Data Controller: pakjp1 ("the Platform", "We", "Us", "Our") acts as
the data controller for all personal data collected through https://pakjp1.cam.
This Privacy Policy describes how we collect, use, store, share, and protect your
personal information when you visit our website or use our services as a registered
Member. By creating a pakjp1 account, you confirm that you have read and accepted
the terms of this Privacy Policy.
1 Introduction
pakjp1 is committed to protecting the privacy and personal data of every individual
who visits or registers on our platform. We recognize that our Members — primarily
adult players based across Indonesia, from Jakarta, Surabaya, and Bandung to
Medan, Bali, and Makassar — place significant trust in us when they share their
personal information, and we take that responsibility seriously.
This Privacy Policy has been written in clear, plain English so that you can
understand precisely what data we collect, why we need it, how long we keep it,
and what choices you have in relation to it. This policy applies to all personal
data we process about visitors to https://pakjp1.cam and registered Members of
the pakjp1 platform.
This Privacy Policy should be read in conjunction with our
Terms & Conditions, which govern the overall
relationship between pakjp1 and its Members. In the event of a conflict between
the two documents, the Terms & Conditions shall prevail on matters relating to
the use of the Platform; this Privacy Policy shall prevail on matters relating
exclusively to personal data.
2 Definitions
The following terms carry specific meanings throughout this Privacy Policy:
"Personal Data"
Any information that identifies or could reasonably be used to identify a specific living individual, either on its own or in combination with other data — including name, email address, phone number, bank account number, and device identifiers.
"Processing"
Any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction — whether automated or manual.
"Data Controller"
The entity that determines the purposes and means of processing personal data. For data collected through pakjp1, the data controller is pakjp1.
"Data Processor"
A third-party entity that processes personal data on behalf of pakjp1 — for example, a KYC verification provider or payment gateway — under a binding data processing agreement.
"Member" / "You"
Any natural person who has registered an account on the pakjp1 platform and is subject to the Terms & Conditions and this Privacy Policy.
"Consent"
A freely given, specific, informed, and unambiguous indication of your wishes by which you agree to the processing of your personal
data for a stated purpose.
"KYC"
Know Your Customer — the identity verification process through which pakjp1 confirms a Member's identity, age, and residential address using official documentation such as a KTP, passport, or driver's license.
"Cookies"
Small text files placed on your device by the pakjp1 website that allow us to recognize your browser, maintain session state, and record preferences across visits.
3 Data We Collect
pakjp1 collects personal data from Members and site visitors through several
channels: directly from you when you register or interact with the Platform,
automatically through your use of the site, and from trusted third-party
service providers such as payment processors and KYC verification partners.
The categories of data we collect are set out below:
Registration Data
- Full legal name
- Date of birth
- Email address
- Mobile phone number
- Residential address
- Username and password (hashed)
KYC / Identity Data
- National ID (KTP) number and scan
- Passport or driver's license copy
- Proof of residential address
- Selfie / liveness check image
Financial Data
- Bank account name and number (BCA, BRI, BNI, Mandiri, etc.)
- E-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja)
- Deposit and withdrawal history
- Transaction timestamps and amounts in IDR
Gameplay Data
- Betting history and wager amounts
- Game sessions, win/loss records
- Bonus and promotion redemption records
- Self-exclusion and limit preferences
Technical Data
- IP address and approximate geolocation
- Device type, OS, and browser version
- Session start/end timestamps
- Referring URL and on-site navigation path
Communications Data
- Live chat transcripts
- Support email correspondence
- Complaint and dispute records
- Marketing opt-in / opt-out preferences
Sensitive Data: pakjp1 does not intentionally collect sensitive
categories of personal data such as racial origin, religious beliefs, political
opinions, or health information. If any such data is incidentally disclosed
during support communications, it will not be processed for any purpose other
than resolving the specific support matter at hand.
4 How We Use Your Data
pakjp1 processes personal data only for specific, legitimate purposes.
We do not process your data beyond the scope of what is described below:
- Account Management: To create, maintain, and administer your pakjp1 Member account, verify your identity, and communicate account-related updates.
- Service Delivery: To process deposits and withdrawals in IDR via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, and other supported channels; to credit winnings; and to manage bonus and promotional allocations.
- KYC & Compliance: To verify your age (21+), identity, and residential address in accordance with our legal obligations under applicable anti-money laundering (AML) and know-your-customer (KYC) requirements.
- Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, account takeovers, bonus abuse, money laundering, and other irregular activity that could harm Members or the Platform.
- Responsible Gaming: To monitor gameplay patterns for signs of problem gambling, to apply deposit limits and self-exclusion settings, and to provide timely interventions where appropriate.
- Customer Support: To respond to queries, complaints, and disputes submitted through our support channels at [email protected] and to improve the quality of our support service.
- Platform Improvement: To analyze aggregated, anonymized usage data for the purposes of improving site performance, user experience, and product offerings.
- Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications. You may withdraw your consent at any time.
- Legal Obligations: To comply with applicable laws, respond to lawful requests from regulatory or law-enforcement authorities, and defend pakjp1's legal rights in disputes.
5 Legal Basis for Processing
For each processing activity, pakjp1 relies on one or more of the following
legal bases:
- Contract Performance: Processing necessary to fulfill the agreement between pakjp1 and the Member — including account operation, payment processing, and service delivery.
- Legal Obligation: Processing required to comply with applicable laws, including AML/KYC regulations, tax reporting obligations, and cooperation with competent authorities.
- Legitimate Interests: Processing carried out for pakjp1's legitimate business interests — such as fraud detection, platform security, and service improvement — where those interests are not overridden by your fundamental rights and freedoms.
- Consent: Processing for which you have given clear, affirmative consent — primarily marketing communications. Where consent is the legal basis, you retain the right to withdraw it at any time without consequence to your account or other services.
6 Data Disclosure & Third-Party Sharing
pakjp1 does not sell your personal data to third parties. We may share your
data with the following categories of recipients, strictly on a need-to-know
basis and subject to binding confidentiality and data processing obligations:
- Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum personal and financial data necessary to process your transactions.
- KYC Verification Partners: Third-party identity verification services receive your identity documents solely for the purpose of confirming your name, age, and address. These providers operate under strict data processing agreements and are prohibited from using your data for any other purpose.
- IT Infrastructure & Security Providers: Cloud hosting, data storage, DDoS protection, and cybersecurity service providers who maintain the technical infrastructure on which pakjp1 operates. All such providers are contractually bound to process data only on pakjp1's documented instructions.
- Game Content Providers: Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive anonymized session identifiers necessary for game delivery. These providers do not receive your personally identifiable information (PII) unless required for jackpot verification purposes.
- Regulatory & Law Enforcement Authorities: pakjp1 will disclose personal data to competent authorities — including financial intelligence units, tax authorities, or law enforcement — when legally required to do so by a court order, statutory obligation, or binding regulatory directive. We will notify affected Members of any such disclosure to the extent permitted by law.
- Professional Advisors: Legal counsel, auditors, and compliance consultants who require access to relevant data in order to provide professional services to pakjp1, subject to professional confidentiality obligations.
No Cross-Border Sale of Data: pakjp1 does not transfer or sell
your personal data to data brokers, advertising networks, or any unaffiliated
commercial third parties for marketing or profiling purposes. Data shared with
service providers named above is used exclusively to deliver services to you
or to fulfill legal obligations.
7 Cookies & Tracking Technologies
pakjp1 uses cookies and similar technologies to ensure the Platform functions
correctly, to protect your session, and to gather anonymized analytics that
help us improve the player experience. We do not use advertising cookies from
third-party ad networks.
The cookies we use fall into the following categories:
- Strictly Necessary Cookies: Essential for the Platform to operate. These include session authentication tokens, CSRF protection cookies, and load-balancing identifiers. They cannot be disabled without breaking core functionality such as login and payment flows.
- Functional Cookies: Used to remember your preferences, such as language settings, notification preferences, and responsible gaming tool configurations. Disabling these cookies may reduce platform usability.
- Analytics Cookies: Anonymized data on how visitors navigate the Platform — page views, session duration, click paths — collected to improve site performance. These cookies do not contain personally identifiable information.
- Security Cookies: Used to detect and prevent fraudulent logins, unusual geographic access patterns, and automated bot activity targeting Member accounts.
You can manage cookie preferences through your browser settings. Most modern
browsers allow you to block or delete cookies; however, disabling strictly
necessary cookies will prevent you from logging in or using core features of
the pakjp1 Platform. Detailed browser-specific instructions are available in
your browser's help documentation.
8 Data Security
pakjp1 implements a comprehensive set of technical and organizational measures
to protect your personal data against unauthorized access, accidental loss,
alteration, disclosure, or destruction. These measures include:
- 128-bit SSL/TLS Encryption: All data in transit between your browser and our servers is encrypted using industry-standard TLS protocols. Our SSL certificate is kept current and monitored for expiry.
- Encrypted Storage: Sensitive data at rest — including KYC documents, bank account details, and password hashes — is stored using strong encryption with keys managed through a dedicated secrets management system.
- Access Controls: Access to personal data is granted on a strict need-to-know basis. All staff access to production data is role-controlled, logged, and subject to quarterly access reviews.
- Two-Factor Authentication (2FA): Members are encouraged to enable 2FA on their pakjp1 accounts. 2FA is mandatory for all internal staff accounts with access to Member data.
- Security Monitoring: Our systems are monitored 24/7 for anomalous access patterns, brute-force login attempts, and data exfiltration indicators. Automated alerts trigger immediate investigation procedures.
- Penetration Testing: pakjp1 engages independent security firms to conduct periodic penetration tests and vulnerability assessments of our infrastructure.
Data Breach Notification: In the unlikely event of a personal data
breach that poses a significant risk to your rights and freedoms, pakjp1 will notify
affected Members without undue delay and, at most, within 72 hours of becoming aware
of the breach. Notification will be sent to the email address registered on your
account and will describe the nature of the breach, the data involved, and steps
taken to mitigate any harm.
9 Data Retention
pakjp1 retains personal data only for as long as is necessary to fulfill the
purpose for which it was collected, or as required by applicable law and
regulatory obligations. The following retention periods apply:
- Active Account Data: Retained for the duration of your membership plus a minimum of 5 years following account closure, in accordance with international AML record-keeping standards.
- KYC Documents: Retained for a minimum of 5 years from the date of verification or account closure, whichever is later, to satisfy financial crime prevention obligations.
- Transaction Records: Financial transaction records (deposits, withdrawals, wagers) are retained for a minimum of 5 years following the date of each transaction.
- Support Communications: Customer support correspondence is retained for 3 years following the resolution of the relevant query or complaint.
- Marketing Preferences: Records of marketing consent and opt-out requests are retained for the duration of your membership and for 2 years following account closure to demonstrate compliance.
- Technical / Analytics Data: Anonymized analytics data may be retained indefinitely as it no longer constitutes personal data. IP address logs are retained for a maximum of 12 months.
When personal data is no longer required and no legal retention obligation applies,
pakjp1 will securely delete or anonymize it in accordance with our internal
data disposal procedures.
10 Your Data Rights
As a pakjp1 Member, you hold the following rights in relation to your personal
data. These rights may be exercised by submitting a written request to
[email protected]. pakjp1 will respond to all verified data rights requests
within 30 calendar days.
Right of Access
Request a copy of all personal data pakjp1 holds about you, including the categories of data, how it is used, and who it has been shared with.
Right to Rectification
Request correction of inaccurate or incomplete personal data held in your pakjp1 account. You may also update core account details directly via your account settings.
Right to Erasure
Request deletion of your personal data where processing is no longer necessary and no legal retention obligation requires us to keep it. This right is subject to regulatory exceptions.
Right to Object
Object to processing based on legitimate interests — including profiling for responsible gaming purposes — where you have grounds relating to your particular situation.
Right to Restriction
Request that processing of your data be restricted — for example, while a dispute over accuracy is being resolved — so that it is stored but not actively used.
Right to Portability
Receive your personal data in a structured, machine-readable format where processing is based on consent or contract, and the processing is carried out by automated means.
How to Exercise Your Rights: Submit your request in writing to
[email protected] with the subject line
"Data Rights Request". We may ask you to verify your identity before processing
the request. pakjp1 does not charge a fee for standard data rights requests.
11 International Data Transfers
pakjp1 primarily processes and stores Member data within server infrastructure
located in Asia-Pacific regions. Where data is processed by a third-party service
provider outside this region, pakjp1 ensures that appropriate safeguards are in
place to protect your personal data to a standard at least equivalent to that
described in this Privacy Policy.
Such safeguards may include contractual clauses requiring the recipient to apply
equivalent data protection standards, the use of service providers that maintain
recognized international security certifications (such as ISO 27001), or transfers
to jurisdictions that have been assessed as providing an adequate level of data
protection by relevant authorities.
If you would like further information about the specific safeguards applied to
any international transfer of your personal data, please contact us at
[email protected].
12 Children's Privacy
The pakjp1 Platform is strictly intended for adults aged 21 and over. We do
not knowingly collect or process personal data from individuals under the age
of 21. Registration by any person under 21 years of age is a violation of our
Terms & Conditions and this Privacy Policy.
If we become aware that a registered Member is under the age of 21, we will
immediately suspend the account, void any associated wagers or winnings, return
any verified net deposit to the originating payment method, and permanently
delete all personal data associated with the underage account from our active
systems, subject to any legal data retention obligations.
If you are a parent or guardian and have reason to believe that a minor in your
care has registered on pakjp1, please contact us immediately at
[email protected] so that we can take prompt action. We encourage parents and
guardians to make use of parental controls and filtering software to prevent
minors from accessing online gambling platforms.
13 Amendments to This Policy
pakjp1 reserves the right to update or amend this Privacy Policy at any time
to reflect changes in our data practices, applicable law, or operational
requirements. When material changes are made, we will notify registered Members
by email and by posting a prominent notice on the Platform at least 7 days
before the changes take effect.
The "Last Updated" date at the top of this page indicates when the most recent
revision was made. Continued use of the pakjp1 Platform after the effective
date of any amendment constitutes your acceptance of the revised Privacy Policy.
If you disagree with any change, you may request account closure in accordance
with Section 11 of our Terms & Conditions before the new policy takes effect.
We encourage you to review this Privacy Policy periodically to remain informed
about how pakjp1 protects your personal data. Prior versions of this policy
are available on request by contacting [email protected].