Privacy Policy

This Privacy Policy ("Policy") explains how jos123 ("we", "us", "our", or the "Company") collects, uses, stores, and discloses personal information obtained from individuals who access or use the jos123 platform ("you" or "User"). By creating an account with jos123 or continuing to use our services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy forms an integral part of the jos123 Terms & Conditions. Capitalised terms not defined in this Policy carry the meanings assigned to them in the Terms & Conditions.

1. Definitions

For the purposes of this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identity number, contact details, financial data, and behavioural data collected via the Platform.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transfer, or deletion.
• "Data Controller" means jos123, which determines the purposes and means of Processing your Personal Data.
• "Data Processor" means any third party that Processes Personal Data on behalf of jos123 under a written agreement.
• "KYC" means Know Your Customer identity verification, which includes submission of government-issued identification and supporting documents.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a jos123 account or interact with the Platform, we collect information you provide voluntarily, including:

• Full legal name as it appears on your national identity card (KTP or equivalent government-issued document).
• Date of birth, used to verify that you meet the minimum age requirement of 21 years.
• Residential address in Indonesia (city, province, and postal code).
• Email address and mobile phone number (used for account security and communications).
• Bank account details for withdrawals (BCA, BRI, BNI, Mandiri) or e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Identity document images submitted during KYC verification (KTP, SIM, or passport).
• Selfie images submitted as part of liveness verification where required.

2.2 Information Collected Automatically

When you access the Platform, our systems automatically collect certain technical data, including:

• IP address and approximate geographic location (city and country level).
• Device type, operating system, browser type, and browser version.
• Session duration, pages visited, features accessed, and betting activity.
• Login timestamps and session identifiers.
• Cookie data and similar tracking technologies (see Section 8 on Cookies below).

2.3 Information from Third Parties

In limited circumstances, we may receive Personal Data about you from third parties, including:

• Payment processors and banking partners (for deposit and withdrawal verification).
• Identity verification service providers (for KYC and fraud prevention checks).
• Fraud detection and anti-money-laundering screening databases.
• Responsible gaming registries (where you have self-excluded or opted into a multi-operator exclusion scheme).

3. How We Use Your Personal Data

jos123 processes your Personal Data for the following purposes:

3.1 Account Administration and Service Delivery

We use your Identity Data, Contact Data, and Financial Data to create and manage your account, authenticate your identity at login, process deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja, settle bets, and respond to support queries. This processing is necessary to fulfil our contractual obligations to you.

3.2 Legal and Regulatory Compliance

We are legally required to verify your identity (KYC), screen your details against sanctions lists and anti-money-laundering (AML) databases, and retain transaction records for a minimum of five years. This processing is necessary to comply with applicable legal obligations, including international AML frameworks and the licence conditions under which jos123 operates.

3.3 Platform Security and Fraud Prevention

We monitor Technical Data and Transactional Data in real time to detect and prevent fraudulent account activity, bonus abuse, collusion, unauthorised access attempts, and other prohibited conduct. This processing is based on our legitimate interest in protecting the integrity and security of the Platform and the interests of our members.

3.4 Responsible Gaming Monitoring

We use Transactional Data and behavioural data to identify patterns that may indicate problem gambling behaviour — for example, rapidly increasing bet sizes, failed withdrawal reversals, or sessions extending beyond normal duration. This allows us to proactively offer responsible gaming tools, including deposit limits, session reminders, and self-exclusion. Further details are available on our Responsible Gaming page.

3.5 Service Improvement and Analytics

We use aggregated, anonymised Technical Data and behavioural data to understand how the Platform is used, identify areas for improvement, and optimise the user experience. This analytics data does not identify individual users and is processed on the basis of our legitimate interests in developing and improving our services.

3.6 Marketing and Promotions

With your consent, we may use your Contact Data to send promotional communications about bonuses, seasonal offers (e.g., Idul Fitri campaigns, Indonesian Independence Day specials), and new platform features. You may withdraw your consent to marketing communications at any time by contacting our support team. Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to withdrawal.

4. Disclosure of Personal Data

4.1 Service Providers and Data Processors

jos123 shares Personal Data with carefully vetted third-party service providers who process data on our behalf under written Data Processing Agreements. These providers include:

• Payment gateway operators and banking partners (to facilitate IDR transactions).
• KYC and identity verification platforms.
• Cloud hosting and content delivery network (CDN) providers.
• Fraud detection and risk management service providers.
• Customer support software and live-chat platform operators.
• Game content providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and similar certified studios).

All Data Processors are contractually prohibited from using your Personal Data for any purpose other than the specific service they provide to jos123.

4.2 Legal Disclosures

jos123 may disclose your Personal Data to law enforcement authorities, regulatory bodies, or other competent public authorities when required to do so by applicable law, court order, or regulatory directive. We will, where permitted by law, notify you of any such disclosure request prior to compliance.

4.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of the Company's assets, your Personal Data may be transferred to the acquiring entity. We will provide you with prior notice of any such transfer and ensure that the acquiring entity is bound by privacy obligations at least equivalent to those in this Policy.

4.4 No Sale of Personal Data

jos123 does not sell, rent, or lease your Personal Data to any third party for commercial marketing purposes. This is an absolute commitment and is not subject to any exception.

5. International Data Transfers

Given that some of our technology partners and cloud infrastructure providers may operate data centres outside Indonesia, your Personal Data may be transferred to and processed in countries other than Indonesia. In such cases, jos123 implements appropriate safeguards to ensure that your data is protected to a standard equivalent to this Policy, including execution of standard contractual clauses or reliance on adequacy frameworks recognised by the data protection authority of the jurisdiction in which jos123 is licensed.

Where Personal Data is transferred internationally, we ensure that: (a) the recipient country provides an adequate level of data protection; (b) appropriate contractual safeguards are in place; and (c) transfers are limited to the minimum data necessary for the specific purpose.

6. Data Retention

jos123 retains your Personal Data for as long as your account remains active and for a further period as required by applicable law and our licensing obligations. Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of the account relationship plus a minimum of 5 years following account closure, in accordance with AML and KYC record-keeping requirements.
• Financial and Transactional Data: Retained for a minimum of 5 years from the date of each transaction, as required by financial record-keeping obligations.
• Technical and Log Data: Retained for up to 12 months for security monitoring and fraud detection purposes, after which it is anonymised or deleted.
• Marketing Consent Records: Retained for the duration of your account relationship and for up to 3 years following account closure, to demonstrate compliance with consent obligations.
• KYC Document Images: Retained for a minimum of 5 years from the date of submission or account closure, whichever is later.

When Personal Data is no longer required for any of the above purposes, it is securely deleted or anonymised so that it can no longer be linked to any individual.

7. Your Rights

Subject to applicable law, you have the following rights in relation to your Personal Data held by jos123. To exercise any of these rights, contact our support team at [email protected] (plain text — not a clickable link). We will respond to all verified requests within 14 business days.

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data. For basic account details (email, phone, address), you can update information directly in your account settings.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent. This right is subject to our legal retention obligations — data we are required to keep by law cannot be deleted on request.
• Right to Restrict Processing: You may request that we limit the processing of your Personal Data in certain circumstances, for example while a dispute about accuracy is being resolved.
• Right to Data Portability: You may request a machine-readable copy of the Personal Data you have provided to us directly, where processing is based on your consent or on a contract.
• Right to Object: You may object to processing carried out on the basis of our legitimate interests, including profiling for responsible gaming purposes. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the jos123 Platform. They help us recognise your device on return visits, remember your preferences, maintain your session security, and collect analytical data to improve the Platform experience.

8.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function — these enable login authentication, session management, and security features. They cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred payment method display, and previously viewed game categories.
• Analytical Cookies: Collect aggregated data about how users navigate the Platform. This data is used in anonymised form to identify areas for improvement and optimise page performance.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot logins and credential stuffing attacks.

8.3 Managing Your Cookie Preferences

You can control non-essential cookies through your browser's cookie settings. Please note that disabling cookies may affect the functionality of the Platform — in particular, disabling strictly necessary cookies will prevent you from logging in. For detailed instructions on managing cookies in popular browsers (Chrome, Firefox, Safari, Edge), refer to the help documentation provided by your browser manufacturer.

9. Children and Minors

The jos123 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect Personal Data from any person under the age of 21. If we become aware that Personal Data has been submitted by a person under 21, we will immediately close the associated account, void all bets and transactions, and delete the data in question.

If you are a parent or guardian and believe that your child has registered on the Platform, please contact us immediately at [email protected] so that we can take appropriate action.

10. Platform Security

jos123 implements a comprehensive set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS 1.3 encryption for all data in transit between your device and our servers.
• AES-256 encryption for sensitive data stored at rest, including financial records and identity documents.
• Multi-factor authentication (MFA) options for account login.
• Regular penetration testing and vulnerability assessments by independent security firms.
• Role-based access controls limiting staff access to Personal Data on a strict need-to-know basis.
• 24/7 security operations monitoring for anomalous access patterns and intrusion attempts.
• Annual third-party security audits of our data handling and storage infrastructure.

While we take every reasonable precaution, no digital platform can guarantee absolute security. You also have a responsibility to protect your account by using a strong, unique password and not sharing your login credentials with any third party.

11. Third-Party Links and Services

The jos123 Platform may contain references to third-party game providers (such as Pragmatic Play, Evolution Gaming, Microgaming, and NetEnt). While these providers are contractually bound by our data protection requirements, their own privacy policies govern any data they collect independently. jos123 is not responsible for the privacy practices of third-party software providers beyond the scope of our Data Processing Agreements with them.

12. Changes to This Privacy Policy

jos123 reserves the right to update or amend this Privacy Policy at any time. The "Last Updated" date at the top of this document reflects the most recent revision. Where changes are material, we will notify you by email to your registered address or via a prominent in-Platform notification prior to the changes taking effect.

Continued use of the Platform after the effective date of any amendments constitutes your acceptance of the revised Policy. If you do not agree with the updated Policy, you must discontinue use of the Platform and may request account closure in accordance with our Terms & Conditions.

13. Contact and Data Protection Enquiries

If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to report a privacy concern, please contact us using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: "Privacy Policy Enquiry" or "Data Rights Request"
• Live Chat: Available 24/7 via the Platform
• Support Hours: 08:00 – 24:00 WIB, daily

We are committed to resolving all privacy-related enquiries promptly and transparently. If you are not satisfied with our response, you have the right to escalate your complaint to the relevant data protection authority in the jurisdiction in which jos123 is licensed.