Privacy Policy

Introduction & Scope

pakjep operates pakjep.cam, an online gaming platform serving players across Indonesia, including those in Jakarta, Surabaya, Medan, Bandung, Yogyakarta, Bali, Semarang, Palembang, and Makassar. This Privacy Policy applies to all personal data collected through the Platform, including via desktop browsers, mobile browsers, and any associated applications.

This policy should be read in conjunction with our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated herein by reference. Where this Privacy Policy conflicts with another document on procedural matters relating to data, this Privacy Policy takes precedence.

We are committed to handling your personal data with the highest standards of transparency, integrity, and security. We do not collect data beyond what is reasonably necessary to provide you with a safe, fair, and enjoyable gaming experience on pakjep.

Definitions

• "Personal Data" means any information that relates to an identified or identifiable living individual, including name, identification number, contact details, financial information, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
• "Data Controller" means pakjep, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of pakjep under a written data processing agreement.
• "KYC Data" means identity and address verification documents collected as part of pakjep's Know Your Customer process, including copies of your KTP, passport, SIM, and bank account details.
• "Cookies" means small text files placed on your device by the Platform to store session information, preferences, and usage analytics.
• "AML" means Anti-Money Laundering — the set of legal obligations requiring pakjep to verify player identity and retain certain transaction records for a prescribed minimum period.

Data We Collect

pakjep collects the following categories of personal data, depending on how you interact with the Platform:

We do not intentionally collect sensitive personal data (such as racial origin, religious beliefs, health information, or political opinions) unless strictly required by law or with your explicit consent. pakjep serves players across Indonesia and is conscious of cultural diversity — data relating to religious observance (for example, noting that a player has opted for a deposit suspension during Ramadhan) is treated as sensitive and afforded the highest level of protection.

How We Collect Data

pakjep collects personal data through the following channels:

• Direct submission: Information you voluntarily provide during account registration, KYC document upload, deposit and withdrawal requests, and communications with our support team.
• Automated collection: Technical and usage data collected automatically by our servers, analytics tools, and cookie systems each time you visit or interact with the Platform.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention and AML screening results from compliance data partners; payment confirmation data from banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Publicly available sources: In limited circumstances where required for AML or fraud screening, we may consult publicly available data sources such as sanctions lists and adverse media databases.

Purposes of Processing

pakjep processes your personal data for the following specific purposes:

1. Account creation and management: To register y our account, verify your identity, and maintain your player profile on pakjep.
2. Service delivery: To process deposits and withdrawals in IDR via your chosen payment method, settle bets and game outcomes, and deliver promotional offers you have opted into.
3. KYC and fraud prevention: To verify your identity documents, screen against AML and sanctions databases, detect suspicious activity, and prevent fraud, money laundering, and underage gambling.
4. Customer support: To respond to your enquiries, resolve disputes, and provide 24/7 Indonesian-speaking assistance via our support channels.
5. Responsible gaming: To monitor gaming patterns for signs of problem gambling, enforce self-exclusion elections, apply deposit limits, and fulfil our duty-of-care obligations to players.
6. Platform improvement: To analyse usage patterns, test new features, diagnose technical issues, and optimise the overall player experience across all device types.
7. Marketing communications: Where you have given explicit consent, to send promotional emails or notifications about bonuses, seasonal offers (such as those tied to Idul Fitri, Ramadhan, and Imlek), new game releases, and BRI Liga 1 or EPL betting promotions.
8. Legal and regulatory compliance: To fulfil our obligations under applicable AML and CFT frameworks, respond to lawful requests from competent authorities, and enforce our Terms & Conditions.

Legal Basis for Processing

pakjep processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you accepted on registration — for example, processing deposits and settling bets.
• Legal obligation: Processing required to comply with applicable law, including AML record-keeping requirements, sanctions screening, and responses to lawful authority requests.
• Legitimate interests: Processing necessary for pakjep's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your explicit, freely given, and specific consent — primarily for marketing communications. You may withdraw this consent at any time without detriment to your account status.

Data Sharing & Disclosure

pakjep does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share personal data only in the following limited circumstances:

7.1 Service Providers (Data Processors)

We engage carefully vetted third-party service providers who process data on our behalf under strict contractual data processing agreements. These include:

• Payment processors and banking partners: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, and Bank Permata for bank transfer settlement; OVO, DANA, GoPay, ShopeePay, and LinkAja for e-wallet transactions.
• KYC and identity verification providers: Third-party identity document verification services that perform automated document authenticity checks.
• AML screening services: Compliance data platforms that screen player profiles against international sanctions lists and politically exposed persons (PEP) databases.
• Game content providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive session and game-round data necessary to deliver their gaming services. These providers operate under their own independent data protection frameworks.
• Analytics and infrastructure providers: Cloud hosting, server infrastructure, and analytics platforms that help us maintain Platform availability and diagnose performance issues.

7.2 Legal and Regulatory Disclosure

pakjep may disclose personal data to competent governmental, law enforcement, or regulatory authorities where required by applicable law, court order, or where we have a good-faith belief that such disclosure is necessary to prevent a crime, protect public safety, or defend the legal rights of pakjep or its players.

7.3 Business Transfers

In the event of a merger, acquisition, asset sale, or corporate restructuring involving pakjep, personal data held about registered players may be transferred to the successor entity. We will notify affected players via email or prominent in-platform notification prior to any such transfer and will ensure the successor entity is bound by privacy commitments no less protective than those set out in this policy.

7.4 Aggregated & Anonymised Data

pakjep may share aggregated, anonymised statistical data (for example, total number of active players in Jakarta, or average session duration during the BRI Liga 1 season) with business partners and media. This data does not identify any individual player and is not subject to the restrictions in this section.

International Data Transfers

pakjep's primary operations and data storage infrastructure are oriented toward serving the Indonesian market (WIB, UTC+7). However, some of our service providers — including game studios and cloud infrastructure vendors — operate servers located outside Indonesia. When personal data is transferred outside Indonesia to process a transaction or deliver a service, pakjep takes appropriate steps to ensure that such transfers are protected by adequate safeguards, including:

• Standard contractual clauses incorporated into data processing agreements with overseas vendors;
• Transferring only the minimum data necessary for the specific service being provided; and
• Conducting due-diligence assessments of the data protection standards maintained by overseas recipients before onboarding them as service providers.

If you would like further information about the safeguards applied to a specific international data transfer, please contact us at [email protected].

Data Retention

pakjep retains personal data only for as long as it is necessary to fulfil the purpose for which it was collected, or for as long as required by applicable law. The following retention periods apply as a general guide:

Upon the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with our internal data disposal procedures. Where data is subject to an ongoing legal hold (for example, active litigation or a regulatory investigation), deletion will be deferred until the hold is lifted.

Cookies & Tracking Technologies

pakjep uses cookies and similar tracking technologies to operate the Platform, maintain your session state, and improve your overall experience. The following types of cookies are used:

10.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function. They enable core features such as logging in, maintaining your session while you navigate between pages, and remembering items in your active bet slip. You cannot opt out of strictly necessary cookies without disabling the Platform entirely.

10.2 Analytics Cookies

We use analytics cookies to collect anonymised data about how players interact with the Platform — for example, which game categories are most visited, how long players spend on specific pages, and which deposit methods are most popular. This data is used exclusively to improve the Platform and is not shared with third-party advertisers.

10.3 Functional Cookies

Functional cookies remember your preferences — such as your preferred language, display settings, and notification configurations — so you do not need to re-enter them on each visit.

10.4 Managing Cookies

You can control or delete cookies through your browser settings at any time. Please note that disabling certain categories of cookies may impair the functionality of the Platform. Most modern browsers (Chrome, Firefox, Safari, Edge) provide clear guidance in their settings menus on how to manage cookie preferences.

Your Rights

As a player whose personal data is processed by pakjep, you are entitled to exercise the following rights at any time by submitting a written request to [email protected]:

• Right of Access: You may request a copy of all personal data pakjep holds about you, including the categories of data, the purposes for which it is processed, and any third parties to whom it has been disclosed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure ("Right to be Forgotten"): You may request that we delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to overriding legal retention obligations (for example, AML requirements).
• Right to Restriction of Processing: You may request that we restrict processing of your personal data in certain circumstances — for example, while the accuracy of data is being contested, or pending the outcome of an objection to processing.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, you may request that your personal data be provided to you (or to a nominated third party) in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing of your personal data where that processing is based on pakjep's legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

pakjep will acknowledge all data rights requests within 72 hours (WIB) and will endeavour to fulfil them within 30 calendar days. Where a request is complex or where pakjep receives a large volume of concurrent requests, we may extend this period by a further 60 days, notifying you of the extension and the reason within the initial 30-day window.

Children's Privacy — 21+ Only

pakjep operates a strict minimum age policy of 21 years. The Platform is not directed at or intended for use by minors, and we do not knowingly collect personal data from individuals under the age of 21.

If we become aware that a player account has been created by or on behalf of a person under 21 years of age, we will immediately suspend the account, void any associated transactions, and securely delete all personal data relating to that individual to the extent permitted by law.

If you are a parent or guardian and have reason to believe that a person under 21 in your care has submitted personal data to pakjep, please contact us immediately at [email protected] so that we can take appropriate remedial action.

Security Measures

pakjep implements a comprehensive, layered information security framework to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and our servers.
• AES-256 encryption at rest for all sensitive personal and financial data stored in our databases.
• Role-based access controls ensuring that only authorised personnel with a verified, documented business need may access player records.
• Multi-factor authentication (MFA) required for all internal staff accounts with access to player data systems.
• Regular penetration testing and vulnerability scanning conducted by independent third-party cybersecurity specialists.
• 24/7 security operations monitoring with automated alerts for anomalous access patterns or potential data breaches.
• Data breach response plan — in the event of a confirmed personal data breach affecting your rights and freedoms, pakjep will notify affected players within 72 hours of becoming aware of the incident and will take immediate steps to contain and remediate the breach.

While pakjep takes all reasonable and technically feasible steps to protect your data, no internet transmission or electronic storage system is entirely immune from risk. We encourage you to use a strong, unique password for your pakjep account, enable two-factor authentication where offered, and contact our support team immediately if you notice any unauthorised activity on your account.

Third-Party Links

The Platform may contain references to third-party content providers, game studios, or informational resources. Any third-party services — such as game interfaces provided by Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Pocket Games Soft — operate under their own privacy policies and data processing practices. pakjep is not responsible for the privacy practices of third-party providers and encourages you to review their individual policies.

pakjep does not embed social media tracking pixels or third-party advertising networks on the Platform. We do not permit third-party advertisers to collect data about your gaming behaviour for the purpose of serving targeted advertisements.

Policy Amendments

pakjep reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform features. When material changes are made, we will notify registered players via email to the address associated with their account and via a prominent in-platform notification, providing at least seven days' advance notice before the revised policy takes effect.

The current version of this Privacy Policy is always accessible at pakjep.cam/privacy-policy. The "Last Updated" date at the top of this page indicates when the most recent revision was made. 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 any material change to this Privacy Policy, you have the right to close your account and request deletion of your personal data (subject to legal retention requirements) by contacting us at [email protected] before the amended policy takes effect.

Contact & Complaints

For all queries, requests, or complaints relating to this Privacy Policy or pakjep's data processing practices, please contact our Data Protection team through the following channel:

• Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week, including Indonesian public holidays (Idul Fitri, Idul Adha, Nyepi, Indonesian Independence Day, and others)
• Response Target: Acknowledgement within 72 hours; full response within 30 calendar days (WIB)
• Languages: English and Indonesian-speaking agents available at all times

When submitting a privacy-related enquiry, please include your registered account username, the nature of your request (for example, "data access request", "marketing opt-out", "data erasure request"), and any relevant context to help us process your request efficiently.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to an independent privacy or data protection authority. We are committed to working constructively with any supervisory authority investigation and to resolving player concerns in a fair, transparent, and timely manner.