Jinjin Privacy Policy

01 Introduction

Jinjin ("we", "us", "our") operates the online casino and sports betting platform accessible at https://jinjin.cam (the "Platform"). We are committed to safeguarding the privacy and personal data of every individual who interacts with our Platform, including registered players, visitors, and prospective users (collectively, "you" or "Data Subject").

This Privacy Policy ("Policy") explains in clear and accessible terms: what categories of personal data Jinjin collects; the purposes for which that data is processed; the legal basis on which processing takes place; how long data is retained; your rights as a data subject; and how to exercise those rights. This Policy applies to all personal data collected through the Platform, whether submitted during registration, gameplay, customer support interactions, payment processing, or passive browsing.

This Policy forms part of Jinjin's broader legal framework alongside the Terms & Conditions and the Responsible Gambling Policy. By using the Platform, you confirm that you have read and understood this Policy and consent to the processing described herein where consent is the applicable legal basis.

02 Definitions

In this Policy, the following terms carry the meanings assigned below:

03 Categories of Personal Data We Collect

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

3.1 Identity Data

• Full legal name as it appears on official identification documents
• Date of birth (for age verification purposes — players must be 21+)
• National identification number (e.g., Malaysian MyKad number) where required for KYC
• Passport number (for international players or where MyKad is unavailable)
• Selfie or facial photograph submitted during identity verification

3.2 Contact Data

• Email address
• Mobile telephone number
• Residential address (city, postcode, country)

3.3 Financial & Payment Data

• Malaysian bank account details (e.g., Maybank, CIMB, Public Bank, Hong Leong) used for deposits and withdrawals
• E-wallet identifiers (Touch 'n Go eWallet, Boost, GrabPay, DuitNow) registered in your name
• Cryptocurrency wallet addresses used for BTC, ETH, or USDT transactions
• Transaction history including deposits, withdrawals, wagering activity, and balance movements

3.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session data including login timestamps, pages visited, and feature interactions
• Cookies and similar tracking technology data (see Section 10)

3.5 Communications Data

• Records of correspondence with our customer support team via live chat or email
• Responses to voluntary surveys, promotions, or feedback forms

04 How We Collect Your Data

Jinjin collects Personal Data through the following methods:

1. Direct Submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or participating in a promotion.
2. Automated Collection: Technical and usage data collected automatically when you access the Platform, including via cookies, server logs, and analytics tools.
3. Third-Party Sources: Identity and payment verification data received from KYC service providers, payment processors, and fraud prevention services that process data on our behalf.
4. Publicly Available Sources: In limited circumstances related to fraud prevention or responsible gambling checks, we may consult publicly available information such as regulatory sanctions lists.

05 Purposes of Data Processing

Jinjin processes your Personal Data for the following purposes:

06 Legal Bases for Processing

Where internationally recognised data protection frameworks apply to Jinjin's processing activities, we rely on the following legal bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you have accepted, including account management, payment processing, and service delivery.
• Legal Obligation: Processing necessary to comply with applicable laws and licensing requirements, including KYC verification and anti-money laundering checks.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gambling monitoring, and analytics, where these interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications, where you have provided explicit, freely given consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

07 Data Sharing & Disclosure

7.1 Service Providers. Jinjin shares Personal Data with trusted third-party Data Processors who provide services necessary to operate the Platform. These include payment processors (e.g., companies facilitating DuitNow, FPX, and e-wallet transactions), KYC verification providers, game studios and platform providers, cloud hosting services, fraud detection services, and customer support software providers. All such processors are bound by contractual obligations that restrict their use of your data to the specified service purpose only.

7.2 Regulatory & Legal Disclosure. Jinjin may disclose Personal Data to competent authorities, licensing bodies, law enforcement agencies, or courts where required to do so by applicable law, a valid legal order, or our international licensing obligations. We will not disclose more data than is strictly required in each case.

7.3 Business Transfers. In the event that Jinjin undergoes a merger, acquisition, reorganisation, or sale of assets, your Personal Data may be transferred to the acquiring entity as part of the transaction, subject to the same data protection obligations set out in this Policy.

7.4 No Commercial Sale. Jinjin does not sell, rent, lease, or otherwise commercially exploit your Personal Data to any third party. Your data is used solely to deliver and improve our services to you.

08 International Data Transfers

Jinjin operates internationally and may transfer your Personal Data to countries outside Malaysia, including countries where our servers, licensors, or service providers are located. Where such transfers occur, Jinjin ensures that appropriate safeguards are in place — such as standard contractual clauses or equivalent data transfer mechanisms — to protect your data to a standard that is consistent with this Policy.

By using the Platform and submitting your Personal Data, you acknowledge that your data may be transferred to and processed in jurisdictions outside Malaysia. Jinjin takes reasonable steps to ensure that such transfers are conducted in a manner that protects your privacy rights.

09 Data Retention

Jinjin retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, as set out in Section 5, and in compliance with applicable legal and licensing obligations. The following general retention guidelines apply:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, to meet anti-money laundering record-keeping obligations.
• Transaction Records: Financial transaction histories are retained for a minimum of five (5) years from the date of the relevant transaction.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following KYC completion or account closure, whichever is later.
• Support Correspondence: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for ongoing dispute resolution.
• Marketing Data: Retained until you withdraw consent or opt out, after which your contact details are suppressed from marketing sends and flagged accordingly.
• Technical & Usage Data: Typically retained for up to 24 months in aggregated or anonymised form for analytics purposes.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with you as an individual.

10 Cookies & Tracking Technologies

Jinjin uses cookies and similar technologies (such as local storage and session tokens) to operate the Platform, provide a personalised experience, and gather usage analytics. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential to the functioning of the Platform, including authentication, session management, and security. These cannot be disabled without impacting platform functionality.
• Functional Cookies: Enable personalisation features such as language preferences, display settings, and game history. These are set based on choices you have made on the Platform.
• Analytical Cookies: Used to understand how players navigate the Platform, which pages are most visited, and where technical issues occur. Data is collected in aggregate and does not identify you individually.
• Marketing Cookies: Used to serve relevant promotional content where you have consented to receive marketing communications. These are optional and can be declined.

11 Security Measures

Jinjin implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. These measures include but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• Encrypted storage of sensitive data including payment credentials and identity documents
• Multi-factor authentication options for account access
• Role-based access controls limiting internal data access to staff with a need-to-know basis
• Regular security assessments, penetration testing, and vulnerability scanning
• Intrusion detection systems and 24/7 infrastructure monitoring
• Incident response procedures and data breach notification protocols

Notwithstanding these measures, no method of electronic transmission or data storage is completely impervious to security threats. In the event of a data breach that is reasonably likely to result in harm to affected individuals, Jinjin will take prompt steps to contain the breach and notify affected parties in accordance with applicable requirements.

12 Your Rights as a Data Subject

Jinjin respects your rights over your personal information. Subject to applicable law and certain limitations, you have the following rights in relation to your Personal Data:

To exercise any of the above rights, please contact us at [email protected] with the subject line "Data Subject Request" and include sufficient information to identify your account. We will acknowledge your request within 5 business days and respond substantively within 30 calendar days. Some rights may be limited where legal retention obligations or anti-money laundering requirements apply.

13 Children & Minors

The Platform is strictly intended for persons aged 21 years and above. Jinjin does not knowingly collect personal data from individuals under the age of 21. Where we have reason to believe that a registered user is under the age of 21, we will suspend the account, delete the associated personal data, and void any transactions undertaken prior to age verification.

Age verification is a mandatory step of our KYC process. If you are aware of a minor who has accessed or attempted to access the Platform, please contact us immediately at [email protected] so that we can take appropriate action.

14 Updates to This Policy

Jinjin reserves the right to update or revise this Privacy Policy at any time. When we make material changes, we will notify you by posting a notice on the Platform, sending an email to the address registered on your account, or both — depending on the nature and significance of the change.

The "Last Updated" date displayed at the top of this Policy reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how your data is being protected. Your continued use of the Platform following the effective date of any revised Policy constitutes acceptance of the updated terms.

The most current version of this Privacy Policy will always be accessible at https://jinjin.cam/privacy-policy.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the handling of your personal data by Jinjin, please do not hesitate to contact our Data Protection team using the details below. We welcome all privacy-related enquiries and will respond with care and promptness.

We aim to respond to all privacy-related correspondence within five (5) business days. For data subject access requests and formal rights exercises, please allow up to 30 calendar days for a complete response. Where an extension is required, we will notify you in advance and explain the reason for the delay.