Privacy Policy — pakjp1

pakjp1 is committed to protecting the privacy and personal data of every Member who uses our platform. We understand that entrusting us with your personal information — including financial details and identity documents — requires a high standard of responsibility on our part. This Policy sets out in plain, professional English exactly what data we hold, why we hold it, how long we keep it, who we may share it with, and how you can exercise control over it at any time.

This Policy is incorporated by reference into the pakjp1 Terms & Conditions. Where any conflict exists between this Policy and the Terms & Conditions on a data-related matter, this Policy shall take precedence. Both documents together form the complete agreement governing your relationship with pakjp1.

Our Platform is directed exclusively at adults aged 21 and above who are residents of Indonesia. We do not knowingly collect personal data from individuals under 21 years of age. If you believe that a minor has provided us with personal data, please contact us immediately at [email protected] (plain text — not a clickable link).

The following definitions apply throughout this Policy:

• "Account" — the personal account created by a Member on the Platform to access pakjp1 services.
• "Company" — pakjp1, the operator of the Platform, acting as data controller in respect of personal data collected through the Platform.
• "Cookie" — a small text file placed on your device by the Platform to enable session management, analytics, and personalization features.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. pakjp1 is the Data Controller for data collected via the Platform.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller under a written data-processing agreement.
• "KYC" — Know Your Customer, the identity and age-verification process required before a Member may withdraw funds or access certain Platform features.
• "Personal Data" — any information that identifies or can be used to identify a natural person, directly or indirectly, including name, date of birth, national identity number, email address, phone number, IP address, device identifiers, and financial account details.
• "Platform" — the website at https://pakjp1.net, any associated subdomains, mobile web interfaces, and any downloadable application operated by the Company.
• "Processing" — any operation or set of operations performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, and deletion.
• "Special Category Data" — sensitive personal data including health information, biometric data, or data revealing racial or ethnic origin. pakjp1 does not intentionally collect Special Category Data unless strictly required for regulatory compliance.

pakjp1 collects the following categories of personal data, depending on the nature of your interaction with the Platform:

We collect personal data through the following channels:

• Direct collection: Data you provide when registering an Account, submitting KYC documents, making deposits or withdrawals, contacting our support team, or completing any form on the Platform.
• Automated collection: Technical and usage data collected automatically when you access the Platform via browser cookies, server logs, session tracking scripts, and analytics tools. See Clause 11 (Cookies & Tracking) for full details.
• Third-party payment processors: When you initiate a deposit or withdrawal via a local bank (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) or an e-wallet (OVO, DANA, GoPay, ShopeePay, LinkAja), the processor may share transaction confirmation data including your registered name and account reference with us for reconciliation and fraud prevention purposes.
• Identity verification providers: During KYC, we may engage a certified identity verification partner to validate the authenticity of documents you submit. That partner processes your data under a written data-processing agreement with pakjp1 and is not permitted to retain or use your data for any other purpose.
• Fraud prevention and risk management services: We may receive data from fraud-detection platforms and anti-money-laundering (AML) screening services to cross-reference your registration details against watchlists and sanctions databases.

pakjp1 processes your personal data only for the following defined purposes:

1. Account Management: Creating, maintaining, and closing your Member Account; verifying your identity and age (21+ compliance); enabling login and session management.
2. Transaction Processing: Processing deposits from and withdrawals to your verified Indonesian bank account or e-wallet; reconciling transaction records; issuing receipts.
3. KYC & Regulatory Compliance: Conducting identity verification, age verification, source-of-funds checks, and AML screening as required under our international compliance obligations.
4. Customer Support: Responding to your support requests, resolving disputes, investigating complaints, and communicating account-related notifications.
5. Fraud Prevention & Security: Detecting, investigating, and preventing unauthorized Account access, bonus abuse, duplicate accounts, payment fraud, and other prohibited conduct described in our Terms & Conditions.
6. Platform Improvement: Analyzing aggregated usage data to understand how Members interact with the Platform, identify bugs, improve game performance, and enhance the user experience.
7. Responsible Gaming: Monitoring betting patterns to identify signs of problem gambling; enforcing self-exclusion and deposit limits set by Members; sending responsible gaming notifications where triggered by our monitoring systems.
8. Marketing & Promotions (with consent): Sending promotional emails, SMS, or in-app notifications about bonuses, seasonal campaigns, and new product releases — only to Members who have explicitly opted in to receive such communications. You may withdraw consent at any time via your Account settings.
9. Legal Obligations: Retaining records as required by applicable AML, financial services, and data-retention regulations; responding to lawful requests from law enforcement or regulatory bodies.

pakjp1 processes your personal data on the following legal bases:

• Contractual necessity: Processing that is required to perform the contract between you and pakjp1 — including Account creation, deposit processing, wager settlement, and withdrawal execution. Without this processing, we cannot provide the service.
• Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC identity verification, AML record-keeping, and responses to lawful authority requests.
• Legitimate interests: Processing carried out to pursue our legitimate business interests — including fraud prevention, platform security, dispute resolution, and aggregate analytics — where those interests are not overridden by your rights and freedoms.
• Consent: Processing for optional purposes such as marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal. Withdrawing marketing consent does not affect your ability to use the Platform.

pakjp1 does not sell your personal data. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment processors: Local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum data required to execute your deposit or withdrawal transaction.
• Identity verification partners: Certified KYC and liveness-check providers receive your submitted identity documents and selfie media solely for the purpose of verification. These partners are bound by data-processing agreements that prohibit secondary use of your data.
• Game studio providers: When you launch a game from a third-party studio — such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Pocket Games Soft — a session token and your Account balance are passed to the game server. These studios do not receive your full identity or financial data; they receive only the session and stake data necessary to run the game.
• Fraud and AML screening services: Your name, date of birth, and account reference may be checked against international sanctions lists, PEP databases, and fraud watchlists via specialist screening providers.
• Legal and regulatory authorities: We may disclose personal data to Indonesian or international law enforcement agencies, financial intelligence units, or courts when we receive a lawful request or when we determine in good faith that disclosure is necessary to prevent fraud, protect our rights, or comply with a legal obligation. Where permitted, we will notify you of such a request.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all assets of the Company, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations. You will be notified in advance of any such transfer.

pakjp1 operates as an international platform. Some of the third-party service providers described in Clause 7 — including game studios, cloud infrastructure providers, and KYC verification partners — may process your data in countries outside Indonesia. Where personal data is transferred outside Indonesia, pakjp1 takes the following safeguards:

• Data is transferred only to countries or organizations that maintain adequate data protection standards recognized by the Company's compliance framework.
• Where an adequate protection standard cannot be presumed, we implement standard contractual clauses or equivalent safeguards in the data-processing agreements with our service providers.
• Personal data transferred internationally is subject to the same access controls, encryption standards, and retention policies as data processed within Indonesia.

By creating an Account and using the Platform, you acknowledge and consent to the international transfer of your personal data as described in this clause, subject always to the safeguards stated above.

pakjp1 retains personal data only for as long as necessary to fulfill the purposes set out in this Policy or as required by applicable law. The following retention schedule applies:

After the applicable retention period expires, personal data is securely deleted or permanently anonymized so that it can no longer be associated with any identifiable individual. Anonymized aggregate data may be retained indefinitely for statistical and analytical purposes.

pakjp1 implements a layered security architecture to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our key security measures include:

• TLS/SSL Encryption: All data transmitted between your browser or device and our servers is encrypted using TLS 1.2 or higher. HTTPS is enforced across the entire Platform with no HTTP fallback.
• AES-256 Encryption at Rest: Personal data and financial records stored on our servers are encrypted at rest using AES-256 symmetric encryption. Encryption keys are managed through a dedicated key management service with access logging.
• Access Controls: Sensitive personal data is accessible only to authorized pakjp1 personnel with a verified business need. All internal access is logged, and access rights are reviewed quarterly. Staff with access to KYC documents are subject to background checks.
• Two-Factor Authentication: Internal administrative systems that access Member data require two-factor authentication (2FA) for all staff logins. We also encourage Members to enable 2FA on their own Accounts for additional security.
• Penetration Testing & Vulnerability Scanning: Our Platform undergoes regular third-party penetration testing and automated vulnerability scanning. Critical findings are remediated within defined SLA windows.
• Incident Response Plan: In the event of a personal data breach that is likely to result in a risk to your rights or freedoms, pakjp1 will notify affected Members and relevant authorities within the timeframes required by applicable regulations. Notification will be sent to the email address registered on your Account.

pakjp1 uses cookies and similar tracking technologies to provide essential Platform functionality and to improve your experience. The following categories of cookies are used:

You can manage your cookie preferences at any time via your browser settings or within your pakjp1 Account settings panel. Disabling strictly necessary cookies will prevent you from logging in or using core Platform features. Disabling analytics or marketing cookies will not affect your ability to place wagers or access games.

As a Member of pakjp1, you have the following rights over your personal data. To exercise any of these rights, contact our support team via live chat or email at [email protected] (plain text — not a clickable link). We will respond within 30 calendar days of receiving your request.

• Right of Access: You may request a copy of all personal data we hold about you. We will provide this in a structured, commonly used, machine-readable format (e.g., PDF or CSV) free of charge for one request per 12-month period.
• Right of Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You may also update most contact details directly via your Account profile page.
• Right of Erasure ("Right to be Forgotten"): You may request deletion of your personal data. We will comply with erasure requests unless we are required to retain the data to comply with a legal obligation (such as AML record-keeping requirements under applicable financial services regulations), to defend legal claims, or to enforce our Terms & Conditions.
• Right to Restrict Processing: You may request that we pause our use of your personal data while a correction request or objection is under review, or where you believe our processing is unlawful but prefer restriction over erasure.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you may request that we transfer your data directly to another service provider in a structured, machine-readable format, where technically feasible.
• Right to Object: You may object to processing carried out on the basis of legitimate interests (Clause 6). We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, or where processing is necessary for legal claims.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications, non-essential cookies), you may withdraw consent at any time without affecting the lawfulness of prior processing. Withdrawal of consent does not affect your Account access or wagering rights.

The Platform is strictly for adults aged 21 years and above. pakjp1 does not knowingly collect, process, or retain personal data from individuals under the age of 21. Our registration and KYC processes include age-verification steps specifically designed to prevent underage access.

If we become aware that personal data has been submitted by a person under 21 years of age — whether through a registration attempt, a support contact, or a KYC submission — we will:

• Immediately suspend or decline the Account in question.
• Delete all personal data associated with the underage individual as promptly as technically possible, subject only to any legal obligation to retain evidence of the incident.
• Return any funds deposited by an underage user to the originating payment method after deducting any wager amounts placed, and withhold all winnings.

If you are a parent or guardian and have reason to believe that a minor in your care has accessed the Platform, please contact our support team immediately. We take underage gambling extremely seriously and will act on all such reports with urgency.

The Platform integrates with third-party game studio servers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft, and others) to deliver game content. When you launch a game from one of these studios, your device communicates directly with the studio's game server. pakjp1 passes only the minimum data necessary — a session token and your current in-game balance — and does not transmit your full identity or financial details to game studios.

The Platform may display informational content that references third-party services such as BCA, BRI, BNI, Mandiri, OVO, DANA, or GoPay in a payment-method context. These references are for Member guidance only; pakjp1 is not responsible for the privacy practices of these third-party financial institutions. Their collection and use of your data during deposit or withdrawal transactions is governed by their own privacy policies.

This Privacy Policy applies solely to the pakjp1 Platform. It does not cover any third-party website, application, or service that you access independently of pakjp1, even if you arrive there via a link on our Platform.

pakjp1 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. When material changes are made, we will:

• Update the "Effective Date" and "Last Reviewed" date shown at the top of this page.
• Display a prominent notice on the Platform homepage and within the Member Account dashboard for a minimum of 14 days following publication of the updated Policy.
• Send an email notification to the address registered on your Account where the changes materially affect your rights or how we handle your personal data.

Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with the revised Policy, you must cease using the Platform and close your Account before the effective date. The current version of this Policy is always available at https://pakjp1.net/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or our handling of your personal data, please contact the pakjp1 Data Protection team through any of the following channels:

• Live Chat: Available 24/7 via the in-app chat widget after logging in to your pakjp1 Account. For privacy-related requests, please include "Privacy Request" in your opening message so the conversation is routed to our data protection team. Average response: 5–10 minutes.
• Email: [email protected] (plain text — not a clickable link). Please use the subject line "Privacy Policy Request — [Your Username]" for faster routing. We respond to privacy requests within 5 business days and fulfill them within 30 calendar days.

For formal data subject access requests, erasure requests, or complaints relating to data processing, please contact us in writing (via email as above) with your full name, registered email address, and a description of your request or complaint. We will acknowledge receipt within 3 business days and provide a substantive response within 30 calendar days, as required under applicable data protection frameworks.