Protection Inquiry" or via our 24/7 live chat service.

2.3 jnt110 operates under the legal framework of its licensing jurisdiction. Our registered business details and data protection registration number are available upon request for the purposes of legal correspondence or regulatory inquiry.

3.1 jnt110 collects several categories of personal information necessary to provide betting and gaming services, verify your identity, process payments, prevent fraud, and comply with legal obligations. The data we collect includes:

3.2 Automated Data Collection. Some data is collected automatically when you use jnt110 services. This includes technical data captured by web server logs, cookies, pixels, and similar technologies. See Section 10 (Cookies & Tracking) for details.

3.3 Data You Provide Voluntarily. Additional data may be collected when you contact customer support, participate in surveys, enter competitions, or provide feedback. This data is used to improve our services and respond to your inquiries.

3.4 Third-Party Data. We may receive data about you from third parties, including payment processors (confirmation of successful deposits), KYC verification providers (identity validation results), and fraud prevention services (risk scores, device fingerprints).

4.1 jnt110 processes your personal data for the following purposes:

• Account Management: To create and maintain your account, verify your identity, authenticate logins, and process password resets;
• Service Provision: To accept bets, process game play, determine outcomes, credit winnings, and provide access to football betting (bandar bola), togel lottery, slots (slot gacor), live casino, and all other platform features;
• Payment Processing: To process deposits via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, and USDT; to verify payment method ownership; and to process withdrawal requests;
• Bonus & Promotions: To determine eligibility for bonuses, apply promotional offers, calculate wagering requirements, and distribute rewards;
• Customer Support: To respond to inquiries, resolve disputes, investigate complaints, and provide assistance via live chat and email;
• Fraud Prevention: To detect and prevent fraudulent activity, multiple account abuse, bonus abuse, money laundering, underage gambling, and other violations of our Terms & Conditions;
• Legal Compliance: To comply with Know Your Customer (KYC) and anti-money laundering (AML) regulations, respond to lawful requests from authorities, and maintain records as required by licensing and regulatory bodies;
• Platform Improvement: To analyze usage patterns, conduct A/B testing, improve user experience, fix technical issues, and develop new features;
• Marketing Communications: To send promotional emails, SMS messages, and in-platform notifications about new games, bonuses, and special offers (you may opt out at any time);
• Responsible Gaming: To enforce deposit limits, self-exclusion periods, age restrictions, and other responsible gaming measures; to identify at-risk behavior and offer support resources.

4.2 We do not use automated decision-making (including profiling) in ways that produce legal effects or similarly significant effects on you, except where necessary to prevent fraud or where you have given explicit consent.

5.1 jnt110 processes your personal data on one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions), including account creation, bet settlement, payment processing, and service delivery;
• Legal Obligation: Processing is required to comply with legal obligations, including KYC/AML regulations, tax reporting, licensing requirements, and lawful requests from authorities;
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, service improvement, and direct marketing (where not overridden by your rights);
• Consent: You have given explicit consent for specific processing activities, such as receiving marketing communications or participating in optional surveys (you may withdraw consent at any time).

5.2 Where we rely on legitimate interests, we have conducted a balancing test to ensure that our interests do not override your fundamental rights and freedoms. You have the right to object to processing based on legitimate interests — see Section 9 (Your Rights).

6.1 jnt110 may share your personal data with the following categories of recipients:

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP), e-wallet providers (OVO, DANA, GoPay, ShopeePay), and cryptocurrency payment gateways (for USDT transactions) require limited personal and financial data to process deposits and withdrawals;
• KYC & Verification Providers: Third-party identity verification services receive identity documents and personal details to confirm your age, identity, and address as part of our regulatory obligations;
• Fraud Prevention Services: Specialized fraud detection and prevention platforms receive technical data (IP addresses, device fingerprints) and transaction patterns to identify suspicious activity;
• Game Providers: Third-party game studios (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft) receive gameplay data necessary to operate live casino tables, slot games, and other third-party content;
• Cloud Service Providers: Data storage, server hosting, and backup services process personal data on our behalf under strict data processing agreements;
• Regulatory & Legal Authorities: We may disclose data to licensing bodies, gambling regulators, tax authorities, law enforcement agencies, and courts when required by law or in response to valid legal requests;
• Professional Advisors: Lawyers, auditors, accountants, and other professional service providers may access data on a need-to-know basis under confidentiality obligations;
• Business Transfers: In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring entity (Members will be notified and given the opportunity to delete their accounts).

6.2 All third-party service providers are contractually required to protect your data, use it only for specified purposes, and comply with applicable data protection laws. We conduct due diligence on all partners before sharing data.

6.3 We may share aggregated, anonymized, or pseudonymized data (which cannot identify you personally) for statistical analysis, research, or marketing purposes without restriction.

7.1 jnt110 implements industry-standard technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or damage. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols. Passwords are hashed using bcrypt or similar one-way cryptographic functions;
• Access Controls: Personal data is accessible only to authorized employees and contractors who require access to perform their duties. All personnel are bound by confidentiality obligations;
• Network Security: Firewalls, intrusion detection systems, and DDoS protection safeguard our infrastructure against cyber attacks;
• Secure Storage: KYC documents and sensitive financial data are stored in encrypted databases with restricted access. Backup systems are encrypted and geographically distributed;
• Regular Audits: We conduct periodic security audits, penetration testing, and vulnerability assessments to identify and address potential risks;
• Incident Response: We maintain a data breach response plan to detect, contain, and notify affected Members in the event of a security incident, as required by law.

7.2 While we take all reasonable precautions, no method of electronic transmission or storage is 100% secure. You acknowledge that you provide data at your own risk. We cannot guarantee absolute security against sophisticated attacks or unauthorized third-party access.

7.3 You are responsible for maintaining the confidentiality of your account credentials. If you suspect unauthorized access to your account, you must notify us immediately via live chat or email at [email protected].

8.1 jnt110 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Accounts: Data is retained for the duration of your account's active status and for six (6) months following your last login or transaction;
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years after account closure, as required by anti-money laundering regulations;
• Transaction Records: Financial transaction history, betting records, and payment data are retained for seven (7) years to comply with tax law and regulatory requirements;
• Marketing Data: If you opt out of marketing communications, your preference is retained indefinitely to ensure we do not contact you again;
• Self-Exclusion Records: Self-exclusion requests are retained permanently to prevent future account re-opening, even if you request data deletion;
• Support Communications: Customer support chat logs and email correspondence are retained for three (3) years for quality assurance and dispute resolution purposes.

8.2 After the applicable retention period expires, personal data is securely deleted or anonymized such that it can no longer identify you. Anonymized data may be retained indefinitely for statistical and research purposes.

8.3 If you request account closure, we will delete or anonymize your data within ninety (90) days, except where longer retention is required by law or for the protection of legal rights.

9.1 Under applicable data protection laws, you have the following rights regarding your personal data:

• Right of Access: You may request a copy of the personal data we hold about you, including details about how it is processed. We will respond within thirty (30) days of a valid request;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. You can update most account information directly in your account settings;
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data, subject to legal retention obligations. Self-exclusion records cannot be deleted to protect you from re-opening an account;
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances, such as while disputing its accuracy or challenging the lawfulness of processing;
• Right to Data Portability: You may request a machine-readable copy of personal data you provided to us, for transfer to another service provider;
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless we have compelling legitimate grounds that override your rights;
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time. This does not affect the lawfulness of processing conducted prior to withdrawal;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Indonesian data protection authority (Lembaga Pelindungan Data Pribadi) or the relevant supervisory authority in your jurisdiction.

9.2 To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request" and provide sufficient information to verify your identity. We will respond within the timeframes required by applicable law.

9.3 These rights are subject to legal limitations and exceptions. For example, we may be unable to delete data required for legal compliance or the establishment, exercise, or defense of legal claims.

10.1 jnt110 uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content. A cookie is a small text file stored on your device by your web browser.

10.2 Types of Cookies We Use:

• Essential Cookies: Required for platform functionality, including session management, login authentication, and security features. These cookies cannot be disabled without impairing core features;
• Performance Cookies: Collect aggregated data about how visitors use the platform, including pages visited, time spent, and error messages. Used to improve platform performance;
• Functional Cookies: Remember your preferences (language, currency, display settings) to provide a more personalized experience;
• Marketing Cookies: Track your activity across sessions to deliver targeted promotions and measure the effectiveness of marketing campaigns. These cookies may be set by third-party advertising partners.

10.3 Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when cookies are being sent. Please note that disabling cookies may impair platform functionality and prevent you from accessing certain features.

10.4 We also use third-party analytics services such as Google Analytics to understand user behavior. These services may use cookies and collect IP addresses, but data is aggregated and anonymized. You may opt out using browser extensions or device settings.

11.1 jnt110 operates internationally, and your personal data may be transferred to, stored in, or processed in countries outside Indonesia, including jurisdictions that may have different data protection standards than Indonesian law.

11.2 Where we transfer data internationally, we implement appropriate safeguards to protect your information, including:

• Standard contractual clauses approved by competent data protection authorities;
• Data processing agreements requiring recipients to apply equivalent data protection standards;
• Transfer to countries recognized as providing adequate data protection under Indonesian law or international frameworks.

11.3 By using jnt110 services, you acknowledge and consent to the international transfer of your data as described in this Policy.

12.1 jnt110 strictly prohibits use of the platform by any person under the age of 21. We conduct age verification as part of the KYC process and will immediately suspend any account found to belong to a minor.

12.2 If we discover that we have inadvertently collected personal data from a person under 21 years of age, we will delete that data as quickly as possible and permanently ban the associated account.

12.3 If you believe a minor has accessed jnt110 services or provided personal data to us, please contact us immediately at [email protected] with the subject line "Underage User Report."

13.1 jnt110 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Material changes will be communicated to you via email, platform notification, or prominent notice on the homepage.

13.2 The "Effective Date" at the top of this Policy indicates when it was last updated. We encourage you to review this Policy periodically to stay informed about how we protect your data.

13.3 Your continued use of jnt110 services after changes to this Policy are published constitutes acceptance of the revised Policy. If you do not agree with any changes, you must cease using the platform and request account closure.

14.1 If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact jnt110 through the following channels:

• Email: [email protected] (for general inquiries) or use subject line "Data Protection Inquiry" for privacy-specific questions;
• Live Chat: Available 24/7 directly on the platform — our Indonesian-speaking agents can assist with privacy questions and data rights requests;
• Data Protection Officer: For formal data rights requests or complaints, contact our Data Protection Officer at [email protected] with subject line "DPO Request";
• Postal Address: Available upon request for formal legal correspondence.

14.2 We will respond to all privacy-related inquiries within thirty (30) days. For complex requests, we may extend this period by an additional sixty (60) days and will notify you of any delay.