jljlee Privacy Policy – How We Handle Your Personal Data

1 Who We Are and Scope of This Policy

jljlee is an online gaming platform operating under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). jljlee acts as the personal information controller ("PIC") for the personal data collected through the jljlee platform. As PIC, jljlee is responsible for determining the purposes and means of processing your personal data.

This Policy applies to:

• All registered jljlee account holders, including players with active, dormant, or suspended accounts
• Visitors to the jljlee.club website who have not yet registered an account
• Individuals who have submitted personal data as part of a registration process that was not completed
• Former account holders whose data is retained in accordance with legal and regulatory requirements

This Policy does not apply to third-party websites or services linked from the jljlee platform. jljlee is not responsible for the privacy practices of any third party.

2 Personal Data We Collect

jljlee collects personal data through the following channels: account registration, identity verification, platform usage, payment transactions, customer support interactions, and automated technical collection. The categories of personal data we collect include:

jljlee does not collect sensitive personal information (as defined under RA 10173) beyond what is strictly required for identity verification, responsible gaming compliance, and PAGCOR reporting obligations.

3 How We Use Your Personal Data

jljlee processes your personal data for the following purposes:

• Account Management: To create, manage, and maintain your jljlee account, including authenticating your identity on login and managing account settings.
• Identity Verification (KYC): To verify that you meet the age and eligibility requirements for gaming on the jljlee platform, as required by PAGCOR and Philippine law.
• Payment Processing: To facilitate deposits and withdrawals through GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels. Transaction data is shared with payment processors solely for the purpose of completing the transaction.
• Regulatory Compliance: To fulfill jljlee's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160, as amended), and related Philippine regulations, including transaction reporting and suspicious activity monitoring.
• Responsible Gaming: To monitor gaming behavior for indicators of problem gambling, enforce player-set deposit and session limits, and administer self-exclusion requests in accordance with PAGCOR responsible gaming standards.
• Platform Security: To detect and prevent fraud, unauthorized access, collusion, money laundering, and other prohibited conduct on the jljlee platform.
• Customer Support: To respond to your inquiries, complaints, and requests submitted via live chat, email, or other support channels.
• Service Improvement: To analyze aggregated, anonymized usage data for the purpose of improving the jljlee platform, game library, and user experience. Individual player data is not used for this purpose without further anonymization.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent and have not subsequently opted out. You may withdraw marketing consent at any time through your account settings.

4 Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform the jljlee Terms and Conditions agreement with you, including account management and payment processing.
• Legal Obligation: Processing necessary to comply with PAGCOR licensing requirements, the Anti-Money Laundering Act, the Tax Code of the Philippines, and other applicable laws.
• Legitimate Interest: Processing for fraud prevention, platform security, and responsible gaming monitoring — where jljlee's legitimate interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and optional features, where you have provided freely given, specific, and informed consent. Consent may be withdrawn at any time.

5 Sharing Your Personal Data

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

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers — for the sole purpose of processing your transactions. These parties process data as independent data controllers under their own privacy policies.
• Identity Verification Providers: Third-party KYC technology providers engaged by jljlee to assist with document verification and biometric matching. These providers act as data processors under jljlee's instructions and are bound by data processing agreements.
• Game Content Providers: Game providers whose software operates within the jljlee platform may receive limited technical session data (such as a session token and bet value) necessary to deliver game results. They do not receive your identity or financial data.
• PAGCOR and Regulatory Authorities: As required by Philippine gaming law and PAGCOR licensing conditions, jljlee reports certain gaming activity and player data to PAGCOR. Compliance with AMLC (Anti-Money Laundering Council) reporting obligations may also require disclosure of transaction data.
• Law Enforcement and Courts: Where required by a valid legal order, court order, or subpoena from a Philippine court or government authority.

6 Data Retention

jljlee retains personal data for as long as necessary to fulfill the purposes set out in this Policy and to comply with legal and regulatory obligations. Specific retention periods include:

• Account and Identity Data: Retained for the duration of the account and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AMLA record-keeping obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with the AMLA implementing rules.
• Gaming Activity Data: Retained for five (5) years for regulatory compliance; aggregated anonymized data may be retained indefinitely for analytics purposes.
• Customer Support Correspondence: Retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of consent plus three (3) years to demonstrate compliance in the event of a complaint.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized using industry-standard methods.

7 Cookies and Tracking Technologies

The jljlee platform uses cookies and similar technologies to operate the platform, maintain your session, and analyze usage patterns. The types of cookies used include:

• Strictly Necessary Cookies: Required for the platform to function. These include session cookies that keep you logged in during a gaming session. They cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, game lobby view preferences, and responsible gaming settings.
• Analytics Cookies: Collect anonymized data about how players navigate the jljlee platform, which games are most visited, and where users encounter difficulties. This data is used to improve the platform. Analytics cookies require your consent and can be disabled.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect platform functionality. jljlee does not use third-party advertising or retargeting cookies.

8 Security Measures

jljlee implements a layered security architecture to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Technical and organizational measures in place include:

• TLS 1.2 or higher encryption for all data in transit
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Multi-factor authentication for all internal administrative systems
• Regular penetration testing and vulnerability assessments by qualified third-party security firms
• 24/7 automated anomaly detection and security monitoring
• Documented incident response procedures aligned with NPC notification requirements

9 Your Rights Under the Data Privacy Act (RA 10173)

As a data subject under Philippine law, you have the following rights with respect to your personal data held by jljlee:

• Right to be Informed: The right to be told that your personal data is being collected and how it will be processed — which this Policy fulfills.
• Right to Access: The right to request a copy of the personal data jljlee holds about you. jljlee will respond to verified access requests within 15 business days.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You may update most account information directly through your jljlee account settings. For KYC-related corrections, contact customer support.
• Right to Erasure: The right to request deletion of your personal data where retention is no longer legally required. Note that jljlee cannot delete data that must be retained for PAGCOR compliance, AMLA obligations, or ongoing regulatory investigations.
• Right to Object: The right to object to the processing of your personal data for marketing purposes. You may opt out of marketing communications at any time through your account settings or by contacting support.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format for transfer to another service, where technically feasible.
• Right to Damages: The right to be compensated for damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data, consistent with the provisions of RA 10173.

To exercise any of the above rights, contact jljlee's Data Protection Officer via the live chat support channel or by email at [email protected]. jljlee will respond within 15 business days of receiving a verified request. jljlee may request proof of identity before processing sensitive data requests.

10 Children and Minors

jljlee strictly prohibits access by individuals under 21 years of age. The platform does not knowingly collect personal data from persons under 21. If jljlee becomes aware that personal data has been collected from a person under 21, the account will be immediately suspended, the data will be deleted (to the extent not required for regulatory breach-reporting purposes), and the matter will be reported to PAGCOR as required.

Parents and guardians who believe a minor has registered on or accessed the jljlee platform should contact jljlee support immediately. jljlee takes underage access violations seriously and cooperates fully with PAGCOR enforcement processes in such cases.

11 Changes to This Privacy Policy

jljlee may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or platform features. Material changes will be communicated to registered Players via in-platform notification or registered email address at least seven (7) days before the changes take effect.

The "Last updated" date at the top of this Policy will always reflect the date of the most recent revision. Continued use of the jljlee platform after the effective date of a revised Policy constitutes acceptance of the updated terms. If you do not agree with the changes, you should close your jljlee account before the effective date.

12 Contact and Complaints

For any questions, concerns, or requests regarding this Privacy Policy or jljlee's data processing practices, contact jljlee's designated Data Protection Officer (DPO):

• Email: [email protected] (subject line: "Privacy / DPO Request")
• Live Chat: 24/7 support available inside your jljlee account

If you believe jljlee has not adequately addressed a privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government authority responsible for administering and enforcing the Data Privacy Act of 2012. Complaint procedures are available on the NPC's official channels.