Thanks for the report, we’ve pushed out a fix for this issue to ensure that jam pages follow the rules for pages that have “Disable new downloads & purchases” enabled.
Generally speaking, when you submit your game you should be giving permission to jam hosts (or judges) to access you game but we haven’t fully defined those permissions, so perhaps we’ll revisit in the future.
For now, if you have “Disable new downloads & purchases” then only key holders will be able to download files.