Privacy Policy

1. Information We Collect

rjs138 collects several categories of personal information necessary to provide our gaming services, ensure platform security, comply with legal obligations, and enhance user experience. The information we collect includes:

1.1 Information You Provide Directly

• Account Registration Data: When you create an account, we collect your full legal name, date of birth, email address, mobile phone number, residential address, username, and password. This information is mandatory for account creation and age verification (minimum 21 years old).
• Identity Verification Documents (KYC): To comply with Know Your Customer (KYC) regulations and prevent fraud, we collect copies of your Indonesian National Identity Card (KTP Nasional), selfie photographs holding your ID, and proof of address documents (utility bills, bank statements, or government correspondence). This information verifies your identity and prevents underage gambling, money laundering, and account fraud.
• Financial Information: We collect bank account details (account holder name, bank name, account number) and e-wallet information (OVO, DANA, GoPay, ShopeePay, LinkAja account identifiers) for processing deposits and withdrawals. Payment card details, if used, are processed through PCI-DSS compliant third-party payment gateways; we do not store full card numbers on our servers.
• Communication Records: When you contact customer support via email ([email protected]), live chat, or WhatsApp, we retain records of your communications, including your inquiries, complaints, feedback, and our responses. This helps us resolve issues efficiently and improve service quality.
• Gaming Preferences and History: We record your gaming activity, including games played, bets placed, winnings, losses, bonuses claimed, and transaction history. This data enables us to provide personalized recommendations, detect fraudulent patterns, and comply with regulatory reporting requirements.

1.2 Information Collected Automatically

• Device and Technical Data: We automatically collect information about the device you use to access rjs138, including IP address, device type, operating system, browser type and version, screen resolution, time zone settings, and unique device identifiers. This technical data helps us optimize platform performance, detect unauthorized access, and prevent fraud.
• Usage Data and Analytics: We track how you interact with our Platform, including pages visited, features used, time spent on each page, click patterns, navigation paths, and session duration. This behavioral data helps us understand user preferences, identify technical issues, and improve website functionality.
• Location Data: We collect your approximate geographic location based on your IP address to verify that you are accessing the Platform from within Indonesian territory, as required by our licensing terms. We do not track precise GPS location unless you explicitly grant permission through your mobile device.
• Cookies and Tracking Technologies: We use cookies (small text files stored on your device), web beacons, pixels, and similar technologies to remember your login status, language preferences, and browsing behavior. You can control cookie settings through your browser, but disabling certain cookies may limit Platform functionality. See Section 8 for detailed cookie information.

1.3 Information from Third Parties

• Payment Processors: When you make deposits or withdrawals through BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, or e-wallet providers, these third parties may share transaction confirmation data, payment status, and basic account verification information with us.
• Game Providers: When you play games from Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, and other licensed game studios, these providers may share gameplay data, bet history, and RTP (Return to Player) statistics with us for auditing and compliance purposes.
• Fraud Prevention Services: We may use third-party identity verification services, fraud detection tools, and anti-money laundering screening databases to validate your identity and detect suspicious activity.

2. How We Use Your Information

rjs138 processes your personal data for the following legitimate business purposes:

2.1 Service Delivery and Account Management

• Creating and maintaining your Player account, authenticating your identity during login, and providing access to gaming services including slots, live casino, sports betting (including bandar bola football bookmaking), and lottery draws (including togel numbers prediction games).
• Processing deposits, withdrawals, and internal account transfers. Reconciling financial transactions and maintaining accurate balance records.
• Administering bonuses, promotions, cashback offers, and loyalty rewards. Verifying eligibility and compliance with wagering requirements.
• Providing customer support through live chat, email, and WhatsApp. Responding to inquiries, resolving disputes, and handling complaints.

2.2 Legal and Regulatory Compliance

• Verifying that you meet age eligibility requirements (minimum 21 years old) and residency restrictions (Indonesia).
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks to prevent identity fraud, terrorist financing, and money laundering.
• Detecting and preventing unauthorized access, fraudulent transactions, bonus abuse, multiple accounts, collusion, and other prohibited activities outlined in our Terms & Conditions.
• Complying with legal obligations under Indonesian gambling regulations, tax reporting requirements, and international data protection standards.
• Responding to lawful requests from government authorities, law enforcement agencies, or courts of competent jurisdiction.

2.3 Platform Security and Fraud Prevention

• Monitoring login attempts, IP addresses, and device fingerprints to detect unauthorized access, account takeovers, and suspicious behavior patterns.
• Implementing risk-based authentication measures, including two-factor authentication (2FA), CAPTCHA challenges, and temporary account locks after multiple failed login attempts.
• Analyzing betting patterns and transaction history to identify potential bonus abuse, collusion between players, or exploitation of software vulnerabilities.
• Maintaining audit logs and security records for internal investigations and regulatory compliance purposes.

2.4 Marketing and Communications (With Your Consent)

• Sending promotional emails about new games, bonus offers, tournaments, and seasonal campaigns (Idul Fitri, Indonesian Independence Day, Christmas promotions) to users who have opted in to marketing communications.
• Displaying personalized game recommendations based on your playing history and preferences.
• Conducting surveys, requesting feedback, and gathering testimonials to improve service quality.
• You may opt out of marketing communications at any time by clicking the "unsubscribe" link in promotional emails or by contacting [email protected]. Opting out of marketing does not affect essential service-related communications such as account verification emails, withdrawal confirmations, or security alerts.

2.5 Analytics and Platform Improvement

• Analyzing user behavior, traffic patterns, and feature usage to identify technical bugs, optimize website performance, and enhance user interface design.
• Conducting A/B testing on new features, layout changes, and promotional campaigns to determine which versions perform best.
• Aggregating anonymized statistical data (e.g., "average session duration across all players," "most popular game categories") for business intelligence and strategic planning. Aggregated data cannot be traced back to individual users.

3. Legal Basis for Processing (GDPR Principles)

Under data protection regulations inspired by GDPR principles, rjs138 processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing your data is essential to fulfill our contractual obligations under the Terms & Conditions you agreed to when registering. This includes account creation, payment processing, game delivery, and customer support.
• Legal Obligation: We are required by law to collect and process certain information for KYC/AML compliance, age verification, tax reporting, and responding to lawful government requests.
• Legitimate Interest: We process data to protect our business interests, including fraud prevention, platform security, risk management, and internal analytics, provided these interests do not override your fundamental privacy rights.
• Consent: For marketing communications, cookies, and certain analytics tracking, we rely on your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing conducted prior to withdrawal.

4. How We Share Your Information

rjs138 does not sell, rent, or trade your personal information to third parties for their independent marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality obligations:

4.1 Service Providers and Business Partners

• Payment Processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, Bank Permata, and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction data necessary to process your deposits and withdrawals.
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, and other licensed studios receive minimal user data (username, bet amounts) required to deliver game sessions and maintain fair play audits.
• Identity Verification Services: Third-party KYC/AML compliance providers receive identification documents and personal details solely for the purpose of verifying your identity and screening against sanctions lists.
• Customer Support Tools: Live chat software, email service providers, and CRM systems process communication records to enable our support team to assist you efficiently.
• Analytics and Marketing Platforms: Web analytics tools (with your consent) receive anonymized or pseudonymized usage data to generate insights about Platform performance and user behavior.

All third-party service providers are contractually obligated to handle your data securely, use it only for specified purposes, and comply with applicable data protection laws. We conduct due diligence on vendors' security practices before engaging their services.

4.2 Legal and Regulatory Disclosures

• Government authorities, law enforcement agencies, regulators, or courts when required by law or legal process (subpoenas, court orders, regulatory audits).
• Financial intelligence units or anti-money laundering authorities if we detect suspicious transactions requiring mandatory reporting.
• Tax authorities as required under Indonesian tax laws for players with significant winnings subject to taxation.

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets involving rjs138, your personal data may be transferred to the acquiring entity, provided the new owner commits to honoring this Privacy Policy or providing equivalent protections.

5. Data Security Measures

rjs138 implements industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data stored in our databases (passwords, financial information, ID documents) is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized employees and contractors who require it to perform their job functions. Access is granted on a need-to-know basis and protected by role-based permissions, multi-factor authentication, and activity logging.
• Secure Infrastructure: Our servers are hosted in secure data centers with 24/7 physical security, fire suppression systems, redundant power supplies, and network monitoring. We employ firewalls, intrusion detection systems, and DDoS protection to prevent cyberattacks.
• Regular Audits: We conduct periodic security audits, vulnerability assessments, and penetration testing to identify and remediate potential weaknesses in our systems.
• Incident Response: In the unlikely event of a data breach affecting your personal information, we will notify affected users and relevant authorities within 72 hours, as required by applicable data protection laws, and take immediate remedial action.

While we employ robust security measures, no system is entirely invulnerable. You also play a critical role in protecting your account by choosing a strong, unique password, enabling two-factor authentication, never sharing your login credentials, and promptly reporting suspicious activity to [email protected].

6. Data Retention

rjs138 retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements:

• Active Accounts: Personal data associated with active Player accounts is retained indefinitely while you continue to use our services.
• Closed Accounts: After you voluntarily close your account or we terminate it for Terms violations, we retain core account data (name, email, transaction history, KYC documents) for seven (7) years to comply with anti-money laundering record-keeping requirements, tax reporting obligations, and potential legal disputes.
• Marketing Consent: If you opt out of marketing communications, we retain your email address on a suppression list to ensure we do not inadvertently contact you again, but we stop processing your data for promotional purposes.
• Legal Holds: If your account is subject to an ongoing investigation, dispute, litigation, or regulatory inquiry, we may retain relevant data beyond standard retention periods until the matter is resolved.

After the applicable retention period expires, we securely delete or anonymize your personal information such that it can no longer be attributed to you individually.

7. Your Data Protection Rights

Under applicable data protection laws, you have the following rights regarding your personal information. To exercise these rights, please contact our Data Protection Officer at [email protected]:

7.1 Right of Access

You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format (e.g., PDF or CSV) within 30 days of your request. The first copy is free; we may charge a reasonable administrative fee for additional copies.

7.2 Right to Rectification

If you believe any personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request correction. You can update your email address, phone number, and residential address directly through your Account settings. For changes to your legal name or date of birth, please contact support with documentary proof (updated ID).

7.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes it was collected, you withdraw consent for processing, or you object to processing based on legitimate interests. However, we may refuse deletion requests if retention is required to comply with legal obligations, establish legal claims, or fulfill contractual obligations. Account closure requests trigger the standard seven-year retention period described in Section 6.

7.4 Right to Restriction of Processing

You may request that we temporarily suspend processing of your personal data in specific situations, such as when you contest the accuracy of the data, the processing is unlawful but you prefer restriction over deletion, or you need the data for legal claims even though we no longer require it.

7.5 Right to Data Portability

You have the right to receive your personal data in a portable format and transmit it to another service provider, where technically feasible. This applies to data you provided to us based on consent or contract, and that we process by automated means.

7.6 Right to Object

You may object to processing based on legitimate interests (e.g., fraud prevention, analytics) or for direct marketing purposes. If you object to marketing, we will immediately cease such processing. For legitimate interest processing, we will stop unless we demonstrate compelling grounds that override your interests.

7.7 Right to Withdraw Consent

Where we process your data based on consent (e.g., marketing emails, cookies), you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

7.8 Right to Lodge a Complaint

If you believe rjs138 has violated your privacy rights, you have the right to file a complaint with the relevant Indonesian data protection authority or supervisory body. We encourage you to contact us first so we can address your concerns directly.

8. Cookies and Tracking Technologies

rjs138 uses cookies and similar technologies to enhance your browsing experience, remember your preferences, and analyze Platform usage. A cookie is a small text file stored on your device when you visit our website. We use the following types of cookies:

Managing Cookies: Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when cookies are being sent. However, disabling essential cookies will prevent you from accessing certain Platform features, including login functionality. Disabling analytics or marketing cookies does not affect core gaming services. To manage cookies, consult your browser's help documentation (Chrome, Firefox, Safari, Edge all provide cookie management tools).

9. International Data Transfers

Your personal information is primarily stored on servers located within Indonesia or in secure data centers in Singapore and other jurisdictions with adequate data protection standards. If we transfer your data outside Indonesia to third-party service providers (e.g., global payment processors, game providers, cloud hosting services), we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by data protection authorities to ensure equivalent protection standards.
• Adequacy decisions confirming that the destination jurisdiction provides adequate data protection.
• Vendor certifications demonstrating compliance with international security standards (ISO 27001, SOC 2).

10. Children's Privacy

rjs138 strictly prohibits underage gambling. Our services are available only to individuals who are 21 years of age or older and residents of Indonesia. We do not knowingly collect personal information from minors. If we discover that a user is under 21, we will immediately close the account, forfeit any balances, void all transactions, and delete associated personal data. If you believe a minor has created an account on our Platform, please report it immediately to [email protected].

11. Third-Party Links

The rjs138 Platform may contain links to external websites operated by game providers, payment processors, or affiliate partners. This Privacy Policy applies only to our Platform. We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any external sites you visit. Clicking on third-party links is at your own risk.

12. Changes to This Privacy Policy

rjs138 reserves the right to update this Privacy Policy periodically to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will notify you via email (if you have provided a valid email address) and/or by posting a prominent notice on our Platform. The "Last Updated" date at the bottom of this page indicates when the policy was most recently revised. Your continued use of the Platform after changes are posted constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed about how we protect your information.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer through the following channels:

• Privacy Inquiries Email: [email protected]
• General Support Email: [email protected]
• Data Subject Rights Requests: Send written requests to [email protected] with subject line "Data Rights Request" and include your full name, registered email address, and description of your request.
• Response Time: We will respond to all privacy inquiries within 30 days. Complex requests may require additional time, in which case we will notify you and provide a revised timeline.