Privacy Policy

1. Definitions

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, identification number, location data, email address, financial account details, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" means pjs138, the entity that determines the purposes and means of processing Personal Data collected through the platform.
• "Data Processor" means any third-party entity that processes Personal Data on behalf of pjs138 under a contractual data processing agreement.
• "Data Subject" means the individual whose Personal Data is being collected and processed — in this context, registered Players and website visitors.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the Data Subject's agreement to the processing of their Personal Data.
• "Cookie" means a small text file placed on your device by our web server to enable core platform functionality, analytics, and personalization features.
• "KYC" means Know Your Customer — the mandatory identity and age verification process required for Account registration and financial transactions on pjs138.

2. Data Controller

pjs138, operated at pjs138.cam, acts as the Data Controller for all Personal Data collected through its platform, website, mobile interfaces, customer support channels, and marketing communications. All requests relating to data access, rectification, erasure, or portability should be directed to our Data Protection team using the contact details provided in Section 14 of this policy.

pjs138 is licensed and regulated internationally. Our platform is designed and operated with Indonesian players as the primary audience, and we maintain data handling practices consistent with internationally recognized privacy standards, including principles derived from the General Data Protection Regulation (GDPR) framework and Indonesia's applicable personal data protection regulations.

3. Personal Data We Collect

pjs138 collects the following categories of Personal Data in the course of providing its Services to registered Players and website visitors:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identity document (KTP or passport)
• Date of birth and confirmed age
• Registered email address and mobile phone number
• Residential address in Indonesia
• Copies of identity verification documents submitted during KYC
• Selfie photographs submitted for facial verification where required

3.2 Financial Data

• Bank account details (account number, bank name — BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, or others) registered to your Account
• E-wallet account identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method used
• Bonus claim history and wagering activity records

3.3 Technical and Usage Data

• IP address, device type, operating system, and browser type and version
• Session login timestamps, session duration, and logout records
• Pages visited, features accessed, and games played within the platform
• Geolocation data (city and country level) derived from IP address
• Referral source and marketing campaign attribution data

3.4 Communications Data

• Records of all live chat conversations, email correspondence, and support ticket interactions with pjs138 customer service
• Feedback, complaints, and dispute records submitted through any channel
• Marketing communication preferences and opt-in or opt-out records

3.5 Responsible Gaming Data

• Self-exclusion requests and their effective dates
• Deposit limit, loss limit, and session time limit settings configured by the Player
• Problem gambling self-assessment responses where voluntarily submitted

4. How We Collect Your Data

pjs138 collects Personal Data through the following channels and mechanisms:

• Account Registration: Data you provide directly when creating your pjs138 Account, including name, date of birth, email address, and payment method details.
• KYC Verification: Identity documents and supporting materials you submit in response to our verification requests.
• Transactional Activity: Financial data generated automatically when you make deposits, place bets, or request withdrawals through any supported payment method.
• Platform Usage: Technical data collected automatically through server logs, cookies, and analytics tools as you navigate the pjs138 platform.
• Customer Support: Information you provide voluntarily when contacting our support team via live chat, email, or WhatsApp.
• Marketing Interactions: Data collected when you open, click, or respond to pjs138 promotional emails or push notifications.
• Third-Party Sources: In limited circumstances, pjs138 may receive data from fraud prevention agencies, payment processors, or identity verification partners to supplement information already held in your Account profile.

5. Purpose and Legal Basis for Processing

pjs138 processes Personal Data only for specified, explicit, and legitimate purposes. The table below summarizes our primary processing activities and the legal basis applied to each:

6. Data Sharing and Third-Party Disclosure

pjs138 does not sell, rent, or trade your Personal Data to any third party for their independent marketing purposes. We share Personal Data only in the following defined circumstances:

6.1 Payment Processing Partners

We share the minimum necessary financial data with our payment processing partners — including Indonesian bank networks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) — to facilitate deposits and withdrawals from your Account. These partners are bound by their own privacy policies and applicable banking regulations.

6.2 Identity Verification Providers

KYC documentation may be shared with certified third-party identity verification services to confirm the authenticity of documents and perform age verification checks. These providers process data solely on our behalf under strict data processing agreements.

6.3 Game Software Providers

To enable game functionality, limited technical session data (such as a pseudonymous player identifier and bet amounts) may be transmitted to our game software providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. These providers do not receive your full identity or financial details.

6.4 Fraud Prevention and Security Agencies

pjs138 works with specialized fraud prevention and cybersecurity partners. Data may be shared with these agencies to screen for fraudulent activity, detect multi-accounting, and prevent money laundering. Where required, suspicious activity may be reported to relevant regulatory or law enforcement authorities.

6.5 Legal and Regulatory Obligations

We may disclose Personal Data to courts, regulators, law enforcement agencies, or government bodies where we are required to do so by law, court order, or regulatory directive. We will notify you of such disclosures where legally permitted to do so.

7. Cookies and Tracking Technologies

pjs138 uses cookies and similar tracking technologies to ensure the proper functioning of the platform, analyze usage patterns, and deliver relevant content to returning visitors. The following categories of cookies are deployed on pjs138.cam:

7.1 Strictly Necessary Cookies

These cookies are essential for the platform to operate and cannot be disabled. They include session cookies that maintain your login state, security tokens that protect against cross-site request forgery (CSRF), and cookies that remember your language and display preferences. No Personal Data is collected or stored through strictly necessary cookies beyond what is required for platform functionality.

7.2 Analytics Cookies

We use analytics cookies to understand how visitors navigate the platform — which pages are most popular, how long sessions last, and where users encounter friction in the registration or deposit flow. This data is aggregated and does not identify you personally. Analytics data helps us continuously improve the pjs138 experience for Indonesian players.

7.3 Functional Cookies

Functional cookies remember your preferences across sessions — such as your preferred deposit method, table game settings, or notification preferences. Disabling these cookies will not prevent access to the platform but will result in a less personalized experience.

7.4 Marketing Cookies

Where you have given explicit consent to receive marketing communications, we may use marketing cookies to attribute your registration or deposit to a specific campaign, measure conversion rates, and ensure that promotional messages are relevant to your demonstrated interests. You may withdraw consent for marketing cookies at any time through your Account settings.

You can manage cookie preferences through your browser settings. Note that blocking essential cookies will impair platform functionality and may prevent you from logging in or completing fina ncial transactions.

8. Data Retention

pjs138 retains Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your active Account plus a minimum of five (5) years following Account closure, to comply with anti-money laundering record-keeping obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with applicable financial reporting and AML compliance requirements.
• KYC Documentation: Retained for five (5) years from the date of submission or Account closure, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless the records relate to an unresolved dispute, in which case they are retained until the dispute is fully resolved.
• Marketing Preference Records: Retained for as long as your Account is active and for two (2) years following Account closure or opt-out, whichever occurs first.
• Technical and Usage Logs: Retained for twelve (12) months on a rolling basis, after which aggregated and anonymized analytics data may be retained indefinitely for platform improvement purposes.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized so that it can no longer be associated with any identifiable individual.

9. Data Security

pjs138 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and pjs138's servers is encrypted using industry-standard Transport Layer Security (TLS) protocols, ensuring that your credentials, financial details, and personal information cannot be intercepted in transit.
• Encrypted Data Storage: Personal Data and financial records stored on pjs138 servers are encrypted at rest using AES-256 encryption. Encryption keys are managed through a dedicated key management system with strict access controls.
• Access Controls and Role-Based Permissions: Access to Personal Data within pjs138 is restricted to authorized personnel on a strict need-to-know basis. All staff with access to player data undergo regular security training and are bound by confidentiality obligations.
• Two-Factor Authentication: Players are strongly encouraged to enable two-factor authentication (2FA) on their Accounts. 2FA is mandatory for all internal staff accounts with access to player data systems.
• Regular Security Audits: pjs138 conducts periodic penetration testing and vulnerability assessments conducted by independent third-party security specialists to identify and remediate potential weaknesses before they can be exploited.
• Incident Response Protocol: In the event of a confirmed data breach that poses a risk to affected individuals, pjs138 will notify impacted Players without undue delay and, where required, report the breach to the relevant supervisory authority within the timeframe prescribed by applicable law.

10. Your Rights as a Data Subject

As a registered Player and Data Subject, you hold the following rights in respect of your Personal Data held by pjs138. To exercise any of these rights, please contact our Data Protection team using the details in Section 14.

10.1 Right of Access

You have the right to request a copy of all Personal Data that pjs138 holds about you, along with information about how it is being processed. We will respond to verified access requests within thirty (30) days of receipt.

10.2 Right to Rectification

If any Personal Data we hold about you is inaccurate, incomplete, or out of date, you have the right to request that it be corrected. You may also update certain Account details directly through your Account settings dashboard without needing to contact support.

10.3 Right to Erasure

You may request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been processed unlawfully. Please note that this right is subject to our legal obligations to retain certain data — for example, AML regulations require us to retain financial records for a minimum of five years, and this obligation takes precedence over an erasure request.

10.4 Right to Restriction of Processing

You may request that we restrict the processing of your Personal Data in certain circumstances — for example, while the accuracy of data is being contested, or while an objection to processing is being assessed. Restricted data will be stored but not actively processed.

10.5 Right to Data Portability

Where processing is based on your consent or a contractual obligation and is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format, and to request that it be transmitted directly to another controller where technically feasible.

10.6 Right to Object

You have the right to object to processing of your Personal Data where that processing is based on legitimate interest. You also have an unconditional right to object to the use of your data for direct marketing purposes at any time, which we will honor immediately upon receipt of your request.

10.7 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal. To withdraw marketing consent, update your preferences in your Account settings or contact our support team.

11. Protection of Minors

pjs138 does not knowingly collect Personal Data from individuals under the age of 21. Our platform is strictly intended for adults aged 21 and above. We employ multiple layers of age verification during Account registration, including KYC document checks that confirm date of birth against a government-issued identity document.

If pjs138 discovers or has reasonable grounds to believe that Personal Data has been collected from a person under the age of 21, we will take immediate action to suspend the associated Account, delete the collected data to the extent permitted by our legal obligations, and where appropriate, notify relevant authorities. Parents or guardians who believe their child may have registered an Account on pjs138 are encouraged to contact our support team immediately.

12. International Data Transfers

pjs138 operates as an internationally licensed platform, and certain data processing activities may involve the transfer of Personal Data to servers or processors located outside of Indonesia. Such transfers may occur in connection with cloud hosting infrastructure, game software providers, payment processing networks, or fraud prevention services that operate globally.

Where Personal Data is transferred internationally, pjs138 ensures that appropriate safeguards are in place to protect the data to a standard at least equivalent to that applied within Indonesia. These safeguards may include contractual clauses modeled on internationally recognized standard contractual clauses, binding corporate rules where applicable, or transfers to jurisdictions that have been assessed as providing an adequate level of data protection.

By using the pjs138 platform and providing your Personal Data, you acknowledge and consent to the possibility that your data may be processed in countries outside Indonesia, subject always to the protections described in this Privacy Policy.

13. Changes to This Privacy Policy

pjs138 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or the Services we offer. When material changes are made, we will notify registered Players by email to the address associated with their Account and display a prominent notice on the pjs138 platform no less than seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect when the most recent revision was published. We encourage you to review this Privacy Policy periodically to stay informed about how pjs138 protects your Personal Data. Your continued use of the platform following the effective date of any revision constitutes your acceptance of the updated policy.

14. Contact Our Data Protection Team

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by pjs138, please reach out to our dedicated Data Protection team through the following channels. All privacy-related requests are treated with strict confidentiality and handled by our trained data protection personnel.

• Email: [email protected] — please use the subject line "Privacy Request" for all data-related inquiries; response within 24–48 hours
• Live Chat: Available 24/7 via the chat widget on pjs138.cam — identify yourself as submitting a privacy or data request at the start of the conversation
• WhatsApp: +62 812-3456-7890 (plain text — not a clickable link; available 24/7 in both English and Indonesian)

We will acknowledge all formally submitted data rights requests within five (5) business days and aim to resolve them fully within thirty (30) calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.