Privacy Policy

1. Introduction and Scope

jaya89 ("jaya89", "we", "us", "our") is committed to protecting the privacy and personal data of everyone who uses our online gaming platform at https://jaya89.cam (the "Platform"). This Privacy Policy explains what personal data we collect from you, why we collect it, how we use and protect it, how long we retain it, and the rights available to you as a data subject.

This Policy applies to all jaya89 Services including the website, mobile applications, Live Chat, email communications, and any other channels through which you interact with jaya89. By registering an Account or otherwise using our Platform, you confirm that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy, which together govern your relationship with jaya89.

2. Data Controller Identity

For the purposes of applicable data-protection legislation, the data controller responsible for your personal data is jaya89, operating the Platform at https://jaya89.cam. All enquiries regarding the processing of personal data should be directed to our Privacy Team at the contact details provided in Section 14.

3. Personal Data We Collect

jaya89 collects personal data in several categories depending on the nature of your interaction with our Platform.

3.1 Identity and Contact Data

• Full legal name as it appears on government-issued identification
• Date of birth (to verify that you are at least 21 years of age)
• Gender (optional, collected during registration)
• Nationality and country of residence
• Residential address, including city, province, and postcode
• Valid email address
• Indonesian mobile phone number

3.2 Account and Authentication Data

• Username and encrypted password
• Security questions and answers (where applicable)
• Two-factor authentication credentials
• Login timestamps, session duration, and IP addresses
• Device identifiers and browser fingerprint data

3.3 Identity Verification (KYC) Data

• Scanned copies or photographs of government-issued photo identification (e.g., Indonesian National ID — KTP, passport, driver's licence)
• Proof-of-address documents (utility bills, bank statements)
• Selfie photographs taken during KYC verification
• Source-of-funds documentation where required by our compliance procedures

3.4 Financial and Transaction Data

• Bank account numbers and account holder names for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, and other Indonesian banks
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja
• Deposit and withdrawal amounts, dates, and reference numbers
• Transaction histories and gaming activity records
• Bonus claims and wagering records

3.5 Gaming Activity Data

• Games played, bet amounts, win/loss records
• Sports betting selections including match choices, odds accepted, and bet outcomes
• Live casino session data including dealer interactions
• Responsible Gaming tool settings including deposit limits, session time limits, and self-exclusion status

3.6 Technical and Usage Data

• IP address and approximate geographic location derived from IP
• Device type (mobile, desktop, tablet), operating system, and browser version
• Pages visited, time spent on pages, click-path data, and referral sources
• Error logs and crash reports

3.7 Communications Data

• Records of Live Chat conversations with customer support
• Email correspondence between you and jaya89
• WhatsApp message records (where support is provided via WhatsApp)
• In-app messaging records

4. How We Collect Data

jaya89 collects personal data through the following means:

• Directly from You: When you register an Account, complete KYC verification, make deposits or withdrawals, contact customer support, or participate in promotions
• Automatically: When you use our Platform, we automatically collect technical and usage data via cookies, web beacons, and similar tracking technologies (see Section 9)
• From Third Parties: We may receive information from payment processors, identity verification providers, fraud-prevention services, and analytics partners
• From Public Sources: We may consult publicly available information to verify identity or confirm details provided during registration

5. Purposes and Legal Bases for Processing

We process your personal data only where we have a lawful basis for doing so. The table below summarises the principal purposes for which jaya89 processes personal data and the corresponding legal basis for each.

6. Data Retention

jaya89 retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal requirements. Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of your Account plus 5 years after Account closure to satisfy anti-money laundering regulations
• KYC Documents: Retained for 5 years after Account closure, as required by applicable financial regulations
• Transaction and Financial Data: Retained for 7 years in line with accounting and audit requirements
• Gaming Activity Logs: Retained for 2 years after last activity, then anonymised for statistical analysis
• Customer Support Records: Retained for 2 years after ticket resolution
• Technical and Usage Data: Retained for 13 months, then aggregated and anonymised

After applicable retention periods have elapsed, personal data is securely deleted or irreversibly anonymised so it can no longer be linked to an individual.

7. Data Sharing and Disclosure

jaya89 does not sell, rent, or trade your personal data to third parties for commercial marketing purposes. We may, however, share your data with trusted parties in the following circumstances:

7.1 Service Providers

We engage carefully vetted third-party service providers who process data on our behalf under strict contractual obligations. These include:

• Payment processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to execute financial transactions
• Identity verification providers: KYC and document verification platforms that authenticate submitted identity documents
• Fraud prevention services: Third-party risk and fraud detection tools that analyse transaction patterns
• Cloud hosting and infrastructure providers: Secure data-centre operators who store Platform data under industry-standard security controls
• Analytics providers: Services that help us understand how users interact with our Platform (data is aggregated and anonymised where possible)
• Customer support tools: Live Chat and helpdesk software providers bound by confidentiality agreements

All service providers are contractually required to process personal data solely for the purposes instructed by jaya89, to maintain appropriate security standards, and to delete data once their engagement concludes.

7.2 Game Content Providers

Where you play games supplied by third-party studios such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Pocket Games Soft, or Spribe, certain technical and session data may be transmitted to those providers for the purpose of game operation, fairness verification, and jackpot calculation. These providers are bound by their own data protection obligations and may not use your data for independent marketing purposes.

7.3 Legal and Regulatory Disclosure

We may disclose personal data to government authorities, law enforcement agencies, courts, or regulators when required to do so by applicable Indonesian law or by a valid legal order. In such cases, we will disclose only the minimum data necessary to satisfy the legal requirement and will, where permitted, notify you of the disclosure.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of jaya89's business, personal data held by jaya89 may be transferred to the acquiring entity as part of the transaction. We will notify affected Users via email or prominent notice on the Platform prior to any such transfer, and the acquiring entity will be required to honour the commitments made in this Privacy Policy.

7.5 Consent-Based Sharing

We may share your data with additional third parties where you have given explicit prior consent to such sharing. You may withdraw that consent at any time by contacting our Privacy Team (see Section 14).

8. International Data Transfers

jaya89 primarily stores and processes personal data within Indonesia and in data centres located in the Asia-Pacific region. Some of our third-party service providers operate from outside Indonesia, which may involve transferring your personal data to countries that have different data protection standards to those in force in Indonesia.

Where such transfers occur, jaya89 implements appropriate safeguards including:

• Standard contractual clauses requiring recipient parties to protect data to an equivalent standard
• Data processing agreements with all international vendors
• Transfer impact assessments for high-risk jurisdictions
• Technical measures such as pseudonymisation and encryption to minimise risk during transit

By using jaya89 Services, you acknowledge that your data may be transferred internationally under these safeguards. If you have questions about specific transfers, please contact our Privacy Team.

9. Cookies and Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device and remember information about your visit such as language preferences, session status, and shopping-cart contents. jaya89 uses cookies and similar technologies (web beacons, pixel tags, local storage) to deliver and improve our Platform.

9.2 Categories of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. They cannot be disabled without preventing core Platform functionality.
• Performance and Analytics Cookies: These collect anonymised data about how visitors use our Platform — pages visited, time on site, error messages — to help us improve performance and user experience.
• Functional Cookies: These remember your preferences such as language, currency display (IDR), and last-visited game category to personalise your experience.
• Responsible Gaming Cookies: These store your self-imposed limit settings and session time reminders locally on your device to enforce the responsible gaming tools you have activated.

9.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You may block or delete cookies at any time; however, disabling strictly necessary cookies will impair your ability to use jaya89 Services, including logging in and processing transactions. Instructions for managing cookies in common browsers are available through your browser's help documentation.

10. Your Privacy Rights

As a data subject, you have the following rights with respect to your personal data held by jaya89. These rights are subject to applicable legal limitations and identity verification requirements.

• Right of Access: You may request a copy of all personal data we hold about you, including the categories of data processed, the purposes of processing, and any third parties with whom your data has been shared.
• Right to Rectification: If any personal data we hold is inaccurate or incomplete, you have the right to request correction. Minor updates such as email address changes can be made directly in your Account settings.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data. Note that this right is subject to our legal retention obligations — for example, KYC and transaction records must be retained for 5–7 years regardless of account closure.
• Right to Restriction of Processing: You may request that we restrict processing of your data while a dispute regarding accuracy or lawfulness is resolved.
• Right to Data Portability: Where processing is based on your consent or contract performance, you may request your data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interest, including profiling for marketing purposes. We will cease that processing unless we can demonstrate compelling legitimate grounds.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

11. Children and Minors

jaya89 is an adult gaming platform intended exclusively for individuals who are at least 21 years of age. We do not knowingly collect, process, or store personal data relating to any person under the age of 21. If you are under 21, you must not register an Account or use our Services.

If we become aware that we have inadvertently collected personal data from a person under 21, we will take immediate steps to delete that data and close the associated Account. Parents or guardians who believe a minor has registered with jaya89 should contact our support team immediately so we can investigate and act accordingly.

We use age verification as part of our KYC process to confirm that all registered Users meet the minimum age requirement. This is a mandatory step before any deposits or withdrawals are permitted.

12. Security Measures

jaya89 employs a multi-layered security framework to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• Transport Encryption: All data transmitted between your device and our servers is protected using 256-bit SSL/TLS encryption, the same standard used by international financial institutions.
• At-Rest Encryption: Sensitive data stored in our databases — including KYC documents, financial records, and authentication credentials — is encrypted at rest using AES-256.
• Access Controls: Personal data is accessible only to authorised jaya89 personnel who require it to perform their job functions. Role-based access controls and audit logs are enforced across all internal systems.
• Regular Security Audits: Our Platform and infrastructure undergo regular penetration testing and security audits conducted by independent third-party firms.
• Password Security: Passwords are stored as salted cryptographic hashes and are never stored in plaintext. We recommend using strong, unique passwords and enabling two-factor authentication.
• Incident Response: We maintain a documented data-breach response plan. In the event of a breach affecting your personal data, we will notify you and relevant authorities within the timeframes required by applicable law.

While we employ robust security measures, no internet-based platform can guarantee absolute security. You are responsible for keeping your Account credentials confidential and for notifying us immediately if you suspect any unauthorised use of your Account.

13. Changes to This Privacy Policy

jaya89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform functionality. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page
• Display a prominent notice on the Platform for at least 14 days following the change
• Send an email notification to the address registered on your Account

Your continued use of jaya89 Services after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated terms, you should discontinue use of our Services and request Account closure.

We encourage you to review this Privacy Policy periodically to stay informed about how jaya89 protects your personal data.

14. Contact and Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or jaya89's handling of your personal data, please contact our Privacy Team through the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line
• Live Chat: Available 24 hours a day, 7 days a week on the jaya89 Platform

We aim to acknowledge all privacy enquiries within 24 hours and to provide a full response within 30 calendar days. For complex requests, we may require additional time; in such cases, we will inform you of the extended timeline within the initial 30-day period.

If you are not satisfied with our response, you have the right to escalate your complaint to the relevant data protection authority in your jurisdiction. For Indonesian residents, enquiries regarding personal data protection may be directed to the Ministry of Communication and Information Technology (Kementerian Komunikasi dan Informatika — Kominfo).