jlll1 Privacy Policy

1. Introduction

jlll1 ("we," "us," "the Platform") is committed to protecting the privacy and personal data of all individuals who interact with the jlll1 online gaming platform accessible at jlll1.org ("the Platform"). This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, sharing, and protection of personal data in connection with the jlll1 platform and its associated services.

This Policy applies to all registered Players, prospective Players who browse the Platform without registering, and any other individuals whose personal data is processed by jlll1 in connection with the provision of our services. By accessing or using the jlll1 platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

jlll1 processes personal data as a Personal Information Controller under Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its implementing rules issued by the National Privacy Commission of the Philippines.

2. Personal Data We Collect

2.1 Registration Data

When you create a jlll1 account, we collect: full legal name; date of birth; nationality; residential address (including city and province); mobile phone number registered in the Philippines; and email address. This information is required to create and maintain your account and to fulfill our KYC obligations.

2.2 Identity Verification (KYC) Data

To comply with our regulatory obligations and to verify your identity before processing withdrawals, jlll1 may collect copies of government-issued identification documents (such as a Philippine passport, PhilSys national ID, SSS ID, driver's licence, or UMID); proof of address documentation; and payment method ownership documentation (e.g., screenshot of a GCash account showing your registered name).

2.3 Financial Data

jlll1 records transaction data including deposit and withdrawal amounts, timestamps, payment method identifiers (e.g., GCash mobile number, last four digits of a bank account), and transaction reference numbers. We do not store full payment card numbers or complete bank account credentials on our servers.

2.4 Gaming and Behavioural Data

We collect data relating to your use of the Platform, including: games played and wagers placed; session duration and login timestamps; device type, operating system, and browser information; IP address and approximate geographic location derived from IP; and in-platform communications with customer support.

2.5 Communications Data

Records of communications between you and jlll1 customer support — including live chat transcripts, email correspondence, and support ticket records — are retained to ensure quality assurance, resolve disputes, and fulfil our regulatory record-keeping obligations.

3. How We Collect Personal Data

jlll1 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, or participate in promotions;
• Automatically — through cookies and similar tracking technologies when you browse or use the Platform (see Section 9 on Cookies);
• From third-party payment providers — GCash, Maya, BPI, BDO, and other payment processors share transaction confirmation data with jlll1 to facilitate deposit and withdrawal processing;
• From identity verification services — where jlll1 uses third-party KYC service providers to verify the authenticity of identification documents submitted by Players.

4. Legal Basis for Processing

jlll1 processes personal data on the following legal bases under the Data Privacy Act of 2012:

• Performance of a contract — processing is necessary to provide you with the jlll1 gaming services you have requested, including account management, payment processing, and customer support;
• Legal obligation — processing is required to comply with applicable laws, including AML/CTF regulations, KYC requirements, and regulatory reporting obligations;
• Legitimate interests — processing is necessary for fraud prevention, platform security, and improving the quality of our services, where these interests are not overridden by your rights and interests;
• Consent — for the sending of optional marketing communications and the use of non-essential cookies, where you have given freely-given, specific, and informed consent.

5. How We Use Your Personal Data

jlll1 uses the personal data we collect for the following purposes:

• Creating, maintaining, and managing your jlll1 Account;
• Processing deposits and withdrawal requests in Philippine Peso via GCash, Maya, and other accepted payment methods;
• Verifying your identity and age (21+) in compliance with our regulatory obligations;
• Detecting and preventing fraud, money laundering, and other illegal activities;
• Providing customer support and resolving disputes;
• Personalising your jlll1 gaming experience, including surfacing relevant game recommendations and applicable promotions;
• Sending transactional communications (e.g., deposit confirmations, withdrawal status updates, security alerts);
• Sending optional promotional communications where you have provided consent, including information about jlll1 bonuses, events, and new game launches;
• Complying with applicable legal and regulatory requirements and responding to lawful requests from government authorities;
• Analysing Platform usage patterns to improve performance, fix technical issues, and develop new features.

6. Data Sharing and Disclosure

6.1 Service Providers

jlll1 may share your personal data with carefully selected third-party service providers who assist in the delivery of our platform and services, including payment processors (GCash, Maya, BPI, BDO, InstaPay, and others), identity verification providers, cloud infrastructure and hosting providers, and customer support technology providers. All service providers are contractually required to process your data only on jlll1's instructions and to implement appropriate security measures.

6.2 Regulatory and Legal Disclosures

jlll1 may disclose personal data to regulatory authorities, law enforcement agencies, courts, and other government bodies in the Philippines where required by applicable law, including disclosures required under AML/CTF reporting obligations, responses to lawful court orders or subpoenas, and mandatory regulatory reporting.

6.3 No Sale of Personal Data

jlll1 does not sell, rent, or trade your personal data to third parties for their own independent commercial marketing purposes. Any sharing of data is limited to the purposes described in this Policy.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of jlll1's business assets, personal data held by jlll1 may be transferred to the acquiring entity as part of the transaction. Players will be notified of any such transfer and the application of any new privacy policy prior to its taking effect.

7. Data Security

jlll1 implements technical and organisational security measures appropriate to the nature of the personal data we process and the risks involved. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jlll1 platform;
• Encryption of sensitive data at rest, including identity document images and KYC records;
• Role-based access controls ensuring that jlll1 staff can only access personal data necessary for their specific job functions;
• Regular security assessments and penetration testing of the jlll1 platform;
• Segregation of Player funds from operational accounts;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While jlll1 takes all reasonable precautions to protect your personal data, no internet-based platform can guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jlll1 will notify the National Privacy Commission and affected individuals in accordance with our obligations under the DPA.

8. Data Retention

jlll1 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, or longer where required by AML/CTF regulations or applicable law;
• Transaction records: Retained for a minimum of five (5) years in compliance with financial record-keeping requirements;
• Customer support communications: Retained for two (2) years from the date of the last communication, or longer where a dispute remains unresolved;
• Marketing consent records: Retained until consent is withdrawn, plus a reasonable additional period for compliance documentation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

9. Cookies and Tracking Technologies

jlll1 uses cookies and similar technologies on the Platform. The categories of cookies used are as follows:

• Strictly necessary cookies: Required for the Platform to function, including maintaining your login session and preserving security settings. These cannot be disabled.
• Performance cookies: Used to collect anonymised data about how Players use the Platform — such as which pages are visited most frequently — to help us improve the user experience. No personal data is shared with third parties through these cookies.
• Preference cookies: Store your Platform preferences such as language settings and preferred display options.

jlll1 does not use third-party advertising cookies or retargeting pixels. You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may affect Platform functionality. Continued use of the jlll1 Platform after reviewing this Policy constitutes acceptance of our use of cookies as described above.

10. Your Data Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jlll1:

• Right to be Informed: The right to be notified of how your personal data is collected and processed — which this Policy fulfils;
• Right of Access: The right to request a copy of the personal data jlll1 holds about you;
• Right to Correction: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to jlll1's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data on grounds of legitimate interests or for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), the right to withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Subject Request – [Your Username]." jlll1 will respond within 30 days of receiving a verifiable request. We may require identity verification before processing your request.

11. Children's Privacy

The jlll1 platform is strictly for adults aged 21 years and older. jlll1 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and permanently close the associated account. Parents or guardians who believe their child has provided personal data to jlll1 should contact us immediately at [email protected].

12. Updates to This Policy

jlll1 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance. When material changes are made, we will notify registered Players via the jlll1 platform notification system or by email to the address registered on your account, at least seven (7) days before the revised Policy takes effect. The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Continued use of the jlll1 platform after the effective date of a revised Policy constitutes your acceptance of the updated terms.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by jlll1, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: "Privacy Inquiry – [Your Username or Full Name]"
• Response time: Within 30 days of receiving a verifiable request
• Support hours: 24 hours a day, 7 days a week

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that jlll1 has violated your rights under the Data Privacy Act of 2012.