jlll Privacy Policy

This Privacy Policy ("Policy") describes how jlll ("jlll," "we," "us," or "our") collects, uses, stores, and discloses personal information obtained from individuals ("you," "Player," or "User") who access or use the jlll website, mobile platform, games, and all associated services (collectively, the "Platform").

jlll operates in the Philippines and is committed to complying with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). This Policy reflects those obligations and our genuine commitment to protecting your personal data.

This Policy should be read alongside our Terms & Conditions, which govern your use of the jlll Platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

jlll collects only the personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by applicable gaming regulations (for example, self-exclusion records maintained for responsible gaming purposes).

jlll collects your personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity and fraud-check data received from payment processors (e.g., GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, and anti-money laundering screening services.
• Regulatory sources: Information received from Philippine regulatory authorities in connection with licensing, compliance, or investigation requirements.

jlll uses your personal data for the following purposes:

• To create, verify, and manage your jlll account, including processing your jlll Login credentials securely.
• To process deposits and withdrawals through your chosen Philippine payment method.
• To verify your identity and age (21+) in compliance with applicable gaming regulations.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited conduct.
• To provide customer support and resolve disputes or complaints.
• To send you transactional communications such as deposit confirmations, withdrawal notifications, and OTPs.
• To send you promotional communications about jlll offers and games — only where you have consented or where we have a legitimate interest to do so, and always with an easy opt-out mechanism.
• To monitor your gaming activity for responsible gaming purposes, including identifying patterns that may indicate problem gambling.
• To improve the Platform's performance, security, and user experience through analytics.
• To comply with our legal and regulatory obligations under Philippine law.

jlll processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with Philippine laws and regulations, including anti-money laundering obligations, age verification requirements, and regulatory reporting.
• Legitimate interests: Processing necessary for jlll's legitimate business interests, such as fraud prevention, Platform security, and service improvement, where those interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and certain cookie-based tracking activities.

jlll does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and card networks, to facilitate deposits and withdrawals.
• Identity verification providers: Third-party KYC and age-verification services used to confirm your identity and comply with regulatory requirements.
• Fraud prevention and AML services: Screening providers used to detect and prevent financial crime.
• IT and platform service providers: Cloud hosting, data analytics, and cybersecurity vendors who process data on our behalf under strict contractual obligations.
• Regulatory and law enforcement authorities: Philippine government agencies, including the National Privacy Commission, where disclosure is required by law or court order.
• Professional advisers: Lawyers, auditors, and insurers, where necessary for the conduct of jlll's business.

Any third party that processes personal data on jlll's behalf is required to do so only in accordance with our instructions and applicable data protection law.

jlll 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 law. In general:

• Account and identity data is retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Support communications are retained for up to three (3) years from the date of the interaction.
• Marketing consent records are retained for as long as you remain a registered jlll player or until you withdraw your consent, whichever is earlier.

When personal data is no longer required, jlll will securely delete or anonymise it in accordance with our data retention and disposal procedures.

jlll uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how the Platform is used.

The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security features. These cannot be disabled.
• Performance cookies: Used to collect anonymised analytics data about how Players use the Platform, helping us identify and fix issues.
• Functional cookies: Used to remember your preferences, such as language settings and display options.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jlll Platform.

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jlll Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls ensuring that only authorised jlll personnel can access personal data, and only to the extent necessary for their role.
• Regular security audits, penetration testing, and vulnerability assessments.
• Multi-factor authentication for internal systems that process personal data.
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC requirements.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jlll:

• Right to be informed: The right to know what personal data jlll holds about you and how it is being used — which is the purpose of this Policy.
• Right of access: The right to request a copy of the personal data jlll holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to jlll's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the jlll Data Protection Officer via the live chat support function on the Platform or by email at [email protected]. We will respond to all verified requests within fifteen (15) business days.

The jlll Platform is strictly intended for individuals who are 21 years of age or older. jlll does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from an individual under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on the jlll Platform, please contact our support team immediately via live chat so we can investigate and take appropriate action.

The jlll Platform may contain links to third-party websites or services, such as payment provider portals. jlll is not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party service you access through the Platform before providing any personal information.

jlll may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. When a material change is made, we will notify registered Players via their registered mobile number or email address, or by displaying a prominent notice on the Platform.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the jlll Platform following the effective date of any update constitutes your acknowledgement of the revised Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or jlll's handling of your personal data, please contact our Data Protection Officer:

• Live Chat: Available 24/7 via the jlll Platform support function.
• Email: [email protected]
• General Support: [email protected]

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been respected.