Privacy Policy — j118 Platform

This Privacy Policy (the "Policy") is published by j118 (the "Operator", "Platform", "we", "us" or "our"), the operator of the online gaming platform accessible at j118.cam (the "Website" or "Platform"). This Policy describes how j118 collects, uses, stores, discloses and protects the personal data of individuals who access or use the Platform ("Users", "you" or "your").

j118 is an English-language platform designed for users in Pakistan. We recognise the expectations Pakistani users hold regarding the handling of their personal information and we are committed to meeting those expectations with transparency and rigour. This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform as a whole.

By registering an account, making a deposit, or otherwise using the j118 Platform, you confirm that you have read this Policy and that you consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must not use the j118 Platform.

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

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, directly or indirectly.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer or deletion.
• "Data Controller" means j118, the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" means a third-party service provider that processes Personal Data on behalf of j118, under contractual instruction.
• "KYC" means Know Your Customer — the identity verification procedures required by j118 under its applicable licensing and AML obligations.
• "AML" means Anti-Money Laundering — regulatory obligations designed to detect and prevent financial crime.
• "Cookies" means small data files stored on your device by the Platform to maintain sessions, remember preferences and collect usage analytics.
• "Sensitive Data" means a subset of Personal Data that warrants heightened protection — including government-issued identification numbers (e.g., CNIC), payment credentials and, where relevant, health information disclosed in the context of responsible gambling tools.

j118 collects the following categories of Personal Data from Users:

Where you supply payment method references associated with Pakistani financial services — such as a registered mobile number linked to Easypaisa or JazzCash, or an account number at HBL, UBL, Meezan Bank or Bank Alfalah — j118 collects and stores only the minimum information required to process or verify your transaction. j118 does not have integration access to these institutions' internal systems. These references are provided by you for verification purposes only.

j118 collects Personal Data through the following means:

• Direct provision: Data you provide when registering an account, completing KYC, making a deposit or withdrawal, contacting support, or submitting a complaint.
• Automated collection: Technical and usage data collected automatically when you access the Platform, via server logs, cookies, and device detection technologies.
• Third-party sources: Identity verification data returned by KYC/AML service providers during the verification process; fraud risk signals from fraud prevention partners; payment status data from payment processing providers.
• Voluntary disclosure: Information you choose to provide to support agents during live chat or email correspondence, including any disclosures related to problem gambling or self-exclusion requests.

j118 processes your Personal Data only where a valid legal basis exists. The applicable bases are:

• Contract performance: Processing necessary to fulfil the agreement between you and j118 as described in the Terms & Conditions. This covers account creation, deposit processing, game provision and withdrawal handling.
• Legal obligation: Processing required to comply with the Operator's applicable licensing conditions, KYC obligations, AML procedures and any other regulatory requirements under the licensing jurisdiction.
• Legitimate interests: Processing necessary for j118's legitimate interests where these are not overridden by your rights. This includes fraud prevention, platform security, abuse detection and service improvement analytics.
• Consent: Where you have actively opted in to specific processing activities — such as receiving promotional communications — consent is the applicable legal basis. You may withdraw consent at any time without affecting the lawfulness of prior processing.

j118 does not use your Personal Data for automated decision-making that produces legal or similarly significant effects without human oversight, except where required by applicable law or explicitly disclosed in advance.

j118 does not sell, rent or trade your Personal Data to third parties for marketing purposes under any circumstances. Your data may be shared only in the following limited circumstances:

• Service Providers (Data Processors): Third-party organisations engaged by j118 to deliver specific functions — including KYC/identity verification providers, payment processing partners, fraud detection services, cloud hosting providers and customer support platform operators. All such providers are contractually obligated to process your data solely for the purposes j118 has authorised, and to maintain appropriate security standards.
• Regulatory and Legal Disclosure: Where j118 is required by applicable law, court order, or the instructions of a competent regulatory authority under its licensing jurisdiction to disclose Personal Data, we will comply. Where legally permissible, we will notify you of such disclosure.
• Fraud Prevention Networks: j118 may share data with industry fraud prevention bodies or shared risk intelligence networks where required to detect, prevent or report fraud, money laundering or other financial crime.
• Business Transfers: In the event of a merger, acquisition or sale of all or part of j118's business, your Personal Data may be transferred to the successor entity, subject to equivalent privacy protections. You will be notified of any such transfer where practicable.

j118 uses cookies and similar technologies (collectively "Cookies") on the Platform. Cookies are small data files placed on your device that serve the following functions:

Essential cookies are necessary for the Platform to function and cannot be disabled without impairing your ability to use core features. All other cookie types may be managed through your browser settings. Disabling performance or functional cookies will not prevent you from using the Platform but may affect your experience.

Most modern browsers allow you to review, delete or block cookies. Please refer to your browser's help documentation for instructions. Note that clearing cookies will log you out of your current session and may reset your saved preferences.

j118 retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes and enforce our agreements. The following indicative retention periods apply:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping obligations under applicable licensing requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Support and Communications Data: Retained for up to three (3) years from the date of the relevant communication, unless required for longer in connection with an ongoing dispute or investigation.
• KYC Documentation: Retained for the duration of the account plus a minimum of five (5) years post-closure.
• Marketing Consent Records: Retained until consent is withdrawn and for a reasonable period thereafter for compliance evidence purposes.
• Technical and Usage Data: Anonymised or deleted within twelve (12) months where it is no longer required for security or analytics purposes.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with j118's internal data lifecycle management procedures.

Subject to applicable data protection law and the limitations imposed by j118's legal and regulatory obligations, you have the following rights in respect of your Personal Data:

To exercise any of the rights above, please contact j118 support using the details in Section 15. We will respond to all valid requests within a reasonable timeframe in accordance with applicable law. We may need to verify your identity before processing your request.

j118 implements technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration, loss or destruction. Key measures include:

• HTTPS/SSL Encryption: All data transmitted between your device and j118.cam is encrypted using TLS (Transport Layer Security). This protects your credentials and financial data from interception on shared or public networks — relevant for players accessing j118 via mobile data networks across Karachi, Lahore, Islamabad and other Pakistani cities.
• Credential Security: Account passwords are stored in hashed form using industry-standard algorithms. j118 staff do not have access to your plaintext password at any time.
• Access Controls: Internal access to Personal Data is restricted to authorised personnel on a strict need-to-know basis. All access is logged and subject to periodic review.
• Fraud Monitoring: Automated systems monitor for unusual account activity, login anomalies and transaction patterns indicative of account compromise or fraud.
• Incident Response: j118 maintains an incident response procedure for data security breaches. Where a breach is likely to result in risk to Users, we will notify affected individuals and relevant regulatory authorities as required by applicable law.

While j118 employs robust security practices, no internet-based service can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for promptly notifying j118 if you suspect unauthorised access to your account.

j118 operates as an international online platform. Your Personal Data may be transferred to and processed in countries other than Pakistan, including the jurisdiction(s) in which j118 holds its applicable operating license and in which its service providers are established.

Where Personal Data is transferred internationally, j118 takes steps to ensure that appropriate safeguards are in place — such as contractual obligations on data processors — to maintain a level of protection consistent with this Policy.

By using the j118 Platform, you acknowledge and consent to the transfer of your Personal Data to jurisdictions outside Pakistan as described in this section. This does not affect your rights under this Policy.

The j118 Platform is intended exclusively for adults aged 18 years and over, or the higher minimum age required by the applicable operator/license jurisdiction. j118 does not knowingly collect Personal Data from individuals under this age.

If j118 becomes aware that Personal Data has been collected from an individual below the applicable minimum age, that data will be deleted from our systems as promptly as practicable and the associated account will be closed. If you believe a minor has registered on j118, please contact us immediately using the details in Section 15.

The j118 Platform may include references to or integrations with third-party services — for example, game content supplied by third-party studios, payment processing gateways, or customer support tools. Where you interact with these third-party components, you may be subject to those third parties' own privacy policies in addition to this Policy.

j118 does not control and is not responsible for the data practices of third-party service providers beyond the contractual obligations j118 imposes on them as Data Processors. We encourage you to review the privacy policies of any third-party services with which you interact.

Specifically regarding payment service references: payment brand names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced as familiar Pakistani payment contexts. j118 does not direct or control the data practices of these institutions. Any data you provide directly to a payment provider is subject to that provider's own privacy policy, not this one.

j118 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or regulatory requirements. All changes will be published at j118.cam/privacy-policy with a revised "Last Updated" date at the top of the document.

Where changes are material — for example, a significant change to the purposes for which we process your data or the categories of third parties with whom we share it — j118 will endeavour to notify registered Users via email or in-platform notification where practicable prior to the changes taking effect.

Your continued use of the j118 Platform following publication of an updated Policy constitutes your acceptance of the changes. If you do not agree with the updated Policy, you must cease using the Platform and may close your account in accordance with our Terms & Conditions.

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to report a privacy concern, please contact j118 using the details below. All communications should be submitted in English.

j118 aims to respond to all privacy-related enquiries within a reasonable timeframe. Response times may vary depending on the complexity of the request and current query volume. Urgent security concerns — such as suspected unauthorised account access — should be clearly marked as urgent in your communication.

For general platform support, account queries and non-privacy matters, please visit the FAQ page or contact the j118 support team through the standard support channel.