jl4jl4 Privacy Policy

1. Introduction

jl4jl4 ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all users who access or register on jl4jl4.org ("the Site"). This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in connection with your use of the jl4jl4 platform.

This Policy applies to all players, visitors, and registered users of jl4jl4, regardless of the device or method used to access the platform. It covers data collected through the Site, our customer support channels, and any other interaction you have with jl4jl4.

By registering an account or continuing to use jl4jl4, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the platform immediately.

This Policy is to be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

For the purposes of applicable data protection legislation, jl4jl4 acts as the data controller in respect of the personal data it collects and processes. As data controller, jl4jl4 determines the purposes and means of processing your personal information.

jl4jl4 operates under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and complies with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

If you have any questions about how jl4jl4 handles your personal data, or if you wish to exercise any of your data subject rights, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

jl4jl4 collects the following categories of personal data from players and site visitors:

4. How We Collect Your Data

jl4jl4 collects personal data through the following means:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically when you access the platform, including through cookies, web beacons, server logs, and similar tracking technologies (see Section 9).
• Third-Party Sources: Data received from payment processors (GCash, PayMaya, BPI, BDO, Metrobank) to verify transactions; identity verification service providers; fraud prevention and anti-money laundering (AML) screening services; and regulatory authorities where required by law.
• Publicly Available Sources: In limited circumstances, jl4jl4 may verify information against publicly available records for compliance purposes.

5. Purpose & Legal Basis for Processing

jl4jl4 processes your personal data only where a valid legal basis exists under applicable Philippine data protection law. The following table outlines the primary purposes for which we process your data and the corresponding legal basis:

Where jl4jl4 relies on your consent as the legal basis for processing (e.g., marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Personal Data

jl4jl4 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, and Metrobank, to facilitate deposits and withdrawals. These providers process your financial data under their own privacy policies and applicable banking regulations.
• Identity Verification Providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements.
• Technology Service Providers: Cloud hosting, data storage, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulation.
• Game Software Providers: Third-party game developers whose games are hosted on the jl4jl4 platform may receive limited technical data (e.g., session tokens) necessary to deliver the gaming experience.
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

7. Data Retention

jl4jl4 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account and transaction data: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• KYC verification documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later.
• Customer support communications: Retained for three (3) years from the date of the interaction.
• Marketing consent records: Retained for the duration of your consent and for three (3) years thereafter as evidence of consent.
• Technical and usage logs: Retained for up to twelve (12) months, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with jl4jl4's data disposal procedures.

8. Data Security

jl4jl4 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the jl4jl4 platform is encrypted using industry-standard SSL/TLS protocols.
• Encrypted Data Storage: Sensitive data, including financial information and identity documents, is stored in encrypted form on secured servers.
• Access Controls: Access to personal data is restricted to authorized jl4jl4 personnel and service providers on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Regular Security Audits: jl4jl4 conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities.
• Incident Response: jl4jl4 maintains a data breach response plan. In the event of a security incident affecting your personal data, we will notify you and the relevant authorities in accordance with applicable law.

While jl4jl4 takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying jl4jl4 immediately if you suspect any unauthorized access to your account.

9. Cookies & Tracking Technologies

jl4jl4 uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and support security functions. The following types of cookies may be used:

• Strictly Necessary Cookies: Essential for the platform to function correctly, including session management, authentication, and security. These cannot be disabled.
• Functional Cookies: Remember your preferences (e.g., language, display settings) to provide a more personalized experience.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the platform, helping jl4jl4 improve its services.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jl4jl4 platform. jl4jl4 does not use cookies to serve third-party advertising.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 and applicable regulations, you have the following rights in respect of your personal data held by jl4jl4:

• Right to be Informed: The right to know what personal data jl4jl4 collects and how it is used — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data jl4jl4 holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to jl4jl4's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact jl4jl4's Data Protection Officer using the details in Section 14. jl4jl4 will respond to all valid requests within thirty (30) days. In complex cases, this period may be extended by a further thirty (30) days, with prior notice to you.

11. Minors & Age Policy

jl4jl4 strictly prohibits the use of its platform by individuals under the age of 21, in compliance with Philippine law and PAGCOR regulations. jl4jl4 does not knowingly collect personal data from persons under 21 years of age.

If jl4jl4 becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, all associated data will be reviewed, and any funds will be handled in accordance with applicable regulatory requirements.

If you are a parent or guardian and believe that a minor has registered on jl4jl4 using false information, please contact our support team immediately at [email protected] so that we can take prompt action.

12. International Data Transfers

jl4jl4 primarily stores and processes personal data within the Philippines. In certain circumstances, data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or game software developers operating in other jurisdictions.

Where such transfers occur, jl4jl4 ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses that meet the standards required by the National Privacy Commission. jl4jl4 will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or a valid legal basis.

13. Changes to This Privacy Policy

jl4jl4 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, jl4jl4 will notify registered players via email or an in-platform notification prior to the changes taking effect.

The updated Policy will be published on this page with a revised "Last Updated" date. Your continued use of the jl4jl4 platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed about how jl4jl4 protects your data.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by jl4jl4, please contact our Data Protection Officer:

jl4jl4 is committed to resolving all privacy-related inquiries promptly and transparently. We aim to acknowledge all contacts within two (2) business days and to provide a substantive response within thirty (30) days.