Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how jljl23 ("jljl23", "we", "us", "our") collects, uses, stores, discloses, and protects the personal data of individuals ("you", "Player", "User") who access or use the jljl23 online casino platform at jljl23.net, including all associated sub-pages, mobile interfaces, APIs, and ancillary services (collectively, the "Platform").

jljl23 is committed to protecting the privacy and personal data of all Filipino players in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and the applicable issuances of the National Privacy Commission ("NPC") of the Philippines.

This Policy should be read alongside jljl23's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. Together, these documents form the complete agreement governing your use of the jljl23 Platform.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, jljl23 acts as the personal information controller ("PIC") in respect of the personal data it collects and processes through the Platform. This means jljl23 is responsible for determining the purposes and means of processing your personal data and for ensuring that such processing is conducted lawfully, fairly, and transparently.

jljl23 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with applicable data privacy laws and this Policy. You may contact the DPO directly using the contact details set out in Section 15 of this Policy.

3 Data We Collect

jljl23 collects personal data through several channels — directly from you during registration and use of the Platform, automatically through your interaction with the Platform, and in limited cases from third-party payment and identity verification providers. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name (as it appears on a Philippine government-issued ID)
• Date of birth (for mandatory 21+ age verification)
• Residential address within the Philippines (barangay, city/municipality, province)
• Valid email address
• Philippine mobile number
• Government-issued ID details (ID type, ID number) — collected during KYC verification
• Username and encrypted password

3.2 Financial & Transaction Data

• GCash or PayMaya mobile wallet details
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) for wire transfers
• Deposit and withdrawal transaction history
• Account balance records
• Bonus and promotional credit history

3.3 Gaming Activity Data

• Game session history (games played, duration, wager amounts, outcomes)
• Sports betting selections and results
• Responsible gaming settings (deposit limits, session reminders, self-exclusion status)

3.4 Technical & Usage Data

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Pages visited, clicks, and navigation paths within the Platform
• Session timestamps and duration
• Cookie identifiers and similar tracking data (see Section 7)

3.5 Communications Data

• Content of messages sent to jljl23 customer support via live chat or email
• Records of promotional communications you have opted into or out of
• Feedback, survey responses, and complaint records

4 How We Use Your Data

jljl23 processes your personal data only for specific, legitimate purposes. The table below sets out the primary purposes for which your data is used and the type of data involved:

jljl23 does not use your personal data for automated decision-making that produces significant legal effects without human review. Where profiling is used — for example, to personalise game recommendations or identify responsible gaming risk signals — a human review process is available upon request.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, jljl23 relies on one or more of the following lawful bases when processing your personal data:

• Contractual necessity: Processing is required to fulfil our obligations under the jljl23 Terms & Conditions — for example, verifying your identity, processing transactions, and providing access to games.
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including the Anti-Money Laundering Act (AMLA), applicable PAGCOR regulations, and the National Privacy Commission's data security requirements.
• Legitimate interests: Processing is necessary for jljl23's legitimate business interests — such as fraud prevention, Platform security, and responsible gaming monitoring — provided those interests are not overridden by your rights and freedoms.
• Consent: For processing that is not strictly necessary — such as sending you personalised promotional communications — jljl23 will rely on your freely given, specific, and informed consent, which you may withdraw at any time without detriment.

6 Data Sharing & Disclosure

6.1 Service Providers

jljl23 shares personal data with trusted third-party service providers who assist in the operation of the Platform. These include payment processors (GCash, PayMaya, BPI, BDO, InstaPay, PESONet), identity verification providers, game software suppliers, cloud hosting providers, and customer support platform operators. All service providers are contractually required to process your data only on jljl23's documented instructions and to implement appropriate technical and organisational security measures.

6.2 Regulatory & Legal Disclosure

jljl23 may disclose your personal data to Philippine government authorities, regulatory bodies (including PAGCOR and the Anti-Money Laundering Council), law enforcement agencies, and courts where jljl23 is legally obligated to do so — for example, pursuant to a court order, regulatory investigation, or mandatory suspicious transaction report under the AMLA.

6.3 No Sale of Data

jljl23 does not sell, rent, lease, or otherwise transfer your personal data to third parties for their own independent marketing, advertising, or commercial purposes. Your data is yours — it exists on the jljl23 Platform to support your gaming experience, not as a commercial commodity.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of jljl23's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified via email or a prominent Platform notice prior to any such transfer, and the acquiring entity will be required to honour the commitments made in this Privacy Policy.

7 Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit the jljl23 Platform. They allow the Platform to recognise your device, remember your session and preferences, and collect usage analytics. jljl23 also uses similar technologies such as web beacons and local storage for session management and security purposes.

7.2 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. They cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming configurations to improve your experience.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform — such as which game categories are most visited — to help jljl23 improve performance and content.
• Marketing Cookies: Used only with your consent to deliver relevant promotional content within the jljl23 Platform. jljl23 does not use third-party advertising networks for cross-site tracking.

7.3 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies via the browser's privacy or settings menu. Note that disabling strictly necessary cookies may impair your ability to log in or use certain Platform features. Detailed instructions for managing cookies are available in the help section of your specific browser.

8 Data Retention

jljl23 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply as a general guide:

• 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 Philippine AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years in accordance with AMLA obligations and applicable tax regulations.
• Gaming activity logs: Retained for three (3) years for fraud prevention, dispute resolution, and responsible gaming monitoring purposes.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent and for one (1) year thereafter as evidence of the prior consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

9 Data Security

jljl23 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jljl23 servers.
• AES-256 encryption for sensitive data at rest, including financial details and government ID information.
• Multi-factor authentication options for player accounts and mandatory multi-factor authentication for all jljl23 staff with access to personal data systems.
• Role-based access controls ensuring that only authorised personnel with a demonstrated need can access personal data.
• Regular penetration testing and independent security audits of Platform infrastructure.
• Secure data centres with physical access controls, CCTV monitoring, and environmental safeguards.
• Formal data breach detection, response, and notification procedures in line with NPC Circular 16-03.

10 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jljl23:

• Right to be Informed: The right to be notified of how your personal data is collected, used, and stored — which this Privacy Policy fulfils.
• Right to Access: The right to request a copy of all personal data jljl23 holds about you, together with information about how it is being processed.
• Right to Correction: The right to request correction of any inaccurate, incomplete, or outdated personal data jljl23 holds about you.
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful — subject to jljl23's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on jljl23's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format, and to request transmission of that data to another controller where technically feasible.
• Right to Damages: The right to seek compensation for any damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please submit a written request to jljl23's Data Protection Officer using the contact details in Section 15. jljl23 will acknowledge your request within five (5) business days and aim to fulfil verified requests within thirty (30) calendar days.

11 Children's Privacy

The jljl23 Platform is strictly intended for adults aged 21 years and above, in accordance with applicable Philippine gaming regulations. jljl23 does not knowingly collect personal data from individuals under the age of 21. If jljl23 discovers that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated account will be closed without delay.

If you are a parent or guardian and believe that your child has registered on the jljl23 Platform, please contact our support team immediately at [email protected] so that we can take appropriate action.

12 Third-Party Links

The jljl23 Platform does not contain links to third-party websites or platforms beyond those necessary to facilitate payment processing through established Philippine payment providers. In the limited instances where payment redirects occur — such as a GCash or PayMaya authentication screen — those interactions are governed by the respective third-party provider's privacy policy. jljl23 is not responsible for the data practices of any third-party platforms or services outside the jljl23 Platform.

13 International Data Transfers

jljl23 primarily stores and processes personal data within data centres located in or serving the Philippines and the Asia-Pacific region. In certain operational circumstances — such as the use of internationally hosted game software platforms or cloud infrastructure — personal data may be transferred to and processed in countries outside the Philippines.

Where such international transfers occur, jljl23 ensures that appropriate safeguards are in place to protect your personal data to a standard at least equivalent to the protections afforded under the Philippine Data Privacy Act of 2012. These safeguards may include contractual data processing agreements incorporating the NPC's standard contractual clauses, or reliance on the recipient country's adequacy status as recognised by the NPC.

You may request details of the specific safeguards applied to any international transfer of your personal data by contacting the Data Protection Officer as described in Section 15.

14 Policy Updates

jljl23 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable Philippine law, NPC guidance, Platform functionality, or business practices. Where changes are material — meaning they significantly affect how jljl23 processes your personal data or your rights in relation to that data — jljl23 will notify you via your registered email address and/or a prominent notice on the Platform at least fourteen (14) days before the changes take effect.

Minor, non-material updates — such as clarifying language or correcting typographic errors — may be made without prior notice, and the revised Policy will be effective immediately upon publication. The "Last Reviewed" date at the top of this Policy will always reflect the most recent revision date.

Your continued use of the jljl23 Platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the revised Policy. If you do not agree with material changes, you have the right to close your account and request deletion of your personal data, subject to jljl23's legal retention obligations.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or jljl23's processing of your personal data, please contact our Data Protection Officer through the following channels:

• Email: [email protected] — please include "Privacy / DPO Request" in the subject line
• Live Chat: Available 24 hours a day, 7 days a week, directly within the jljl23 Platform
• Response Time: jljl23 acknowledges all privacy-related requests within five (5) business days and aims to resolve them within thirty (30) calendar days
• Operating Timezone: Philippine Standard Time (PST, UTC+8)

If you are not satisfied with jljl23's response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent government body responsible for administering and enforcing the Philippine Data Privacy Act of 2012.