Privacy Policy

Introduction

jphoki ("we", "us", "our", "the Company") operates the online betting and gaming platform accessible at https://jphoki.cam (the "Platform"). As the data controller responsible for the personal information you provide to us and that we gather through your use of the Platform, we are fully committed to protecting your privacy and handling your data responsibly, transparently, and in strict compliance with applicable data protection principles.

This Privacy Policy applies to all individuals who visit, register on, or otherwise interact with the jphoki Platform, including registered Players, visitors browsing without an account, and individuals who contact our customer support team. It covers all personal data collected through the Platform, our mobile interfaces, email correspondence, live chat, and WhatsApp support channels.

jphoki's services are directed primarily at adult players (21 years of age and older) residing in Indonesia. We process personal data with particular sensitivity to the expectations and rights of Indonesian users, and we maintain technical and organizational safeguards consistent with internationally recognised data protection standards.

Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Account" — the registered profile created by a Player on the jphoki Platform to access betting and gaming services.
• "Cookie" — a small text file stored on your device by a website to remember information about your visit and behaviour on that site.
• "Data Controller" — the entity that determines the purposes and means by which personal data is processed; jphoki acts as the Data Controller for all personal data described in this Policy.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller under a written agreement and solely on the Controller's instructions.
• "KYC" — Know Your Customer; the identity and age verification procedures jphoki conducts to confirm the eligibility and identity of Players.
• "Personal Data" — any information that identifies or could reasonably identify a specific individual, directly or indirectly; this includes names, email addresses, Indonesian National Identity Card (KTP) numbers, IP addresses, and device identifiers.
• "Player" — any individual who has registered and holds an active or inactive Account on the jphoki Platform.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Sensitive Data" — a subset of Personal Data warranting heightened protection; this includes identity document numbers, financial account details, and transaction history.

Data We Collect

3.1 Registration and Account Data

When you register an Account on jphoki, we collect the following personal information as a mandatory part of the registration process:

• Full legal name (as it appears on your Indonesian National Identity Card — KTP);
• Date of birth (to verify you are at least 21 years of age);
• Email address (used for account communications and notifications);
• Mobile telephone number (used for two-factor authentication and support communications);
• Residential address in Indonesia;
• Preferred username and encrypted password.

3.2 Identity Verification (KYC) Data

As part of our mandatory KYC process, we may request and store copies of the following documentation:

• Indonesian National Identity Card (Kartu Tanda Penduduk — KTP);
• A recent bank statement or utility bill confirming your registered residential address (issued within the previous three months);
• Bank account passbook or statement confirming that the payment account used belongs to you;
• A selfie photograph holding your KTP (in some verification cases).

3.3 Financial Transaction Data

When you make deposits or request withdrawals, we collect and process the following financial data:

• Bank account number and bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, or BSI);
• E-wallet account identifiers (OVO, DANA, GoPay, ShopeePay, or LinkAja);
• Transaction amounts in Indonesian Rupiah (Rp / IDR);
• Transaction timestamps and reference numbers;
• Deposit and withdrawal history associated with your Account.

3.4 Gaming Activity Data

We collect a detailed record of your gaming activity on the Platform, including:

• All bets placed (sports markets, casino games, slot titles, togel lottery selections, crash games);
• Game outcomes, winnings, and losses;
• Session duration, session start and end times (recorded in WIB timezone);
• Bonus activations, wagering progress, and bonus settlements;
• Responsible gaming tool activations (deposit limits, self-exclusion requests, cooling-off periods).

3.5 Technical and Device Data

When you access the Platform, our servers automatically collect certain technical information, including:

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type and version;
• Unique device identifier and mobile advertising identifier (where applicable);
• Pages visited, time spent on pages, and navigation paths within the Platform;
• Referring URLs (the page you visited before arriving at jphoki).

3.6 Communications Data

When you contact jphoki through any channel, we collect and retain records of those communications, including:

• Live chat transcripts;
• Email correspondence to and from [email protected];
• WhatsApp message records (retained in accordance with our retention schedule);
• Customer complaint records and resolution outcomes.

How Data Is Collected

jphoki collects your personal data through the following means:

• Directly from you: when you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact customer support, respond to surveys, or update your Account profile;
• Automatically: through server logs, cookies, pixels, and similar technologies when you browse or use the Platform — including session activity, device data, and IP address information;
• From third-party payment providers: when you make a payment through BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, or LinkAja, our payment processor may share transaction confirmation data with us;
• From third-party game providers: game studios such as Evolution Gaming, Pragmatic Play, PG Soft, and others may pass game session data back to jphoki for settlement, dispute resolution, and fraud detection purposes;
• From fraud detection and security services: third-party fraud prevention and identity verification partners may provide us with risk scores, identity confirmation signals, or flagged account indicators.

Purpose & Use of Data

jphoki processes your personal data strictly for the following defined purposes:

Legal Basis for Processing

jphoki processes your personal data on the following legal grounds:

• Contractual Necessity: Processing is essential for the performance of the contract between you and jphoki (i.e., the Terms & Conditions). Without processing your personal data, we cannot provide the betting and gaming services you have requested. This legal basis covers Account creation, transaction processing, and service delivery.
• Legal Obligation: jphoki is required to process certain personal data to comply with legal and regulatory obligations, including KYC requirements, anti-money laundering (AML) record-keeping, and responding to lawful requests from authorities.
• Legitimate Interests: jphoki has a legitimate business interest in processing personal data for fraud prevention, Platform security, customer support quality assurance, business analytics, and Platform improvement — provided that this interest is not overridden by your fundamental data protection rights.
• Consent: Where required by law, jphoki processes certain data (such as sending marketing communications) based on your freely given, informed, and specific consent. You may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

Data Sharing & Disclosure

7.1 Third-Party Service Providers

jphoki engages trusted third-party service providers to support the operation of the Platform. These providers act as Data Processors under written agreements that restrict their use of your personal data solely to the purposes defined by jphoki. Categories of third parties with whom we share data include:

• Payment processors: To facilitate deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Game providers: Evolution Gaming, Pragmatic Play, PG Soft, NetEnt, Microgaming, Spribe, Play'n GO, and other licensed game studios receive session data necessary to deliver their games on the Platform.
• Identity verification providers: Specialized KYC and document authentication services that verify the authenticity of submitted identity documents.
• Fraud detection and security providers: Third-party services that analyze transaction patterns, IP addresses, and device fingerprints to detect and prevent fraud, collusion, and bonus abuse.
• Cloud hosting and data storage providers: Infrastructure providers that host the Platform's servers and databases in secure, encrypted environments.
• Customer support tools: Live chat, email ticketing, and CRM systems used by our support team to manage and respond to player inquiries.

7.2 Legal Disclosures

jphoki may disclose your personal data where required by law, including in response to court orders, subpoenas, or requests from regulatory or law enforcement authorities in Indonesia or other jurisdictions. We will only disclose the minimum data necessary to satisfy the legal requirement.

7.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of jphoki's assets, your personal data may be transferred to the acquiring entity. You will be notified via email or prominent notice on the Platform if such a transfer occurs, and the acquiring entity will remain bound by the terms of this Privacy Policy unless you are provided an opportunity to consent to revised terms.

7.4 No Sale of Personal Data

jphoki does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Any data shared with third parties is strictly for the purposes described in this Privacy Policy and under contractual protections.

Cookies & Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They enable the website to remember information about your visit, such as your login state, language preferences, and browsing behaviour. Cookies are essential for the functioning of modern web applications, including the jphoki Platform.

8.2 Types of Cookies We Use

• Essential Cookies: Strictly necessary for the Platform to function. These cookies enable core features such as account login, secure authentication, session management, and transaction processing. Essential cookies cannot be disabled without severely impacting your ability to use the Platform.
• Performance Cookies: Collect aggregated, anonymous data about how visitors use the Platform, including page load times, navigation paths, and error messages. This data helps us optimize Platform performance.
• Functionality Cookies: Remember your preferences and settings, such as language selection, timezone display (WIB / WITA / WIT), and layout preferences, to provide a personalized experience.
• Advertising and Analytics Cookies: Track user interactions across the Platform to understand which promotions, bonuses, and games are most popular. These cookies may also enable personalized marketing messages (subject to your marketing preferences).

8.3 Managing Cookies

You may control or disable cookies through your browser settings. Note that disabling essential cookies will prevent you from using key features of the Platform, including Account login and transaction processing. Instructions for managing cookies in common browsers can be found in your browser's help section.

Data Retention

jphoki retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our data retention schedule is as follows:

• Active Account Data: Retained for the entire period during which your Account remains active and for six (6) months following voluntary Account closure or permanent self-exclusion, to allow for reopening or dispute resolution.
• Financial Transaction Records: Retained for seven (7) years from the date of the transaction, as required under anti-money laundering regulations and standard financial record-keeping practices in Indonesia.
• KYC Documentation: Retained for seven (7) years from the date of Account closure, in compliance with regulatory KYC record-keeping requirements.
• Gaming Activity Logs: Retained for three (3) years from the date of the session or bet placement, to support dispute resolution and regulatory reporting.
• Customer Support Communications: Retained for two (2) years from the date of the communication, for quality assurance and training purposes.
• Marketing Consent Records: Retained for the duration of your Account's active status plus two (2) years, to evidence your consent preferences.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer identify you.

Data Security

jphoki employs technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, or disclosure. Our security framework includes:

• Encryption: All personal data in transit between your device and our servers is encrypted using 256-bit SSL/TLS encryption. Sensitive data at rest (including passwords and financial account details) is encrypted using industry-standard AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized jphoki personnel and approved third-party processors on a strict need-to-know basis. Access is logged and regularly audited.
• Secure Infrastructure: jphoki's servers and databases are hosted in secure data centers with physical access controls, firewalls, intrusion detection systems, and 24/7 security monitoring.
• Regular Security Audits: We conduct periodic security assessments and vulnerability scans to identify and remediate potential weaknesses in our systems.
• Incident Response: jphoki maintains a documented data breach response plan. In the event of a personal data breach that is likely to result in a high risk to your rights, we will notify affected individuals within 72 hours of becoming aware of the breach, as required under applicable data protection regulations.

While we implement robust security measures, no method of electronic transmission or storage is entirely immune to compromise. You are responsible for maintaining the confidentiality of your Account password and for notifying us immediately if you suspect unauthorized access to your Account.

Your Privacy Rights

Under applicable data protection principles, you hold the following rights in relation to your personal data processed by jphoki:

To exercise any of these rights, please submit a written request to [email protected] with the subject line "Privacy Rights Request". We will respond to all valid requests within thirty (30) days. We may require proof of identity before processing your request to protect against unauthorized access.

Children's Privacy

jphoki's services are strictly restricted to individuals aged 21 years and older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and permanently close the associated Account without notice. Any balances held in an underage Account will be forfeited.

Parents and guardians who believe their child has registered an Account on jphoki should contact us immediately at [email protected] so that we may take appropriate action.

International Data Transfers

jphoki primarily serves players residing in Indonesia and processes data within secure data centers located in jurisdictions with robust data protection frameworks. However, some of our third-party service providers (including cloud hosting infrastructure, payment processors, and game studios) may be located outside Indonesia.

Where personal data is transferred internationally, jphoki ensures that appropriate safeguards are in place to protect your data in accordance with internationally recognized standards. These safeguards include standard contractual clauses approved by data protection authorities, binding corporate rules, and adherence to cross-border data transfer frameworks.

By using jphoki's services, you acknowledge and consent to the international transfer of your personal data as necessary to deliver the services you have requested.

Policy Amendments

jphoki reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or business operations. Material changes will be communicated to registered Players via email and through a prominent notice on the Platform at least seven (7) days before the revised Policy takes effect. The "Last Updated" date at the top of this page indicates the date of the most recent revision.

Your continued use of jphoki following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not accept the revised terms, you must cease using the Platform and may request Account closure and data deletion in accordance with Section 11.

Contact & Privacy Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or jphoki's handling of your personal data, please contact our Data Protection team using the details below:

• Email: [email protected] (Subject: Privacy Inquiry)
• Live Chat: Available 08:00 – 24:00 WIB daily via the Platform
• WhatsApp Support: Available 08:00 – 24:00 WIB daily

jphoki is committed to resolving all privacy-related inquiries and complaints promptly and transparently. We aim to acknowledge all formal privacy complaints within 24 hours and to provide a comprehensive written response within ten (10) business days. If you are not satisfied with our response, you retain the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction.