jlj3 Privacy
Policy

1. Identity of the Data Controller

For the purposes of Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, jlj3 is the personal information controller with respect to the data collected through the jlj3 Platform. jlj3 operates under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to Philippine jurisdiction for all data protection matters.

Players may contact jlj3's designated data protection point of contact at [email protected]. Correspondence regarding personal data must be submitted from the email address or mobile number associated with your registered jlj3 account to enable identity verification.

2. Categories of Personal Data We Collect

jlj3 collects and processes the following categories of personal data, limited to what is necessary for the stated purposes:

Category	Specific Data Elements	Purpose
Identity Data	Full name, date of birth, nationality, government ID number, ID document images, selfie photograph	KYC verification, age verification (21+), PAGCOR compliance
Contact Data	Philippine mobile number, email address (if provided)	Account registration, OTP delivery, support communications
Financial Data	GCash/Maya account identifiers, bank account details (where provided), deposit and withdrawal transaction records, wallet balance history	Payment processing, AML compliance, withdrawal verification
Gaming Activity Data	Game session logs, bet amounts, win/loss records, game type preferences, active bonus status	Game administration, dispute resolution, responsible gaming monitoring
Technical Data	IP address, device type and identifiers, browser type, operating system, connection timestamps	Security monitoring, fraud prevention, platform optimisation
Communications Data	Live chat transcripts, support ticket content, promotional opt-in status	Customer service, dispute resolution, compliance audit trail

jlj3 does not intentionally collect sensitive personal information such as biometric data, medical records, or racial or ethnic origin beyond what is incidentally contained in government-issued ID photographs submitted for KYC.

3. How We Collect Personal Data

jlj3 collects personal data through the following means:

• Direct submission: Information you provide during registration, KYC verification, payment setup, and live chat or email support interactions;
• Automated collection: Technical data collected automatically as you interact with the jlj3 Platform, including via cookies and server logs (see Section 6);
• Payment processors: Transaction confirmation data shared by GCash, Maya, banks, and card networks when you make a deposit or receive a withdrawal;
• KYC verification partners: Where jlj3 uses a third-party identity verification service, that provider shares verification results (pass/fail and document type) with jlj3, but does not store your ID documents on jlj3's behalf;
• PAGCOR and regulatory sources: Regulatory watchlists, self-exclusion registers, and other sources jlj3 is required to check as a licensed operator.

4. Lawful Basis for Processing

jlj3 processes personal data only where a lawful basis exists under the Data Privacy Act of 2012. The applicable lawful bases are:

• Consent: You provide consent at the point of registration for jlj3 to process your personal data for the purposes described in this Policy. You may withdraw consent at any time (see Section 11);
• Contract performance: Processing necessary to fulfil our contractual obligations to you as a registered player — including account management, game provision, payment processing, and support;
• Legal obligation: Processing required to comply with Philippine law and PAGCOR regulations, including AML/CTF obligations under Republic Act No. 9160, PAGCOR's player data requirements, and tax reporting obligations;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improvement of our services, where such interests are not overridden by your data protection rights.

5. How We Use Your Personal Data

jlj3 uses the personal data we collect for the following purposes:

• To create, maintain, and administer your jlj3 account;
• To verify your identity and age (minimum 21 years) as required by PAGCOR;
• To process deposits, withdrawals, and in-platform wallet transactions in Philippine Pesos;
• To provide customer support and resolve disputes through our live chat and email channels;
• To detect and prevent fraud, money laundering, unauthorized access, and other prohibited conduct as defined in our Terms and Conditions;
• To comply with PAGCOR reporting obligations, Philippine AML/CTF requirements, and any other applicable legal obligations;
• To administer promotional offers and bonuses, where you have opted in or where the promotion is available to all eligible players;
• To monitor your gaming activity for responsible gaming purposes and enforce any limits, restrictions, or self-exclusion you have applied to your account;
• To improve the jlj3 Platform through aggregated, anonymised analytics of user behaviour and game performance;
• To send you account-related communications (OTPs, security alerts, account status updates) via SMS to your registered Philippine mobile number.

6. Cookies and Tracking Technologies

jlj3 uses cookies and similar tracking technologies on the Platform to enable essential functionality and to improve the player experience. The categories of cookies we use are:

• Strictly necessary cookies: Required for the Platform to function, including session management, login state maintenance, and security token handling. These cannot be disabled without severely impairing Platform functionality;
• Functional cookies: Store your preferences, such as language settings and display preferences, to personalise your experience;
• Performance and analytics cookies: Collect anonymised data about how players navigate the Platform to help jlj3 identify technical issues and improve page performance. This data does not identify individual players;
• Security cookies: Assist in detecting suspicious activity, bot traffic, and unauthorised access attempts.

jlj3 does not use cookies to serve third-party advertising. You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to the jlj3 Platform.

7. Third-Party Sharing and Disclosure

jlj3 does not sell, rent, or trade your personal data to any third party. We may share personal data with the following categories of recipients where strictly necessary:

• Payment processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, Visa, Mastercard, and other payment service providers, solely to process transactions you have authorised;
• KYC verification providers: Third-party identity verification services engaged to assist with PAGCOR-mandated player identification requirements;
• Game content providers: Gaming studios and platform providers (e.g., Vivo Gaming) may receive your session and wager data to the extent necessary to operate their games, subject to their own data processing agreements with jlj3;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or regulatory direction;
• Technology and infrastructure providers: Cloud hosting, security, and IT infrastructure partners who process data on jlj3's behalf under written data processing agreements and strict confidentiality obligations;
• Law enforcement: Philippine law enforcement and judicial authorities, where disclosure is required by court order or applicable law.

8. Data Security Measures

jlj3 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure:

• Encryption in transit: All data transmitted between your device and the jlj3 Platform is encrypted using 256-bit SSL/TLS;
• Encryption at rest: Sensitive data stored in jlj3's systems, including identity documents and financial records, is encrypted at rest using industry-standard algorithms;
• Password hashing: Account passwords are stored as one-way cryptographic hashes. jlj3 staff cannot view or retrieve your plain-text password;
• Two-factor authentication: jlj3 offers OTP-based 2FA for all accounts and encourages all players to enable it;
• Access controls: Access to player personal data within jlj3's systems is restricted to staff with a documented operational need, and all access is logged;
• Penetration testing: jlj3's platform undergoes periodic security assessments by qualified third-party security professionals;
• Incident response: jlj3 maintains a documented security incident response plan. In the event of a data breach, affected players will be notified as required by the National Privacy Commission and the Data Privacy Act.

Notwithstanding these measures, no online platform can guarantee absolute security. Players are responsible for maintaining the security of their own login credentials and for notifying jlj3 immediately if they suspect unauthorised access to their account.

9. Data Retention

jlj3 retains personal data for the periods specified below, or longer where required by Philippine law or PAGCOR regulations:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR and AML/CTF obligations under Republic Act No. 9160;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act;
• Gaming activity data: Retained for five (5) years from the date of each session to support dispute resolution and regulatory audit requirements;
• Support communications: Retained for three (3) years from the date of the last communication, or longer if relevant to an active dispute or regulatory investigation;
• Technical/log data: Retained for twelve (12) months from the date of creation, unless required for an active security investigation;
• Marketing consent records: Retained for the duration of your account plus three (3) years to evidence compliance with consent obligations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to an identifiable individual.

10. Children and Minors

jlj3 does not knowingly collect personal data from individuals under the age of 21 years. The Platform is strictly restricted to adult players meeting the PAGCOR-mandated minimum age requirement. If jlj3 becomes aware that personal data has been collected from an individual under 21, that account will be immediately suspended and the personal data will be securely deleted, subject to any legal obligations to retain records of the underage access incident.

Parents and guardians who believe a minor has accessed the jlj3 Platform should contact jlj3 support immediately via live chat or at [email protected].

11. Your Data Subject Rights

Under Republic Act No. 10173, you have the following rights with respect to your personal data held by jlj3:

• Right to be informed: The right to be notified of how your data is processed — this Policy fulfils that obligation;
• Right to access: The right to obtain confirmation of whether jlj3 holds personal data about you and to request a copy of that data;
• Right to correction: The right to request correction of inaccurate, incomplete, or outdated personal data;
• Right to erasure: The right to request deletion of your personal data, subject to jlj3's legal retention obligations;
• Right to object: The right to object to processing for direct marketing purposes;
• Right to data portability: The right to receive your data in a structured, commonly used format where technically feasible;
• Right to withdraw consent: The right to withdraw previously given consent at any time, without affecting the lawfulness of prior processing;
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, submit a written request to [email protected] from the email address or using the mobile number registered to your jlj3 account. jlj3 will acknowledge your request within 2 business days and respond substantively within 15 business days. In complex cases, this period may be extended by an additional 15 days with written notice.

12. Data Breach Response Protocol

In the event of a personal data breach that creates a real risk of serious harm to affected players, jlj3 will:

1. Notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, as required by the Data Privacy Act;
2. Notify affected players without undue delay, providing information on the nature of the breach, the categories of data affected, the likely consequences, and the remedial measures jlj3 has taken or intends to take;
3. Implement containment and remediation measures to prevent further unauthorized access;
4. Conduct a post-incident review to identify root causes and implement improvements to prevent recurrence.

jlj3 maintains a dedicated security incident response team and documented escalation procedures to ensure timely and appropriate breach response.

13. Cross-Border Data Transfers

Some of the third parties with whom jlj3 shares personal data (including game content providers and technology infrastructure partners) may process data outside the Philippines. Where personal data is transferred outside the Philippines, jlj3 ensures that appropriate safeguards are in place, including:

• Contractual clauses with the receiving party requiring them to protect your data to a standard consistent with the Data Privacy Act of 2012;
• Transfer only to jurisdictions with data protection frameworks recognised as providing adequate protections under Philippine NPC guidelines; and
• Processing limited strictly to what is necessary for the stated purpose of the transfer.

jlj3 will not transfer personal data to jurisdictions that do not provide an adequate level of protection without first implementing appropriate contractual safeguards and, where required, obtaining your explicit consent.

14. Updates to This Privacy Policy

jlj3 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, Philippine legal requirements, or PAGCOR regulations. Material changes will be communicated to registered players via the mobile number on file and/or through a notice on the jlj3 Platform at least 7 days before the change takes effect, unless an immediate change is required by law or regulatory directive.

The effective date at the top of this Policy will be updated whenever a change is made. We encourage you to review this Policy periodically. Continued use of the jlj3 Platform following notification of a change constitutes acceptance of the revised Policy.

15. Contact Us and Filing a Complaint

For any questions, concerns, or requests regarding this Privacy Policy or jlj3's personal data handling practices, please contact us through the following channels:

• Live Chat: Available 24/7 on the jlj3 Platform
• Email: [email protected]

If you are not satisfied with jlj3's response to your data privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines, the independent regulatory body responsible for enforcing the Data Privacy Act of 2012. The NPC's contact details and complaint procedures are available through official Philippine government channels.