jljlee Privacy Policy — How We Protect Your Data

jljlee ("we," "us," "our") is committed to protecting the privacy and personal data of all individuals who use the jljlee platform accessible at jljlee.net (the "Platform"). This Privacy Policy has been prepared in compliance with the Data Privacy Act of 2012 (Republic Act 10173) of the Philippines and its Implementing Rules and Regulations, as well as applicable PAGCOR regulatory requirements.

This policy governs the collection, processing, storage, disclosure, and protection of personal data provided to or collected by jljlee in the course of operating the Platform. It applies to:

• Registered account holders who use the Platform to play games, make deposits, or request withdrawals;
• Individuals who browse jljlee.net without creating an account;
• Individuals who contact jljlee through live chat, email, or other support channels;
• Any other person whose personal data is processed by jljlee in connection with Platform operations.

Where this policy refers to "personal data," it means any information that identifies or could reasonably be used to identify a living natural person, whether alone or in combination with other data.

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, jljlee is the personal information controller responsible for the data collected and processed through the Platform.

All data processing activities conducted by jljlee are carried out in accordance with the principles of transparency, legitimate purpose, and proportionality as mandated by the Data Privacy Act and overseen by the National Privacy Commission (NPC) of the Philippines.

Where jljlee engages third-party processors to handle personal data on its behalf (for example, payment processors, identity verification services, or game providers), such processors are engaged under contractual arrangements that require them to process data only in accordance with jljlee's instructions and to maintain appropriate security standards.

jljlee collects the following categories of personal data in the course of providing its services:

jljlee does not intentionally collect sensitive personal data beyond what is necessary for regulatory compliance. Where sensitive data such as government ID numbers is collected, it is processed solely for identity verification and regulatory obligations.

jljlee collects personal data through the following means:

4.1 Directly From You

• Account registration forms — name, contact details, date of birth;
• KYC document upload — government ID, selfie, proof of address;
• Payment method registration — GCash number, bank account details;
• Customer support interactions — live chat, email correspondence;
• Responsible gaming tool submissions — deposit limit settings, self-exclusion requests.

4.2 Automatically Through Platform Use

• Log files recording your IP address, browser type, access times, and pages visited;
• Cookies and similar tracking technologies (see Section 10);
• Game session data — bet amounts, game outcomes, session duration;
• Device fingerprinting data used for fraud prevention and duplicate account detection.

4.3 From Third Parties

• Identity verification services that validate government ID authenticity;
• Payment processors that provide transaction confirmation data;
• Anti-fraud and AML screening services that may flag account activity against regulatory watchlists.

jljlee processes personal data only for defined, legitimate purposes. The specific purposes for which each category of data is used are set out below:

1. Account Management: To create, maintain, verify, and administer your jljlee Account, including identity verification and age confirmation (21+ requirement).
2. Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and card payment networks. Financial data is shared with relevant payment processors solely for this purpose.
3. Regulatory Compliance: To comply with PAGCOR licensing obligations, Philippine Anti-Money Laundering Act (AMLA) requirements, and the Data Privacy Act of 2012, including record-keeping and reporting obligations.
4. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, account takeovers, bonus abuse, and other prohibited conduct on the Platform.
5. Responsible Gaming: To administer responsible gaming tools including deposit limits, self-exclusion, and session alerts, and to identify patterns of play that may indicate problem gambling requiring intervention.
6. Customer Support: To respond to your inquiries, resolve disputes, process complaints, and maintain records of support interactions.
7. Service Improvement: To analyse Platform usage patterns in aggregate (anonymised) form to improve game selection, user experience, and platform performance.
8. Marketing Communications: Where you have provided consent, to send you information about jljlee promotions, bonuses, and new game releases. You may withdraw this consent at any time by contacting support.

Under the Data Privacy Act of 2012, jljlee relies on the following legal bases for processing personal data:

• Contractual Necessity: Processing required to fulfil the Terms and Conditions agreement — including account creation, identity verification, and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, and other applicable Philippine law — including KYC record-keeping and AMLA reporting.
• Legitimate Interests: Processing necessary for fraud prevention, Platform security, and responsible gaming monitoring, where jljlee's legitimate interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes such as marketing communications, where your specific prior consent has been obtained. Consent may be withdrawn at any time.

jljlee does not sell, rent, or trade your personal data. We share personal data with third parties only in the following circumstances and only to the extent necessary:

7.1 Service Providers and Processors

• Payment processors: GCash (Mynt), Maya (Voyager Innovations), BPI, BDO, Metrobank, Visa/Mastercard networks — for transaction processing;
• Identity verification providers: For KYC document authenticity validation;
• Game providers: Evolution, Pragmatic Play, NetEnt, Play'n GO — limited game session data for game integrity and audit purposes;
• Customer support platform providers: Live chat and ticketing system operators — for support service delivery;
• Hosting and infrastructure providers: Cloud and server providers who process data in the course of providing hosting services.

7.2 Regulatory and Legal Disclosure

• PAGCOR or other Philippine regulatory authorities, where disclosure is required by law, regulation, or lawful authority request;
• The Anti-Money Laundering Council (AMLC) where transaction reporting is required under the Anti-Money Laundering Act;
• Law enforcement authorities, where disclosure is required by court order or lawful request.

jljlee implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data it processes. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your device and jljlee servers is protected using 256-bit SSL/TLS encryption;
• Encryption at rest: Sensitive personal data stored on jljlee systems is encrypted at rest using industry-standard algorithms;
• Password security: Account passwords are stored using one-way cryptographic hashing — jljlee staff cannot access your actual password;
• Access controls: Access to personal data systems is restricted to authorised personnel on a need-to-know basis, with access logs maintained;
• Two-factor authentication: Available for player accounts and enforced for administrative system access;
• Regular security assessments: jljlee conducts periodic security reviews of its data processing infrastructure;
• Staff training: All staff who handle personal data receive data privacy and security training.

Notwithstanding these measures, no security system is impenetrable. In the event of a personal data breach, jljlee will follow the breach notification procedures required by the Data Privacy Act of 2012, including notification to the National Privacy Commission and affected data subjects where required.

jljlee retains personal data only for as long as necessary to fulfil the purposes for which it was collected, and in compliance with applicable legal and regulatory retention requirements.

Following the expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised in accordance with jljlee's data disposal procedures.

jljlee uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function — session management, authentication, and security. These cannot be disabled without preventing Platform use.
• Functional Cookies: Remember your preferences, such as language and display settings, to improve your experience across sessions.
• Analytics Cookies: Collect anonymised data about how players navigate the Platform to help jljlee identify and resolve usability issues and improve game discovery.
• Fraud Prevention Cookies: Used alongside device fingerprinting to detect and prevent duplicate account creation and fraudulent activity.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair Platform functionality. jljlee does not use third-party advertising or tracking cookies for cross-site advertising purposes.

As a data subject under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data processed by jljlee:

1. Right to Be Informed: You have the right to know how your personal data is collected, processed, and used — which is the purpose of this Privacy Policy.
2. Right to Access: You may request a copy of the personal data jljlee holds about you, along with information about how it is being processed.
3. Right to Correction: You may request that inaccurate, incomplete, or outdated personal data be corrected or updated. Basic account details can be updated via account settings; KYC data corrections require support assistance.
4. Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to applicable legal retention requirements that override this right.
5. Right to Object: You may object to the processing of your personal data where that processing is based on legitimate interests, including objection to direct marketing communications.
6. Right to Data Portability: You may request that personal data you have provided to jljlee be delivered to you in a structured, commonly used, machine-readable format.
7. Right to Lodge a Complaint: If you believe jljlee has processed your personal data in violation of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The jljlee Platform is strictly intended for individuals who are 21 years of age or older, in compliance with PAGCOR regulations governing online gambling in the Philippines. jljlee does not knowingly collect personal data from persons under the age of 21.

Age verification is conducted during account registration and KYC review. Any account found to belong to a person under 21 years of age will be immediately suspended and closed. Any personal data collected from an underage individual will be securely deleted, and any balance held in the account will be returned through the registered payment method.

If you have reason to believe that a person under 21 has registered an account on the jljlee Platform, please contact our support team immediately via live chat or at [email protected] so that we can take appropriate action.

In the course of operating the jljlee Platform, personal data may be transferred to and processed by servers or service providers located outside the Philippines. Such transfers occur primarily in connection with:

• Cloud hosting and content delivery infrastructure;
• International game providers whose backend systems process game session data;
• International payment network processors.

All cross-border transfers of personal data are conducted in accordance with the Data Privacy Act of 2012 and NPC issuances on cross-border data flows. jljlee ensures that any recipient of personal data outside the Philippines provides at minimum an equivalent level of data protection to that required under Philippine law, through contractual obligations, adequacy assessments, or other lawful transfer mechanisms.

jljlee may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, jljlee will:

• Publish the updated policy on this page with a revised "Last Updated" date;
• Display a notification within the Platform at your next login where the changes are significant;
• Where required by law, seek fresh consent for new processing activities.

The version of this policy published on this page at any given time constitutes the current and operative version. We encourage you to review this policy periodically to stay informed about how jljlee protects your data.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jljlee, please contact us through the following channels:

• Live Chat: Available 24/7 on-site — average response time under 5 minutes. Tagalog-speaking agents available at all times.
• Email: [email protected] — data privacy requests will be acknowledged within 3 business days and resolved within 30 days.

If you believe that jljlee has handled your personal data in a manner inconsistent with the Data Privacy Act of 2012 and your rights have not been adequately addressed through our internal process, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.