1 Introduction
This Privacy Policy ("Policy") describes how jclub ("we", "us", "our", "the Company"), the operator of the online gaming platform at jclub.cam ("the Platform"), collects, processes, stores, and discloses personal data belonging to our registered users ("Players", "you") and visitors to our website.
jclub is committed to handling personal data responsibly, transparently, and in compliance with applicable data protection legislation. We collect only the data that is necessary for the operation of our Platform and the provision of gaming, payment, and customer support services to Malaysian players and other eligible users.
This Policy covers data collected through: account registration and the KYC verification process; payment transactions via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank Online, and cryptocurrency payment channels; customer support interactions; website usage and cookies; and any other interaction you have with jclub's Platform or communications.
If you have any questions about how jclub handles your personal data, or if you wish to exercise any of your data rights, please contact our Data Privacy contact at [email protected].
2 Definitions
For the purposes of this Privacy Policy, the following terms carry the meanings defined below:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person — including name, identification number, contact details, financial information, IP address, or any combination of data that could identify an individual. |
| "Data Subject" | The natural person whose personal data is being collected and processed — in the context of this Policy, primarily the registered Player or website visitor. |
| "Processing" | Any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, transmission, erasure, or destruction. |
| "Data Controller" | The entity that determines the purposes and means of processing personal data. jclub is the Data Controller for personal data collected through the Platform. |
| "Data Processor" | A third party that processes personal data on behalf of jclub under contractual instructions — for example, payment processors, KYC verification providers, or cloud storage providers. |
| "Consent" | Freely given, specific, informed, and unambiguous indication by the Data Subject that they agree to the processing of their personal data for a specified purpose. |
| "KYC" | Know Your Customer — the identity verification process requiring Players to submit valid identification documents to jclub, used for legal compliance and fraud prevention. |
| "Third Party" | Any person or entity other than the Data Subject, jclub, and persons authorised by jclub to process personal data under its direct authority. |
3 Data We Collect
jclub collects personal data through several channels during the course of your relationship with our Platform. The categories and specific data points we collect are set out below.
3.1 Registration Data
When you create a jclub Account, we collect the following information:
- Full legal name (as it appears on your government-issued identification)
- Date of birth (to verify eligibility — 21+ requirement)
- Residential address, including city, state, and postcode
- Email address (used as primary account identifier and for communications)
- Mobile phone number (used for OTP/2FA authentication and account alerts)
- Username and encrypted password credentials
- Preferred currency (Malaysian Ringgit / MYR by default)
3.2 Identity Verification (KYC) Data
As part of our mandatory KYC process, we collect and store:
- Scanned copy or photograph of a valid Malaysian identity document (MyKad/NRIC, Driver's Licence, or Passport)
- Proof of residential address — utility bill, bank statement, or official correspondence dated within the last 3 months
- A live selfie photograph holding the identity document
- Where required: bank account details, e-wallet account screenshots, or cryptocurrency wallet address to verify payment method ownership
3.3 Financial & Transaction Data
- Deposit and withdrawal transaction records including amounts in MYR, timestamps, payment method identifiers, and transaction reference numbers
- Payment method details: bank account numbers (partially masked), e-wallet account identifiers (Touch 'n Go, Boost, GrabPay), DuitNow/FPX reference data, and cryptocurrency wallet addresses
- Betting and gaming activity records: game titles played, wager amounts, win/loss records, bonus usage history
3.4 Technical & Usage Data
When you access the Platform, we automatically collect:
- IP address and approximate geolocation (country and city level)
- Device type, operating system, and browser type and version
- Session timestamps, page views, and navigation patterns within the Platform
- Cookie and similar tracking technology data (see Section 9)
- Login history and access logs
3.5 Communication Data
- Live chat transcripts and customer support email correspondence
- Feedback, complaints, and dispute records
- Responses to surveys or promotional communications
4 Legal Basis for Processing
jclub processes your personal data only where we have a valid legal basis to do so. The legal bases we rely upon are as follows:
| Legal Basis | When It Applies | Examples |
|---|---|---|
| Contractual Necessity | Processing is necessary to perform the contract between jclub and the Player — i.e., providing gaming services. | Account registration, payment processing, withdrawal execution, game participation records. |
| Legal Obligation | Processing is required to comply with applicable laws including anti-money laundering (AML) regulations, age verification requirements, and financial record-keeping obligations. | KYC identity verification, transaction monitoring, reporting obligations to competent authorities. |
| Legitimate Interests | Processing is necessary for jclub's legitimate business interests, provided these interests are not overridden by the Data Subject's rights. | Fraud detection and prevention, platform security, internal analytics to improve services, responsible gambling monitoring. |
| Consent | You have given explicit, freely withdrawable consent for a specific processing purpose not otherwise covered by the above bases. | Marketing communications, optional promotional emails, analytics cookies beyond strictly necessary. |
Where we process data on the basis of consent, you retain the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
5 How We Use Your Personal Data
jclub uses the personal data we collect for the following purposes:
5.1 Account Operation & Service Delivery
- Creating, managing, and securing your Account
- Processing deposits and withdrawals through Malaysian payment channels and cryptocurrency networks
- Delivering live dealer, slot, and sports betting services
- Communicating account-related notifications (deposits confirmed, withdrawal processed, security alerts)
5.2 Compliance & Legal Obligations
- Verifying your identity and age (21+ requirement) through our KYC process
- Monitoring transactions for anti-money laundering (AML) compliance
- Maintaining financial and transactional records as required by applicable regulations
- Reporting to competent authorities where legally required
5.3 Security & Fraud Prevention
- Detecting and preventing fraudulent activity, multi-accounting, bonus abuse, and unauthorized access
- Monitoring login activity and flagging anomalous behavior
- Enforcing self-exclusion restrictions and responsible gambling limits
5.4 Platform Improvement & Analytics
- Analysing aggregated usage patterns to improve Platform design, game selection, and performance
- Conducting internal research and statistical analysis using anonymised or pseudonymised data
5.5 Customer Support
- Responding to enquiries, complaints, and dispute resolution requests
- Maintaining records of communications for quality assurance and compliance purposes
5.6 Marketing Communications (Consent-Based Only)
Where you have expressly consented, jclub may send you promotional emails, bonus offers, and relevant updates about new games or features. You may withdraw consent for marketing communications at any time by contacting our support team at [email protected]. Opting out of marketing communications will not affect your account status or access to services.
6 Data Sharing & Disclosure
jclub does not sell, rent, or trade your personal data to third parties for their own commercial use. We share personal data only in the following strictly defined circumstances:
6.1 Service Providers (Data Processors)
We engage third-party service providers who process personal data on our behalf and under our instructions, bound by contractual data processing agreements. These include:
- Payment processors: Malaysian payment gateway operators facilitating DuitNow, FPX, e-wallet (Touch 'n Go, Boost, GrabPay), and bank transfer transactions
- KYC and identity verification providers: Third-party verification technology that validates identity documents and detects potential fraud
- Cloud infrastructure providers: Encrypted server hosting and data storage services
- Customer support platform providers: Live chat and ticketing software used to manage support interactions
- Analytics providers: Aggregated, anonymised Platform usage analytics — no personally identifiable data shared
6.2 Legal Authorities
jclub may disclose personal data to regulatory bodies, law enforcement agencies, courts, or other competent authorities where we are required or permitted to do so by applicable law — for example, in connection with AML investigations, fraud inquiries, or a valid court order.
6.3 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of jclub's business assets, your personal data may be transferred as part of the transaction. We will provide advance notice via your registered email address and ensure that the receiving entity is bound by obligations no less protective than those in this Policy.
7 Data Retention
jclub retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory obligations. Our standard retention periods are as follows:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account Registration Data | Duration of Account + 5 years after closure | Legal obligation and legitimate interests |
| KYC / Identity Documents | Duration of Account + 5 years after closure | AML compliance requirements |
| Financial Transaction Records | 7 years from transaction date | Financial record-keeping legal obligations |
| Gaming Activity Records | Duration of Account + 3 years after closure | Responsible gambling compliance and dispute resolution |
| Customer Support Correspondence | 3 years from last interaction | Legitimate interests (quality assurance and dispute records) |
| Technical / Usage Logs | 13 months from collection | Fraud prevention and security monitoring |
| Marketing Consent Records | Until consent is withdrawn + 3 years | Proof of lawful consent basis |
| Self-Exclusion Records | Duration of exclusion period + 5 years | Responsible gambling compliance |
Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised so that it can no longer be attributed to an identified individual. Data that is required for ongoing legal proceedings, regulatory investigations, or unresolved disputes will be retained until those matters are concluded.
8 Data Security
jclub implements a comprehensive set of technical, administrative, and physical security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our key security practices include:
- Encryption in transit: All data transmitted between your browser and the jclub Platform is encrypted using 256-bit TLS (Transport Layer Security). Look for the padlock icon in your browser address bar.
- Encryption at rest: Sensitive personal data — including KYC documents, financial records, and authentication credentials — is encrypted when stored on our servers.
- Access controls: Personal data access is restricted on a strict need-to-know basis. Staff who access personal data are bound by confidentiality obligations and receive regular data protection training.
- Two-factor authentication (2FA): Withdrawal transactions require 2FA verification, reducing the risk of unauthorized fund transfers even if login credentials are compromised.
- Intrusion detection and monitoring: Our infrastructure is monitored continuously for suspicious activity, unauthorized access attempts, and anomalous traffic patterns.
- Third-party security audits: We periodically engage independent security professionals to review platform security and identify vulnerabilities.
Despite these measures, no data transmission over the internet or electronic storage system is completely impenetrable. In the event of a data breach that is likely to result in risk to your rights and freedoms, jclub will notify affected individuals and relevant authorities in accordance with applicable legal requirements.
9 Cookies & Tracking Technologies
jclub uses cookies and similar tracking technologies (such as web beacons and local storage) to enable Platform functionality, maintain session security, analyze usage patterns, and deliver a personalized experience. This section explains our use of these technologies and your control options.
9.1 What Are Cookies?
Cookies are small text files placed on your device by a website when you visit it. They allow the website to remember your actions and preferences over time. Cookies do not contain executable code and cannot directly access other data on your device.
9.2 Categories of Cookies We Use
| Category | Purpose | Can Be Disabled? |
|---|---|---|
| Required for core Platform functionality — login session management, security tokens, CSRF protection. Without these, the Platform cannot function. | No — strictly necessary | |
| Collect aggregated, anonymised data about how visitors use the Platform — page views, session duration, navigation paths — to help us improve the user experience. | Yes — via cookie preferences | |
| Remember your preferences such as language settings, last-used payment method, and table game preferences to reduce repetitive selection. | Yes — may affect experience | |
| Used only where you have consented — may track visits across our Platform to understand which promotions are relevant to you. No data shared with third-party advertisers. | Yes — consent-based only |
9.3 Managing Your Cookie Preferences
You can manage or withdraw your consent for non-essential cookies at any time via your browser settings. Most browsers provide options to block or delete cookies. Note that disabling essential cookies will prevent the Platform from operating correctly. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.
10 Your Data Rights
As a Data Subject, you hold a set of rights in relation to your personal data processed by jclub. These rights are summarised below and may be exercised by contacting us at [email protected]. jclub will respond to all valid data rights requests within thirty (30) days of receipt.
You have the right to request a copy of the personal data jclub holds about you, along with information on how it is being processed. Requests will be fulfilled in a structured, commonly used, machine-readable format where technically feasible.
If your personal data is inaccurate or incomplete, you have the right to request that it be corrected. You can update basic account information (email, phone, address) directly from your Account settings, or contact support for changes to verified identity data.
You may request the deletion of your personal data where there is no legitimate legal basis for continued processing. Note that data subject to mandatory retention periods (e.g., AML compliance records — typically 5–7 years) cannot be erased until those periods expire.
You may request that jclub restricts the processing of your personal data in certain circumstances — for example, while you contest the accuracy of data we hold, or pending investigation of a complaint.
Where processing is based on your consent or a contract, and carried out by automated means, you have the right to receive your personal data in a structured, commonly used format, and to transmit that data to another controller.
You have the right to object to processing based on legitimate interests or for direct marketing purposes. Objections to direct marketing will be honoured immediately. Objections to other processing will be assessed against our legitimate interests and obligations.
Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time. This will not affect the lawfulness of processing that occurred before withdrawal.
To exercise any of these rights, please submit a written request to [email protected] from your registered email address. We may need to verify your identity before processing a data rights request. jclub will not charge a fee for reasonable data rights requests.
11 International Data Transfers
jclub's primary operations serve Malaysian players, and we endeavour to process personal data within secure infrastructure that maintains appropriate data protection standards regardless of geographic location.
In certain circumstances, personal data may be transferred to or processed by service providers operating in jurisdictions outside Malaysia — for example, cloud infrastructure providers or KYC verification technology partners. Where such transfers occur, jclub ensures that appropriate contractual safeguards are in place to protect your personal data to a standard equivalent to that applied within Malaysia.
Before engaging any third-party service provider that will process personal data outside Malaysia, jclub conducts a data transfer impact assessment and implements appropriate safeguards, which may include contractual clauses based on recognized international data transfer mechanisms.
12 Minors & Age Verification
jclub's Platform and all associated services are strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from persons under the age of 21. Age verification is conducted as part of the account registration process and through mandatory KYC documentation review.
If jclub discovers or has reasonable grounds to believe that a registered Account belongs to a person under 21, we will immediately suspend that Account, initiate an investigation, delete all personal data relating to that individual (subject to any mandatory retention obligations), and return any deposited funds to the original payment source after appropriate due diligence.
13 Amendments to This Policy
jclub reviews this Privacy Policy periodically and will update it as necessary to reflect changes in our data processing practices, legal obligations, or the services we provide. The "Last Updated" date at the top of this page reflects the date of the most recent revision.
Material changes to this Policy — meaning changes that significantly affect how we collect, use, or share your personal data — will be communicated to registered Players via email to your registered address and/or through a prominent notification on the Platform, at least fourteen (14) days before the changes take effect.
Your continued use of the Platform after the effective date of a revised Privacy Policy constitutes your acknowledgement of the changes. If you do not accept the revised Policy, you must cease using the Platform and may close your Account as described in our Terms & Conditions.
14 Contact Us & Data Privacy Enquiries
For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jclub, please contact us through the following channels:
For data rights requests, privacy concerns, and formal complaints:
[email protected]Please use the subject line: "Privacy Request – [Your Registered Email]"
Available 24/7 on the Platform for general enquiries. For formal data rights requests, written email correspondence is preferred to ensure a documented response trail.
jclub aims to respond to all data privacy enquiries within 5 business days and to fully resolve data rights requests within 30 calendar days of receipt. For further information about your rights under this Policy, please also refer to our Terms & Conditions and our Responsible Gambling policy.