Section 1 Overview & Scope
jp369 ("we", "us", "our") operates the online betting and gaming platform accessible at https://jp369.cam (the "Platform"). This Privacy Policy describes how jp369 collects, uses, stores, discloses, and protects the personal information of individuals ("you", "your", "Player") who visit, register on, or use our Platform and associated services.
This Policy applies to all personal data processed by jp369 in connection with:
- Account registration and management;
- Identity verification (KYC) processes;
- Deposits, withdrawals, and payment processing;
- Betting, gaming, and use of all Platform features;
- Customer support interactions;
- Marketing communications (where consent has been given);
- Browsing and navigating the Platform, including via mobile devices.
By registering an Account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform and contact our support team to close your Account.
This Policy is written in plain English to be as clear as possible. It is incorporated by reference into our Terms & Conditions and forms part of the binding agreement between you and jp369.
Section 2 Definitions
The following definitions apply throughout this Privacy Policy:
- "Personal Data" means any information that identifies or could reasonably identify a natural person, directly or indirectly — including name, identification number, location data, online identifier, or factors specific to the physical, economic, cultural, or social identity of that person.
- "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, erasure, or destruction.
- "Data Controller" means jp369, the entity that determines the purposes and means of processing Personal Data.
- "Data Processor" means any third party that processes Personal Data on behalf of jp369 under a data processing agreement.
- "Sensitive Personal Data" means a subset of Personal Data that warrants heightened protection — including government-issued ID numbers, financial account details, and biometric data collected for identity verification purposes.
- "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
- "Cookie" means a small text file placed on your device by the Platform to enable functionality, analyse usage, or deliver relevant content.
- "WIB" means Western Indonesia Time (UTC+7), the default time zone referenced in this Policy for all time-sensitive processing activities unless otherwise stated.
Section 3 Data We Collect
jp369 collects Personal Data across several categories depending on how you interact with the Platform. The table below summarises the primary data categories and specific data points collected:
| Category | Data Points Collected | Required? |
|---|---|---|
| Identity Data | Full legal name, date of birth, gender, nationality, government ID number (KTP/Passport/SIM), ID document images | Mandatory |
| Contact Data | Email address, Indonesian mobile phone number, residential address | Mandatory |
| Financial Data | Bank account name, bank account number, bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata), e-wallet identifier (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history | Mandatory |
| Technical Data | IP address, device type, operating system, browser type and version, session timestamps, login history | Automatic |
| Usage Data | Pages visited, betting and gaming activity, search queries within the Platform, feature interaction logs | Automatic |
| Communications Data | Customer support chat transcripts, email correspondence, complaint records | As applicable |
| Marketing Preferences | Opt-in/opt-out status for promotional emails and SMS, preferred communication channel | Optional |
jp369 does not collect special categories of Personal Data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, or health data, except where voluntarily disclosed by a Player in a support interaction.
Section 4 How We Collect Data
jp369 collects Personal Data through the following channels:
4.1 Direct Collection
Data you provide directly to jp369 when you:
- Complete the Account registration form;
- Submit KYC documents for identity and address verification;
- Make a deposit or withdrawal request, including providing payment account details;
- Contact our customer support team via live chat or email;
- Respond to a survey, promotion, or voluntary feedback request;
- Update your Account profile or communication preferences.
4.2 Automated Collection
Data collected automatically when you use the Platform, including through cookies, web beacons, pixel tags, and server-side logs. This includes your IP address, device identifiers, session duration, pages accessed, and in-platform actions taken. See Section 8 for full details on our cookie practices.
4.3 Third-Party Sources
In limited circumstances, jp369 may receive Personal Data about you from third parties, including:
- KYC verification service providers who cross-reference your submitted documents against national identity databases;
- Payment processors and banking partners (BCA, BRI, BNI, Mandiri, and e-wallet operators) who confirm the status and ownership of payment instruments;
- Fraud detection and anti-money-laundering (AML) screening services that flag accounts or transactions requiring enhanced due diligence;
- Publicly available sources such as sanctions lists, politically exposed persons (PEP) databases, and adverse media registries.
Section 5 Purposes & Legal Basis
jp369 processes Personal Data only where a valid legal basis exists. The primary purposes for which we process your data, and the corresponding legal basis for each, are set out below:
| Purpose | Legal Basis |
|---|---|
| Account creation and management | Performance of a contract |
| KYC identity and age verification | Legal obligation; legitimate interest |
| Processing deposits and withdrawals via local Indonesian banks and e-wallets | Performance of a contract |
| Fraud prevention, AML screening, and security monitoring | Legal obligation; legitimate interest |
| Providing customer support and resolving disputes | Performance of a contract; legitimate interest |
| Sending transactional emails and Account notifications | Performance of a contract |
| Sending promotional communications and personalised offers | Consent |
| Platform analytics and service improvement | Legitimate interest |
| Responsible gaming monitoring and intervention | Legal obligation; legitimate interest |
| Compliance with applicable laws, regulations, and licensing requirements | Legal obligation |
Where jp369 relies on legitimate interest as the legal basis for processing, we have conducted a balancing test to confirm that our interests do not override your fundamental privacy rights. You may request a summary of that balancing test by contacting our privacy team.
Section 6 Data Sharing
jp369 does not sell, rent, or trade your Personal Data to any third party for commercial purposes. We share Personal Data only in the limited circumstances described below, and only to the extent necessary for the stated purpose:
6.1 Service Providers (Data Processors)
jp369 engages carefully vetted third-party service providers that process Personal Data strictly on our behalf and under binding data processing agreements. These include:
- KYC & Identity Verification Vendors: Process government-issued ID documents to confirm identity and age;
- Payment Processors & Banking Partners: Facilitate IDR deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, and LinkAja;
- Fraud & AML Screening Services: Screen transactions and accounts against international sanctions and PEP databases;
- Customer Support Platform Providers: Host and manage live chat and ticketing systems used to deliver support;
- Cloud Infrastructure Providers: Host Platform data on secure, access-controlled servers.
6.2 Legal & Regulatory Disclosure
jp369 may disclose Personal Data to competent authorities, law enforcement agencies, or regulatory bodies where required by applicable law, court order, or valid legal process. We will notify you of such disclosures to the extent permitted by law.
6.3 Business Transfers
In the event of a merger, acquisition, asset sale, or corporate restructuring involving jp369, Personal Data held at the time of the transaction may be transferred to the acquiring entity. We will notify affected Players prior to any such transfer and ensure that the receiving entity is bound by privacy obligations no less protective than those in this Policy.
jp369 will never share your Personal Data with third-party advertisers, data brokers, or marketing aggregators. Any provider that receives your data is contractually prohibited from using it for their own purposes.
Section 7 International Data Transfers
jp369 operates internationally, and your Personal Data may be transferred to, stored in, or processed in countries outside Indonesia. These countries may have data protection laws that differ from those in your home jurisdiction.
Whenever jp369 transfers Personal Data internationally, we ensure that appropriate safeguards are in place, including:
- Contractual clauses with recipients that impose data protection obligations equivalent in substance to those in this Policy;
- Transfer to jurisdictions that have been recognised as providing an adequate level of data protection by a competent regulatory authority;
- Implementation of technical and organisational security measures appropriate to the risk profile of the transfer.
You may request further information about the specific safeguards applied to any international transfer of your Personal Data by contacting our privacy team at the details provided in Section 15.
Section 8 Cookies & Tracking Technologies
jp369 uses cookies and similar tracking technologies to operate the Platform, analyse usage patterns, and deliver a consistent user experience. The categories of cookies we deploy are as follows:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Enable core Platform functions — login session management, security tokens, language preferences, and bet-slip state | Session / up to 24 hours |
| Functional | Remember your preferences such as odds format, deposit method defaults, and notification settings | Up to 12 months |
| Analytics | Collect anonymised data on page views, navigation paths, and feature usage to improve the Platform | Up to 13 months |
| Fraud Prevention | Detect and flag suspicious access patterns, multiple-account attempts, and automated bot activity | Up to 6 months |
Strictly Necessary cookies cannot be disabled as they are essential for the Platform to function. You may manage Functional and Analytics cookies through your browser settings. Note that disabling certain cookies may limit your access to some Platform features.
jp369 does not deploy third-party advertising cookies or retargeting pixels. No cookie data is shared with ad networks or social media platforms for commercial targeting purposes.
Section 9 Data Retention
jp369 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. Our standard retention periods are as follows:
- Account Data: Retained for the duration of the Account relationship, plus a minimum of 5 years following Account closure to comply with anti-money-laundering record-keeping requirements;
- KYC Documents: Retained for a minimum of 5 years from the date of verification, or longer where required by applicable law;
- Financial Transaction Records: Retained for a minimum of 5 years from the date of the transaction;
- Customer Support Records: Retained for 2 years from the date of the last interaction, or longer where the record relates to an unresolved dispute or active investigation;
- Marketing Consent Records: Retained for the duration of your opt-in, plus 2 years after withdrawal of consent as evidence of lawful processing;
- Technical & Usage Logs: Retained for up to 13 months on a rolling basis, then anonymised or deleted.
Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised so that it can no longer be linked to an identified or identifiable individual.
Section 10 Security Measures
jp369 takes the security of your Personal Data seriously. We implement a layered set of technical and organisational controls designed to protect against unauthorised access, accidental loss, destruction, or alteration of your data. Our security programme includes:
- Transport Encryption: All data transmitted between your device and jp369 servers uses TLS 1.3 encryption, ensuring that data in transit cannot be intercepted by third parties;
- Encryption at Rest: Sensitive Personal Data stored on jp369 servers — including KYC documents, financial records, and Account credentials — is encrypted using AES-256 or equivalent standards;
- Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. Staff access is governed by role-based access controls, multi-factor authentication, and audit logging;
- Infrastructure Security: Platform infrastructure is hosted in secure data centres with physical access controls, redundant network architecture, and 24/7 monitoring;
- Vulnerability Management: jp369 conducts regular penetration testing, code security reviews, and vulnerability scans. Critical findings are remediated within defined SLA windows;
- Incident Response: jp369 maintains a documented data breach response procedure. In the event of a breach that poses a risk to your rights, we will notify affected Players and relevant authorities within the timeframes required by applicable law.
While jp369 applies rigorous security controls, no internet-based system can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials and for notifying us immediately if you suspect unauthorised access to your Account.
Section 11 Your Privacy Rights
As a Player, you have the following rights with respect to your Personal Data held by jp369. To exercise any of these rights, please contact us using the details in Section 15. We will respond to all verified requests within 14 business days.
Right of Access
Request a copy of all Personal Data jp369 holds about you, along with information on how it is processed.
Right to Rectification
Request correction of inaccurate or incomplete Personal Data held in your Account profile.
Right to Erasure
Request deletion of your Personal Data where it is no longer necessary for the purpose collected, subject to legal retention obligations.
Right to Restriction
Request that jp369 restrict processing of your Personal Data while a dispute or rectification request is being resolved.
Right to Portability
Receive a machine-readable copy of Personal Data you have provided to jp369 and transmit it to another controller.
Right to Object
Object to processing based on legitimate interest, including profiling and direct marketing communications.
Withdraw Consent
Withdraw previously given consent for marketing communications at any time without affecting prior lawful processing.
Right to Complain
Lodge a complaint with jp369's privacy team or with a competent data protection authority if you believe your rights have been infringed.
Some rights are subject to limitations. For example, we cannot erase Personal Data that we are legally required to retain for AML compliance purposes. Where we cannot fulfil a request in full, we will explain the specific reason in writing.
Section 12 Minors
21+ Only. The jp369 Platform is strictly for adults aged 21 and over. jp369 does not knowingly collect Personal Data from individuals under the age of 21. If we become aware that Personal Data has been collected from an underage individual, we will immediately suspend the associated Account, delete the data, and reverse any financial transactions where possible.
If you are a parent or guardian and believe that a minor has registered an Account on jp369 using false age information, please contact us immediately at the details provided in Section 15. We treat all underage access reports as a priority matter and will act within 24 hours of receiving a verified complaint.
jp369 uses mandatory KYC age verification as the primary control against underage access. No Account is permitted to make a first withdrawal without completing identity and age verification. Players found to be under 21 at the time of Account closure will have all deposited funds returned and all gameplay voided.
Section 13 Third-Party Links
The jp369 Platform may contain references to third-party content, including game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft), payment networks (Visa, Mastercard), and sports data providers. Where links to third-party platforms are present, jp369 does not control and is not responsible for the privacy practices of those third parties.
This Privacy Policy applies solely to data processed by jp369 in connection with the Platform. We encourage you to review the privacy policies of any third-party services you access independently. jp369 cannot be held liable for the data practices of third-party platforms or services.
Section 14 Policy Amendments
jp369 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or business operations. When we make material changes to this Policy, we will:
- Update the "Last Updated" date displayed at the top of this page;
- Notify registered Players by email to the address on record;
- Display a prominent notice on the Platform for a minimum of 14 days following the effective date of the change.
Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with a material change, you may close your Account by contacting our support team before the effective date, and your Real Money Balance will be returned to your registered payment method.
We recommend reviewing this Privacy Policy periodically. The version number and effective date at the top of this page identify the current version in force.
Section 15 Contact & Complaints
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your Personal Data by jp369, please contact our privacy team through the following channel:
Privacy & Data Enquiries: support@jp369.cam (plain text — not a clickable link)
Our privacy team is available 24 hours a day, 7 days a week, with native Indonesian-speaking agents on hand at all hours (WIB). We commit to acknowledging all privacy-related enquiries within 24 hours and providing a substantive response within 14 business days. Complex requests, such as Subject Access Requests involving large volumes of data, may require up to 30 days; we will notify you if an extension is required.
If you are not satisfied with jp369's response to a privacy complaint, you have the right to escalate your complaint to a competent data protection authority or supervisory body in your jurisdiction. jp369 will cooperate fully with any such authority in the resolution of a complaint.
For general account and support queries unrelated to privacy, please visit our FAQ page where many common questions are addressed, or refer to our Terms & Conditions for the full contractual framework governing use of the Platform.