Privacy Policy – jljlaaa

1.1 jljlaaa ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of all users ("you," "the Player," "data subject") who access or use the jljlaaa platform, including our website at https://jljlaaa.com and our mobile application (collectively, the "Platform").

1.2 This Privacy Policy describes the types of personal data we collect, the purposes for which we process it, the parties with whom we may share it, and the rights available to you as a data subject under Philippine law. It also explains how you can contact us to exercise those rights or raise a concern.

1.3 This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference and form part of the overall agreement between you and jljlaaa.

1.4 If you do not agree with any part of this Privacy Policy, you should not register an account or use the jljlaaa Platform. Continued use of the Platform following any update to this Policy constitutes your acceptance of the revised terms.

2.1 For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, jljlaaa acts as the personal information controller in respect of the personal data it collects and processes through the Platform.

2.2 As personal information controller, jljlaaa determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with applicable Philippine data privacy laws and regulations.

2.3 jljlaaa has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data privacy laws. You may contact the DPO using the contact details provided in Section 15 of this Policy.

3.1 jljlaaa collects the following categories of personal data from Players and prospective Players:

Identity & Contact Data

• Full legal name (first name, middle name, last name);
• Date of birth;
• Gender;
• Residential address (including barangay, city/municipality, province, and postal code);
• Email address;
• Philippine mobile number.

Verification & KYC Data

• Government-issued photo identification (e.g., Philippine passport, driver's license, SSS ID, UMID, PhilSys National ID);
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie or facial image submitted for identity verification purposes;
• Source of funds documentation where required by applicable regulations.

Financial Data

• Payment method details (e.g., GCash mobile number, PayMaya account reference, BPI/BDO/Metrobank account name);
• Transaction history, including deposit amounts, withdrawal amounts, and dates;
• Account balance information.

Gaming & Behavioral Data

• Game history, including games played, wager amounts, and outcomes;
• Session duration and frequency of play;
• Bonus and promotion usage history;
• Responsible gaming tool settings and self-exclusion records.

Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Unique device identifiers;
• Log data, including access times, pages viewed, and error reports.

Communications Data

• Records of communications between you and jljlaaa customer support;
• Marketing preferences and opt-in/opt-out records;
• Survey responses and feedback submitted voluntarily.

4.1 jljlaaa collects personal data through the following means:

4.2 Where jljlaaa collects personal data from third-party sources, we ensure that such collection is carried out in accordance with applicable data privacy laws and that the third party has a lawful basis for sharing the data with us.

5.1 jljlaaa processes your personal data for the following purposes:

5.2 jljlaaa will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing another lawful basis for processing.

6.1 Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, jljlaaa processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and provision of gaming services;
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC, AML, and responsible gaming obligations;
• Legitimate interests: Processing necessary for jljlaaa's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6.2 Where jljlaaa relies on legitimate interests as the legal basis for processing, we have conducted a balancing assessment to ensure that our interests do not override your fundamental rights and freedoms as a data subject.

7.1 jljlaaa does not sell, rent, or otherwise transfer your personal data to unaffiliated third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

Service Providers & Data Processors

jljlaaa engages trusted third-party service providers who process personal data on our behalf and under our instructions. These include:

• Payment processors (GCash, PayMaya, BPI, BDO, Metrobank) for transaction processing;
• Identity verification and KYC service providers;
• Fraud detection and cybersecurity service providers;
• Cloud hosting and infrastructure providers;
• Customer support platform providers;
• Analytics and platform performance monitoring providers.

All third-party processors are bound by data processing agreements that require them to process personal data only on jljlaaa's instructions and to implement appropriate security measures.

Regulatory & Law Enforcement Authorities

jljlaaa may disclose personal data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by applicable Philippine law, including but not limited to disclosures required under the Anti-Money Laundering Act (AMLA) and its amendments.

Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of jljlaaa's assets, personal data held by jljlaaa may be transferred to the acquiring entity. Players will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

8.1 jljlaaa uses cookies and similar tracking technologies on its website and mobile application to enhance your experience, maintain session security, and gather analytics data. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences (such as language settings and login status) to provide a more personalized experience.
• Analytics cookies: Collect aggregated, anonymized data about how Players use the Platform, helping us identify areas for improvement.
• Marketing cookies: Used only with your consent to deliver relevant promotional content within the jljlaaa Platform.

8.2 You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the service.

8.3 jljlaaa does not use third-party advertising cookies or allow external advertisers to place cookies on the Platform.

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

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in accordance with AML and regulatory record-keeping requirements;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine financial regulations;
• Gaming and behavioral data: Retained for the duration of the account relationship and for up to three (3) years following account closure;
• Customer support communications: Retained for up to three (3) years from the date of the communication;
• Marketing consent records: Retained for the duration of the consent and for up to two (2) years following withdrawal of consent.

9.2 Where personal data is no longer required for any lawful purpose, jljlaaa will securely delete or anonymize it in accordance with our data disposal procedures.

10.1 jljlaaa implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the jljlaaa Platform;
• Encryption of sensitive data at rest, including payment information and government ID data;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Multi-factor authentication for administrative access to systems containing personal data;
• Regular security assessments, vulnerability scanning, and penetration testing;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jljlaaa will notify the National Privacy Commission (NPC) and affected data subjects in accordance with the timeframes and requirements prescribed under the Data Privacy Act and NPC regulations.

10.3 While jljlaaa takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are also responsible for maintaining the security of your account credentials and should notify jljlaaa immediately if you suspect any unauthorized access to your account.

11.1 Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by jljlaaa:

11.2 To exercise any of the above rights, please contact jljlaaa's Data Protection Officer using the contact details provided in Section 15. We will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11.3 jljlaaa will not charge a fee for processing data subject requests unless the request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

11.4 jljlaaa may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties. You may be asked to provide a copy of a government-issued ID for this purpose.

12.1 jljlaaa's services are intended exclusively for adults aged 21 years and above, in accordance with Philippine gaming regulations. The Platform is not directed at, and does not knowingly collect personal data from, persons under the age of 21.

12.2 If jljlaaa becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage user will be returned to the payment source after verification.

12.3 If you are a parent or guardian and believe that your child has registered an account on jljlaaa, please contact our support team immediately using the contact details in Section 15.

13.1 jljlaaa primarily processes personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure and identity verification providers — may process data in jurisdictions outside the Philippines.

13.2 Where personal data is transferred outside the Philippines, jljlaaa ensures that appropriate safeguards are in place to protect your data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law;
• Transfers only to jurisdictions that have been assessed as providing an adequate level of data protection;
• Compliance with any cross-border data transfer requirements prescribed by the National Privacy Commission.

13.3 You may request further information about the safeguards applied to international data transfers by contacting jljlaaa's Data Protection Officer.

14.1 jljlaaa reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

14.2 Where changes to this Privacy Policy are material, jljlaaa will notify registered Players via email or an in-platform notification prior to the changes taking effect. For non-material changes, the updated Policy will be published on this page without separate notification.

14.3 Your continued use of the jljlaaa Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions.

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jljlaaa, please contact our Data Protection Officer:

15.2 jljlaaa will acknowledge receipt of all privacy-related inquiries within three (3) business days and will endeavor to resolve all complaints within fifteen (15) business days of receipt.

15.3 If you are not satisfied with jljlaaa's response to your privacy complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines.

15.4 For questions about your account, payments, or gaming services, please visit our FAQ page or contact our general support team.