Privacy Policy

This Privacy Policy ("Policy") describes how Jaya128, operating the online gaming platform accessible at https://jaya128.cam ("Platform", "We", "Us", "Our"), collects, uses, stores, shares, and protects the personal data of users ("You", "User", "Player") who access or use the Platform.

This Policy applies to all personal data processed in connection with your use of Jaya128, including data collected during account registration, identity verification, payment transactions, customer support interactions, and general Platform browsing. It forms part of the broader contractual relationship between you and Jaya128 and should be read together with our Terms & Conditions.

By registering an account on Jaya128, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the Platform and should contact us to request account closure.

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

Jaya128 collects personal data in the categories described below. We collect only what is necessary for the purposes described in this Policy.

We do not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information except where strictly required by applicable regulatory or AML obligations (for example, processing self-exclusion requests that reference a gambling-related health concern).

Jaya128 collects your personal data through the following channels:

• Directly from you: When you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact customer support, or update your account profile.
• Automatically through Platform use: Technical and usage data is collected automatically via server logs, session tracking, and browser cookies when you access and use the Platform. See Section 10 (Cookies & Tracking) for details.
• From third-party service providers: Identity verification agencies, payment processors, and fraud detection services may provide us with data about you in the course of fulfilling their contracted services. For example, a KYC provider may confirm the validity of your submitted identity document.
• From publicly available sources: In limited circumstances related to AML compliance, we may cross-reference publicly available data such as sanction lists or politically exposed persons (PEP) databases.

We process your personal data for the following specific and limited purposes:

• Account Registration & Management: Creating and maintaining your Jaya128 account, enabling login and session management, storing your preferences and game history.
• Identity Verification (KYC): Verifying your age (21+), identity, and payment method ownership in compliance with our international licensing obligations.
• Payment Processing: Processing deposits and withdrawals via your selected payment method — Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, or cryptocurrency channels.
• Fraud Prevention & AML Compliance: Detecting and preventing fraudulent activity, money laundering, collusion, bonus abuse, and other prohibited conduct as defined in our Terms and Conditions.
• Customer Support: Responding to your queries, resolving disputes, and maintaining records of support interactions for quality and training purposes.
• Legal Compliance: Meeting obligations under our international gaming licence, including record-keeping, regulatory reporting, and responding to lawful requests from competent authorities.
• Platform Improvement: Analysing aggregated usage data to improve the Platform's performance, game catalogue, and user experience. This analysis is conducted on anonymised or pseudonymised data where possible.
• Responsible Gambling: Monitoring betting patterns to identify potential problem gambling indicators and enforcing player-imposed limits and self-exclusion requests.
• Marketing Communications (consent-based): Sending promotional offers, bonus notifications, and relevant updates where you have explicitly opted in. You may withdraw consent at any time.

Jaya128 processes your personal data on the following legal bases, consistent with internationally recognised data protection principles:

• Contractual Necessity: Processing required to perform our contractual obligations to you — including account management, payment processing, and KYC verification — is carried out on the basis that it is necessary to deliver the services you have requested.
• Legal Obligation: Processing required by our international operating licence conditions, AML regulations, and lawful requests from regulatory or law enforcement authorities is carried out on the basis of legal obligation.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, and improvement of services is based on our legitimate interest in operating a secure and compliant gaming platform, provided this does not override your fundamental privacy rights.
• Consent: Processing for optional marketing communications and non-essential cookies is conducted only the basis of your explicit, withdrawable consent.

Jaya128 does not sell, rent, or trade your personal data. We share your data only in the following limited and controlled circumstances:

• Payment Service Providers: We share necessary payment and identity data with our payment partners — including providers of Touch 'n Go, Boost, GrabPay, DuitNow, FPX, Maybank/CIMB integration gateways, and cryptocurrency processing services — strictly to process your deposit and withdrawal transactions.
• KYC & Identity Verification Providers: We engage licensed third-party KYC providers to assist in verifying your identity documents. These providers process your submitted documents under strict data processing agreements and are not permitted to use your data for any other purpose.
• Game Software Providers: Our game platform partners may receive limited technical data (such as a pseudonymised user ID and session token) necessary to provide game services. They do not receive your full identity or payment data.
• Fraud Prevention & Security Services: We use third-party fraud detection and IP analysis services that process technical data (IP address, device fingerprint, session patterns) to protect the Platform and its users.
• Regulatory & Legal Authorities: We will disclose personal data to competent authorities, courts, or regulators when required by law, our operating licence conditions, or valid legal process. We will notify affected users of such disclosure where we are legally permitted to do so.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of the Company's business assets, personal data held by Jaya128 may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

As an internationally operated platform, Jaya128 may transfer personal data to servers or service providers located outside of Malaysia. When such transfers occur, we ensure that appropriate safeguards are in place to protect your data, including:

• Transfers to jurisdictions that provide an adequate level of data protection under applicable standards.
• Use of contractual data protection clauses with receiving parties that require equivalent protection to that described in this Policy.
• Application of technical security measures (encryption, access controls) regardless of the country of data storage.

By using the Platform, you acknowledge that your data may be transferred to and processed in countries outside Malaysia. We take reasonable steps to ensure that any such transfer is handled securely and in accordance with this Policy.

Jaya128 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention guidelines apply:

• Active Account Data: Retained for the duration of your registered account's active status plus a minimum of five (5) years after account closure, to satisfy AML record-keeping obligations under our operating licence.
• KYC Documents: Retained for a minimum of five (5) years from the date of submission or from account closure, whichever is later.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer Support Communications: Retained for up to three (3) years from the date of the last interaction, unless a longer period is required in connection with an ongoing dispute or legal matter.
• Marketing Consent Records: Retained for as long as you hold an account with Jaya128, or until you withdraw consent, whichever is earlier.
• Technical and Usage Data (Logs): Typically retained for 12 months in identifiable form before aggregation or deletion.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. In some cases, data may be retained in anonymised form for statistical or research purposes where it no longer identifies any individual.

Jaya128 uses cookies and similar tracking technologies to deliver and improve the Platform. Cookies are small data files stored on your device when you visit the Platform. We use the following categories of cookies:

• Essential / Strictly Necessary Cookies: Required for core Platform functionality, including maintaining your login session, storing your active game state, and enabling secure payment flows. These cannot be disabled without significantly impairing Platform functionality.
• Analytics Cookies: Used to collect aggregated information about how users interact with the Platform — including pages visited, session duration, and navigation paths. This data is used to improve Platform performance and user experience. Analytics data is collected in a pseudonymised or aggregated form.
• Preference Cookies: Used to remember your selected language, display settings, and game preferences so you do not need to re-enter them on each visit.
• Marketing & Targeting Cookies (consent-required): Used to display relevant promotional content based on your Platform activity. These cookies are only set with your explicit consent and can be withdrawn through your browser settings or Account preferences.

You can manage cookie preferences through your browser settings. Please note that disabling non-essential cookies will not affect your ability to access core Platform features, but may affect the personalisation of your experience.

Jaya128 implements appropriate technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:

• TLS Encryption: All data transmitted between your device and the Platform is encrypted using industry-standard Transport Layer Security (TLS 1.2 or higher).
• At-Rest Encryption: Sensitive personal data stored on our servers is encrypted at rest using AES-256 or equivalent encryption standards.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. Staff members with access to personal data are subject to confidentiality obligations and undergo regular security training.
• Two-Factor Authentication: All administrative access to production systems requires multi-factor authentication.
• Penetration Testing: The Platform undergoes regular security assessments, including vulnerability scans and periodic independent penetration testing.
• Incident Response: A documented data breach response procedure is in place. In the event of a security incident affecting your personal data, we will notify you within a reasonable timeframe as required by applicable regulations.

While we implement robust security measures, no internet transmission or electronic storage system is completely secure. We cannot guarantee absolute security, and you should also take responsibility for protecting your own Account credentials.

Subject to applicable law and the specific circumstances of your request, you may exercise the following rights in relation to your personal data held by Jaya128:

To exercise any of these rights, contact our support team via Live Chat (available 24/7) or in writing to [email protected]. We will respond to verified requests within a reasonable timeframe, typically within 30 calendar days. Where a request involves complex data retrieval or affects multiple systems, we will notify you of any extension to this timeframe.

Please note that some rights are subject to limitations where processing is required to fulfil legal obligations, prevent fraud, or protect the rights of other parties. We will communicate any such limitation clearly at the time of responding to your request.

The Jaya128 Platform is strictly for adults aged21 years and above. We do not knowingly collect, process, or store personal data from individuals below the age of 21. If we become aware that an Account has been registered by or on behalf of a minor, that Account will be immediately closed, all data will be securely deleted in accordance with our standard deletion procedures, and any deposits will be returned to the verified payment source.

If you have reason to believe that a minor has registered an account on Jaya128, please contact our support team immediately so that we can investigate and take appropriate action.

The Jaya128 Platform may from time to time display references to or descriptions of third-party services (for example, payment providers such as Touch 'n Go, Maybank, or Boost). This Privacy Policy applies exclusively to data processed by Jaya128 through the Platform.

We are not responsible for the privacy practices, data collection, or content of any third-party services. When you interact with a third-party payment provider, bank, or e-wallet application, you are subject to that provider's own privacy policy and terms. We encourage you to review the privacy policies of any third-party services you use in conjunction with your Jaya128 account.

Jaya128 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or business operations. When material changes are made, we will notify registered Users by displaying a prominent notice on the Platform and, where appropriate, by email to the address associated with your Account, no less than seven (7) days before the amended Policy takes effect.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. We recommend reviewing this Policy periodically. The current version is always accessible at https://jaya128.cam/privacy-policy and is identified by the "Last Updated" date displayed at the top of this page.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our support team. All data-related requests will be handled by our designated privacy team and responded to within 30 calendar days.

• Live Chat: Available 24/7 on the Platform — average response time 3–5 minutes. Ask to speak with a Privacy Request agent for data access or deletion requests.
• Support Email: [email protected] — please include "Privacy Request" in your subject line for faster routing. (Plain text — not a clickable link.)
• Languages: Our support team handles privacy requests in English, Bahasa Melayu, and Chinese, reflecting the multicultural reality of our Malaysian player base.

This Privacy Policy was last updated on 1 January 2026. The version published at https://jaya128.cam/privacy-policy is always the current binding version.