jl33 Privacy Policy

Introduction & Scope

jl33 ("we", "us", "our") is committed to protecting the privacy and personal data of every individual who interacts with our platform at jl33.asia. This Privacy Policy ("Policy") sets out the principles, practices, and obligations governing the collection, use, storage, disclosure, and protection of personal information in connection with your use of the jl33 online casino and sports betting platform.

This Policy applies to all personal information processed by jl33 in connection with:

• Account registration and the ongoing maintenance of your jl33 player account;
• Identity verification (KYC) procedures required by PAGCOR and Philippine anti-money laundering legislation;
• Deposit and withdrawal transactions processed through GCash, Maya, BPI, BDO, Metrobank, and other supported payment methods;
• Gameplay data generated by your use of any jl33 game, including slots, live dealer, bingo, and sportsbook;
• Communications between you and the jl33 support team;
• Your use of jl33.asia including browsing behaviour, device data, and session information.

jl33 processes personal data in strict compliance with the Republic Act No. 10173 — the Data Privacy Act of 2012 ("DPA") and its Implementing Rules and Regulations, as well as National Privacy Commission ("NPC") issuances and applicable PAGCOR data governance directives. Where the DPA imposes obligations that exceed the requirements of any other applicable law, the DPA shall prevail.

Data Controller

For the purposes of the Data Privacy Act of 2012, jl33 is the Personal Information Controller (PIC) in respect of all personal data collected and processed through the jl33 platform. As PIC, jl33 determines the purposes and means of processing your personal data and bears the obligations of a controller under the DPA and applicable NPC regulations.

jl33 has designated a Data Protection Officer (DPO) in compliance with Section 21 of the Data Privacy Act and NPC Advisory Opinion requirements applicable to personal information controllers processing sensitive personal information at scale. The DPO is responsible for overseeing jl33's compliance with the DPA, managing data subject requests, and coordinating with the National Privacy Commission on data breach notifications and other regulatory matters.

Personal Data We Collect

jl33 collects only the personal data that is necessary for the specific, explicit, and legitimate purposes described in this Policy. The categories of personal data we collect are set out below.

3.1 Registration & Account Data

• Full legal name as it appears on your government-issued Philippine identification document;
• Date of birth (for age verification — 21+ requirement under PAGCOR regulations);
• Philippine mobile number (used for account login, OTP authentication, and communications);
• Email address (used for account communications and password recovery);
• Username and encrypted password;
• City or province of residence in the Philippines.

3.2 Identity Verification (KYC) Data

In compliance with PAGCOR licensing requirements and the Anti-Money Laundering Act of 2001 (as amended), jl33 collects the following sensitive personal information as part of the KYC process:

• Government-issued Philippine ID (PhilSys, Passport, LTO Driver's Licence, UMID, Voter's ID, PRC ID) — front and back images;
• Selfie photograph for biometric comparison against the submitted ID document;
• Proof of address documentation (utility bill, bank statement, or government correspondence issued within the past 90 days), where required;
• Source of funds documentation for enhanced due diligence cases as required by AMLC and PAGCOR rules.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction history (amount, method, timestamp, status);
• GCash account number or registered mobile number, Maya account identifier, BPI or BDO account details (last four digits only — full account numbers are not stored by jl33);
• Bonus and promotional credit history;
• VIP tier status and points balance history.

3.4 Gameplay & Betting Data

• Game session logs (game title, session duration, wager amounts, outcomes);
• Sports betting slip history (market, selection, stake, settlement result);
• Responsible gaming tool usage (deposit limits set, session time-outs activated, self-exclusion requests);
• Aggregate win/loss data.

3.5 Technical & Device Data

• IP address at the time of each login and significant platform action;
• Device type, operating system, and browser type;
• Session identifiers and authentication tokens;
• Cookies and similar tracking technologies (see Section 8).

3.6 Communications Data

• Records of support communications (live chat transcripts, email correspondence);
• Complaint and dispute correspondence;
• Responses to surveys or promotional participation where you have voluntarily provided information.

How We Collect Your Data

jl33 collects personal data through the following means:

Legal Basis for Processing

Under the Data Privacy Act of 2012, jl33 processes your personal data on one or more of the following legal bases:

Where jl33 relies on your consent as the legal basis for processing — in particular for direct marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal.

How We Use Your Personal Data

jl33 uses your personal data solely for the purposes described in this Policy and consistent with the legal bases identified in Section 5. Specifically, we use your data to:

1. Create and maintain your jl33 account — including authentication, balance management, session tracking, and account security;
2. Process deposits and withdrawals — reconciling transactions with GCash, Maya, BPI, BDO, and other payment providers and maintaining your account balance in PHP;
3. Verify your identity — conducting KYC procedures as required by PAGCOR and the Anti-Money Laundering Council;
4. Enforce age restrictions — confirming that all registered players are 21 years of age or older, as required under PAGCOR's regulatory framework for licensed online gaming in the Philippines;
5. Provide customer support — responding to enquiries, resolving disputes, and processing complaints through jl33's support channels;
6. Monitor for responsible gaming compliance — tracking gameplay patterns, enforcing deposit limits and session time-outs, and processing self-exclusion requests in accordance with PAGCOR's responsible gaming directives;
7. Detect and prevent fraud and money laundering — screening transactions, account activity, and login patterns against fraud indicators and AMLC watchlists;
8. Administer VIP programme benefits — calculating tier status, crediting cashback, and managing promotional awards;
9. Communicate with you — sending account notifications, transaction confirmations, security alerts, and (where you have consented) promotional communications;
10. Improve the jl33 platform — analysing aggregated usage data to improve platform performance, game selection, and the player experience;
11. Meet our legal and regulatory obligations — including reporting to PAGCOR and the Anti-Money Laundering Council as required by applicable Philippine law.

jl33 does not use your personal data for automated profiling that produces legal or significantly impactful effects on you without appropriate safeguards, except to the extent that automated screening is required by law for anti-money laundering or responsible gaming compliance purposes.

Data Sharing & Third-Party Disclosure

jl33 does not sell, rent, or trade your personal data to any third party for their independent commercial purposes. We disclose personal data only in the circumstances described below:

7.1 Authorised Service Providers (Personal Information Processors)

jl33 engages third-party service providers who process personal data on jl33's behalf as Personal Information Processors under the DPA. These include:

• Payment processors — GCash (G-Xchange Inc.), Maya (Voyager Innovations), and banking partners, for deposit and withdrawal processing;
• KYC and identity verification technology providers — for document authentication and biometric comparison during the identity verification process;
• Game providers — including PG Soft, Pragmatic Play, and Jili, who receive gameplay data necessary for game delivery and session reconciliation;
• Cloud infrastructure and hosting providers — who store platform data on jl33's behalf under strict data processing agreements;
• Customer support platform providers — who process support communications on jl33's infrastructure.

All Personal Information Processors are bound by written data processing agreements that require them to process personal data only on jl33's documented instructions and to implement security measures equivalent to those maintained by jl33.

7.2 Regulatory and Legal Authorities

jl33 discloses personal data to the following authorities where required by Philippine law or under a valid legal order:

• PAGCOR — for licence compliance, regulatory inspection, and player complaint investigation;
• Anti-Money Laundering Council (AMLC) — for covered and suspicious transaction reporting under Republic Act No. 9160 (as amended by RA 10365 and RA 11521);
• National Privacy Commission (NPC) — for data breach notifications and regulatory compliance matters under the DPA;
• Philippine courts and law enforcement agencies — in response to valid court orders, subpoenas, or lawful requests from authorised Philippine government bodies.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of jl33's assets, personal data held by jl33 may be transferred to the acquiring entity, subject to the acquiring entity providing at minimum equivalent data protection commitments to those contained in this Policy. jl33 will provide reasonable notice to affected players prior to any such transfer where practically possible.

Cookies & Tracking Technologies

jl33 uses cookies and similar tracking technologies on jl33.asia to enable platform functionality, enhance your experience, and collect analytical data that helps us improve the platform. A cookie is a small data file placed on your device by a web server when you visit a website.

Strictly necessary cookies cannot be disabled as they are essential to the operation of the jl33 platform — disabling them would prevent you from logging in or using account features. Functional and analytics cookies may be managed through your browser settings. Marketing cookies are only set where you have provided explicit consent and may be withdrawn at any time.

Most browsers allow you to view, manage, delete, and block cookies through the browser's settings menu. Please note that disabling certain cookies may impair the functionality of the jl33 platform or affect the performance of game delivery.

Data Retention

jl33 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulation. Our standard retention periods are as follows:

Upon expiry of the applicable retention period, jl33 will securely delete or anonymise personal data in accordance with NPC-recommended disposal standards. Anonymised data — from which no individual can be identified or re-identified — may be retained for analytical purposes indefinitely.

Data Security

jl33 implements technical, organisational, and physical security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:

1. TLS encryption — all data transmitted between your device and jl33.asia is encrypted using Transport Layer Security (TLS 1.2 or higher);
2. At-rest encryption — sensitive personal data stored in jl33's databases, including KYC documents and financial data, is encrypted at rest;
3. Access controls — access to personal data is restricted on a strict need-to-know basis, with role-based permissions and mandatory authentication for all jl33 staff accessing data systems;
4. Password security — account passwords are stored using industry-standard one-way cryptographic hashing; jl33 does not store plaintext passwords;
5. Two-factor authentication — jl33 supports and recommends 2FA for all player accounts to protect against unauthorised login;
6. Penetration testing — jl33's platform undergoes regular security assessments by qualified cybersecurity professionals;
7. Staff training — all jl33 personnel with access to personal data receive regular data protection and security awareness training;
8. Incident response — jl33 maintains a documented data breach response procedure aligned with NPC Circular 16-03 requirements for breach notification.

Notwithstanding jl33's security measures, no internet transmission or data storage system can be guaranteed to be 100% secure. You are responsible for maintaining the security of your own jl33 account credentials. If you believe your account has been compromised, contact jl33 support immediately.

Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to the personal data that jl33 holds about you:

To exercise any of the above rights, contact jl33's Data Protection Officer at support@jl33.asia. jl33 will respond to all verified data subject requests within thirty (30) calendar days of receipt, as required by the DPA. Where a request is complex or involves a high volume of data, jl33 may extend this period by a further 30 days, with notice to you.

Children & Minors

If jl33 becomes aware that personal data has been collected from a person under the age of 21, jl33 will promptly close the associated account, reverse any remaining balance to the funding source where possible, and delete all personal data associated with the minor's registration, to the extent not prohibited by applicable legal obligations.

If you are a parent or guardian and believe that a minor in your care has registered an account on jl33, please contact us immediately at support@jl33.asia so that appropriate action can be taken. jl33 takes its responsibilities under both PAGCOR regulation and the Data Privacy Act seriously in respect of protecting minors from access to gambling services.

International Data Transfers

jl33's primary data processing operations are conducted within the Philippines. However, certain service providers — including game providers, cloud infrastructure partners, and technology vendors — may process personal data in jurisdictions outside the Philippines.

Where jl33 transfers personal data outside the Philippines, we ensure that such transfers are conducted only in accordance with the Data Privacy Act of 2012 and applicable NPC regulations, specifically:

1. Transfers to countries that the NPC has recognised as providing an adequate level of protection for personal data;
2. Transfers subject to binding contractual safeguards — including NPC-compliant data processing agreements or standard contractual clauses — that require the recipient to protect personal data to a standard equivalent to Philippine law;
3. Transfers necessary for the performance of your contract with jl33 (e.g., delivery of game content by international game providers), where no other adequate safeguard is available.

You may request information about the specific safeguards applicable to any cross-border transfer of your personal data by contacting jl33's Data Protection Officer.

Amendments to This Policy

jl33 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable Philippine law, or NPC guidance. Material amendments — those that substantially affect your rights or jl33's data processing obligations — will be communicated to registered players via their registered email address at least fourteen (14) days before the amended Policy takes effect.

Non-material amendments — including corrections of typographical errors, clarifications that do not alter the substance of the Policy, or additions that expand your privacy rights — may take effect without prior notice, but will be reflected in the "Last Updated" date displayed at the top of this Policy.

We encourage you to review this Policy periodically to remain informed about how jl33 protects your personal data. The most current version of the Privacy Policy is always available at jl33.asia/privacy-policy.

Contact & Data Protection Officer

For all matters relating to your personal data, your privacy rights under the Data Privacy Act of 2012, or any concerns about jl33's data processing practices, please contact jl33's Data Protection Officer:

If you are not satisfied with jl33's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. The NPC's complaint process and contact details are available through the NPC's official government channels.

As a PAGCOR-licensed operator committed to responsible and transparent data governance, jl33 welcomes data privacy enquiries from players and regulators alike. Your trust in the security and responsible use of your personal data is something we take seriously — and we are committed to maintaining that trust through full compliance with the Data Privacy Act of 2012 and all applicable NPC regulations.