Privacy Policy — JSM88

JSM88 ("JSM88", "we", "us", "our") operates the online casino and sports betting platform accessible at jsm88.cam ("the Platform"). We are committed to safeguarding the personal data of every individual who accesses or uses our Services, in full compliance with the Malaysian Personal Data Protection Act 2010 (PDPA 2010) and internationally recognised data protection standards.

This Privacy Policy ("Policy") sets out in clear and precise terms the categories of personal data we collect, the purposes for which that data is processed, the conditions under which we may share it with third parties, the security measures we employ to protect it, and the rights you hold as a data subject.

This Policy applies to all current and former registered users of the JSM88 Platform, to visitors who browse our Platform without registering, and to any individual whose personal data we receive in connection with our business operations, including via email correspondence and customer support interactions.

By registering an account, accessing the Platform, or otherwise providing your personal data to JSM88, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any aspect of this Policy, you must discontinue use of the Platform and contact our support team to request account closure.

For the purposes of this Privacy Policy, the following definitions shall apply:

JSM88 is the Data Controller responsible for the Personal Data collected and processed through the Platform. As Data Controller, JSM88 determines the purposes and means by which Personal Data is processed, and bears primary responsibility for compliance with applicable data protection obligations.

Where JSM88 engages third-party service providers to process Personal Data on its behalf — for example, payment processors, KYC verification service providers, or IT infrastructure providers — those entities act as Data Processors under JSM88's instructions and are contractually bound to process data only in accordance with JSM88's documented requirements and applicable law.

JSM88 collects Personal Data across several categories, depending on your interaction with the Platform. The following table summarises the principal categories of data collected:

JSM88 does not intentionally collect sensitive personal data such as racial or ethnic origin, religious beliefs, health information, or biometric data except where strictly required by applicable law or regulation (e.g., identity verification requirements). Where such data is incidentally contained in KYC documents, it is treated with the highest level of confidentiality.

JSM88 collects Personal Data through the following channels and mechanisms:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or participating in promotional activities.
• Automated collection: Technical Data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access or navigate the Platform.
• Third-party payment processors: Transaction confirmation data returned by FPX, DuitNow, and eWallet providers (Touch 'n Go, Boost, GrabPay) upon successful payment processing. JSM88 receives only the data necessary to confirm and record the transaction.
• Identity verification providers: Data returned by third-party KYC verification services engaged to assist with identity document authentication, where applicable.
• Publicly available sources: In limited circumstances, JSM88 may cross-reference data from publicly available government databases to fulfil AML screening obligations.

JSM88 processes your Personal Data only for lawful purposes. The specific purposes for which we process each category of data are set out below:

1. Account Creation and Management: To register your account, verify your identity, maintain accurate account records, and provide access to the Platform and Services.
2. Transaction Processing: To process deposits made via Maybank, CIMB, Public Bank, Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and cryptocurrency channels, and to facilitate withdrawal requests to your verified payment method.
3. KYC and AML Compliance: To verify your identity and source of funds in accordance with anti-money laundering obligations, and to satisfy regulatory requirements applicable to JSM88's operating licence.
4. Service Delivery and Improvement: To operate, maintain, and continuously improve the Platform, including analysing usage patterns to identify areas for technical enhancement.
5. Customer Support: To respond to your enquiries, resolve complaints, and provide technical assistance through our 24/7 support channels.
6. Promotions and Personalisation: Where you have consented to marketing communications, to send relevant bonus offers, personalised promotions, and platform updates. You may withdraw this consent at any time.
7. Responsible Gambling: To administer self-exclusion requests, deposit limits, session reminders, and other responsible gambling tools, and to monitor account activity for signs of problem gambling behaviour.
8. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, bonus abuse, account takeovers, and other security threats to the Platform and its users.
9. Legal Obligations: To comply with applicable laws, court orders, regulatory directions, and requests from competent authorities.

JSM88 processes your Personal Data on the following legal bases as recognised under the PDPA 2010 and applicable data protection frameworks:

• Consent: Where you have provided clear, informed consent to a specific processing activity — for example, when you opt in to receive promotional email communications from JSM88. Consent may be withdrawn at any time without prejudice to the lawfulness of prior processing.
• Contract Performance: Where processing is necessary to fulfil our contractual obligations to you under the JSM88 Terms and Conditions, including account management, transaction processing, and Service delivery.
• Legal Obligation: Where processing is required to comply with a legal or regulatory obligation applicable to JSM88, including AML reporting requirements, KYC obligations, and responses to lawful authority requests.
• Legitimate Interests: Where processing is necessary for JSM88's legitimate business interests, provided that those interests are not overridden by your rights and freedoms. This includes fraud prevention, platform security, and aggregate analytics used to improve the Services.

JSM88 does not sell, rent, or trade your Personal Data to any third party for marketing or commercial purposes. We may share your Personal Data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual safeguards:

• Payment Service Providers: Banks, eWallet operators (Touch 'n Go, Boost, GrabPay), and payment gateway providers (FPX, DuitNow, Visa, Mastercard) to facilitate deposits and withdrawals. These providers receive only the data necessary to execute and confirm the specific transaction.
• KYC and Identity Verification Providers: Third-party service providers engaged to assist with identity document verification, biometric checks (where applicable), and sanctions screening. All such providers are contractually bound to process data exclusively for the specified verification purpose.
• IT Infrastructure Providers: Cloud hosting, data storage, and security providers who process data on JSM88's behalf under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: JSM88 will disclose Personal Data to competent regulatory bodies, law enforcement agencies, or courts of law where required to do so by applicable law, court order, or legal process. JSM88 will, where legally permissible, notify the affected user of such a disclosure.
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by JSM88 in connection with its business operations, where access to specific Personal Data is strictly necessary for the service being provided.

Any third party with whom JSM88 shares Personal Data is required to maintain appropriate technical and organisational security measures and to process the data solely in accordance with JSM88's documented instructions and applicable data protection law.

JSM88's primary server infrastructure is located within jurisdictions that maintain data protection standards consistent with applicable law. In certain circumstances, Personal Data may be transferred to, stored, or processed in jurisdictions outside Malaysia — for example, where third-party service providers maintain infrastructure in other countries.

Where such international transfers occur, JSM88 takes appropriate steps to ensure that the receiving entity provides an adequate level of protection for Personal Data, including through contractual mechanisms such as data processing agreements incorporating appropriate data transfer clauses.

By using the JSM88 Platform, you acknowledge that your Personal Data may be transferred to and processed in jurisdictions outside Malaysia, subject always to the safeguards described in this Policy.

JSM88 retains Personal Data for no longer than is necessary for the purposes set out in this Policy, subject to applicable legal and regulatory retention requirements. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised in accordance with JSM88's data disposal procedures.

JSM88 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session continuity, and gather aggregate analytics on Platform usage. Cookies are small text files placed on your device by your web browser upon visiting our Platform.

The following categories of cookies are used on the JSM88 Platform:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that maintain your login state and security tokens. These cookies cannot be disabled without impacting core Platform functionality.
• Performance and Analytics Cookies: Used to collect aggregated, anonymised data on how users navigate the Platform — for example, which pages are most visited and where users encounter errors. This data helps JSM88 improve the Platform experience.
• Functional Cookies: Used to remember your preferences such as language selection, last-used payment method, and responsible gambling settings, to provide a more personalised experience.
• Marketing Cookies: Where you have consented to marketing communications, these cookies may be used to tailor promotional content presented to you based on your usage patterns. These cookies are only active where explicit consent has been provided.

You may manage cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect your ability to use specific features of the Platform. Detailed instructions for managing cookies are available through the settings menu of all major browsers including Chrome, Firefox, Safari, and Edge.

JSM88 implements a comprehensive suite of technical and organisational security measures designed to protect your Personal Data from unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include but are not limited to:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the JSM88 Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Encrypted Data Storage: Personal Data and financial records stored in JSM88's systems are encrypted at rest using AES-256 encryption or equivalent standard.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. All staff access is logged, and privileged access requires multi-factor authentication.
• Regular Security Audits: JSM88 conducts periodic security assessments, penetration testing, and vulnerability scanning to identify and remediate potential weaknesses in its security posture.
• Intrusion Detection: Real-time intrusion detection and prevention systems monitor for anomalous access patterns and potential security incidents.
• Staff Training: All JSM88 personnel who handle Personal Data receive regular training on data protection obligations and security best practices.

While JSM88 employs rigorous security measures, no digital system can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, JSM88 will notify affected individuals in accordance with applicable legal notification requirements.

As a data subject, you hold the following rights in relation to your Personal Data held by JSM88. These rights may be subject to limitations where they conflict with JSM88's legal obligations or the legitimate rights of third parties.

To exercise any of the above rights, please submit a written request to our support team via email at [email protected] with the subject line "Data Rights Request". Please include your registered username and a description of the right you wish to exercise. JSM88 will acknowledge your request within twenty-four (24) hours and provide a substantive response within twenty-one (21) calendar days, or notify you if an extension is required under applicable law.

JSM88 reserves the right to verify your identity before processing any data rights request in order to protect the security of player data.

The JSM88 Platform is strictly intended for individuals aged twenty-one (21) years and above. JSM88 does not knowingly collect Personal Data from any person under the age of 21. Age verification is conducted as part of the KYC process for all new registrations.

If JSM88 discovers or is notified that Personal Data has been collected from a person under the age of 21, all such data will be deleted immediately and the associated account will be permanently closed. If you believe that a minor may have accessed the Platform, please notify us immediately at [email protected].

The JSM88 Platform may, from time to time, contain references to payment processors or third-party service providers in the context of your account. JSM88 is not responsible for the privacy practices, content, or security of any third-party websites, applications, or services accessed via links from the Platform or otherwise in connection with your use of the Services.

We encourage you to review the privacy policies of any third-party services you use in connection with payments or account verification to understand how they handle your Personal Data independently.

JSM88 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, our data processing practices, or Platform functionality. Material changes will be communicated to registered users via email notification and/or a prominent notice on the Platform no fewer than seven (7) days prior to the effective date of the change.

The current version of this Policy, including the effective date, is always accessible on this page. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with the revised terms, you may exercise your right to close your account by contacting JSM88 support.

We recommend that you review this page periodically to remain informed of how JSM88 protects your Personal Data.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the manner in which JSM88 processes your Personal Data, please contact our Privacy Team using the details below. We treat all privacy complaints seriously and will endeavour to resolve them promptly and fairly.

If you are unsatisfied with JSM88's response to a privacy complaint, you have the right to escalate the matter to the relevant data protection authority in the jurisdiction applicable to your situation. In Malaysia, the supervisory authority for PDPA 2010 matters is the Department of Personal Data Protection Malaysia (JPDP).