jl97 Privacy Policy

1. Data Controller Identity

jl97 operates jl97.org as a Personal Information Controller (PIC) as defined under the Philippine Data Privacy Act. jl97 determines the purposes and means of processing personal data collected through the Platform. For all data privacy enquiries, including the exercise of data subject rights, Players may contact jl97's designated Data Protection Officer (DPO) using the contact details provided in Section 16 of this Policy.

2. Scope of This Policy

This Policy applies to all personal data collected by jl97 in connection with:

• The creation and management of a jl97 player account;
• Deposits, withdrawals, and all financial transactions processed through the Platform;
• KYC identity and age verification processes;
• Customer support interactions via live chat or email;
• Participation in games, betting, promotions, and the jl97 Loyalty Programme;
• Access to and navigation of the jl97 website and mobile interface;
• Communications sent to Players regarding account activity, promotions, and policy updates.

This Policy does not apply to third-party websites, payment processors, or game providers whose services are accessible through jl97. Those parties operate under their own privacy policies and jl97 is not responsible for their data practices.

3. Personal Data We Collect

3.1 Registration and Identity Data

• Full legal name as it appears on government-issued identification;
• Date of birth (for age verification — players must be 21 or older);
• Registered Philippine mobile number;
• Email address (where provided);
• Residential address;
• Nationality and citizenship status.

3.2 KYC Verification Data

• Copies or images of government-issued identity documents (Passport, PhilSys ID, Driver's Licence, UMID, etc.);
• Selfie or live photograph submitted for facial verification against identity documents;
• Source of funds declarations where required for enhanced due diligence.

3.3 Financial Transaction Data

• GCash account references, Maya account references, or bank account details used for deposits and withdrawals;
• Transaction amounts, dates, times, and payment method identifiers;
• Wallet balance history and betting transaction records.

3.4 Gameplay and Behavioural Data

• Games played, wagers placed, and outcomes;
• Session durations and frequency of play;
• Responsible gaming tool usage (deposit limit settings, self-exclusion history);
• Promotional offer claims and bonus wagering activity.

3.5 Technical and Device Data

• IP address and approximate geographic location derived from IP;
• Device type, operating system, and browser version;
• Device identifiers and fingerprint data used for fraud prevention and duplicate account detection;
• Session logs, access timestamps, and referral source data.

3.6 Communications Data

• Records of customer support chat transcripts and email correspondence;
• Feedback and survey responses submitted voluntarily by Players.

4. How We Collect Your Data

jl97 collects personal data through the following means:

• Directly from you: information you provide during registration, KYC submission, deposit/withdrawal requests, and communications with customer support;
• Automatically: technical and device data collected when you access and use the Platform, including through cookies, session logs, and analytics tools;
• From payment processors: transaction confirmation data returned by GCash, Maya, BPI, BDO, Metrobank, and other integrated payment providers;
• From KYC verification services: results and flags from third-party identity verification tools used to validate documents and detect fraud;
• From regulatory databases: checks against PAGCOR-required lists and anti-money laundering screening databases.

5. Purposes of Processing

jl97 processes your personal data for the following purposes:

• Account creation and management: setting up and maintaining your jl97 player account, including authentication and security;
• Age and identity verification: confirming that you are 21 years of age or older in compliance with PAGCOR requirements and Philippine law;
• Payment processing: facilitating deposits and withdrawals via your chosen payment method;
• AML/CTF compliance: screening transactions and player activity against anti-money laundering and counter-terrorism financing obligations under Republic Act No. 9160 (Anti-Money Laundering Act) as amended;
• Fraud prevention and security: detecting and preventing unauthorised account access, duplicate registrations, bonus abuse, and other fraudulent activity;
• Platform operation: delivering games, processing bets, operating the Loyalty Programme, and personalising your platform experience;
• Responsible gaming: monitoring gameplay patterns to identify potential problem gambling indicators and enforcing player-set limits and self-exclusion orders;
• Customer support: responding to enquiries, resolving disputes, and processing complaints;
• Marketing communications: sending promotional offers, bonus notifications, and platform updates to Players who have consented to receive such communications;
• Legal compliance: meeting obligations under Philippine law, PAGCOR directives, and National Privacy Commission requirements;
• Analytics and improvement: analysing Platform usage patterns to improve performance, user experience, and game offerings.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act, jl97 relies on the following legal bases for processing personal data:

• Contractual necessity: processing required to fulfil the player account agreement, including account management, payment processing, and game delivery;
• Legal obligation: processing required to comply with PAGCOR regulations, AML/CTF laws, NPC requirements, and other applicable Philippine legislation;
• Legitimate interests: fraud prevention, security monitoring, duplicate account detection, and platform analytics — where our legitimate interests do not override your fundamental rights;
• Consent: direct marketing communications and non-essential cookies — where you have given specific, informed consent which you may withdraw at any time.

7. Data Sharing and Disclosure

7.1 Service Providers (Personal Information Processors)

jl97 shares personal data with carefully selected third-party service providers who process data on our behalf under written data processing agreements. These providers include:

• Payment gateway providers (GCash, Maya, and integrated bank payment systems);
• KYC and identity verification service providers;
• Cloud hosting and infrastructure providers;
• Game content providers and platform operators;
• Customer support software providers;
• Fraud detection and cybersecurity service providers.

All service providers are contractually required to process personal data only for the specified purpose and in compliance with the Philippine Data Privacy Act.

7.2 Regulatory and Legal Disclosure

jl97 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement authorities, or courts of competent jurisdiction where required or permitted by Philippine law, or where necessary to protect the rights, property, or safety of jl97, its Players, or third parties.

7.3 No Sale of Personal Data

jl97 does not sell, rent, lease, or trade personal data to third-party advertisers, data brokers, or marketers. Any disclosure of data is strictly for the operational, legal, or security purposes described in this Policy.

8. Data Retention Periods

jl97 retains personal data for the following periods, after which data is securely deleted or irreversibly anonymised:

9. Security Measures

jl97 implements the following technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, and destruction:

• Encryption in transit: All data transmitted between your device and jl97 servers is encrypted using TLS 1.2 or higher (256-bit SSL);
• Encryption at rest: Sensitive personal data, including KYC documents and payment references, is stored in encrypted form in jl97's database systems;
• Access controls: Strict role-based access controls limit which jl97 staff can access personal data, restricted to those with a legitimate operational need;
• OTP verification: Account access from unrecognised devices requires one-time password verification to the Player's registered mobile number;
• Fraud monitoring: Automated systems monitor account activity, device fingerprints, and IP addresses to detect and flag suspicious access attempts;
• Regular security assessments: jl97 conducts periodic security reviews and vulnerability assessments of its infrastructure and data handling processes.

While jl97 takes all reasonable steps to protect your data, no digital transmission or storage system is completely immune to security risks. Players are encouraged to use strong, unique passwords for their jl97 account and to contact support immediately if they suspect unauthorised access.

10. Cookies and Tracking Technologies

10.1 What We Use

jl97 uses cookies and similar technologies (including session tokens, local storage, and device fingerprinting scripts) on the Platform. These technologies serve the following purposes:

• Essential cookies: Required for the Platform to function — maintaining your logged-in session, remembering wallet state, and enabling security features. These cannot be disabled without preventing use of the Platform;
• Analytics cookies: Used to measure how Players navigate the Platform, which games are most used, and where technical issues occur. This data is aggregated and anonymised;
• Fraud prevention cookies: Device and session identifiers used to detect duplicate accounts and suspicious access patterns;
• Preference cookies: Storing your language preference and display settings across sessions.

10.2 Managing Cookies

You may disable non-essential cookies through your browser settings. Please note that disabling essential cookies will prevent you from logging into your jl97 account and using the Platform. jl97 does not use third-party advertising cookies and does not allow third-party advertisers to place cookies through the Platform.

11. Minors and Age-Restricted Platform

jl97 is strictly an adults-only platform. The minimum age to register and use jl97 is 21 years of age, in compliance with PAGCOR's online gaming regulations for the Philippines. jl97 does not knowingly collect personal data from individuals under 21 years of age. If jl97 identifies that a registered account belongs to a person under 21, the account will be immediately suspended, all balances forfeited, and any personal data collected will be deleted in compliance with this Policy.

Parents and guardians who believe a minor has registered an account on jl97 should contact jl97 support immediately via live chat to report the account for investigation and deletion.

12. Exercising Your Data Subject Rights

To exercise any of the data subject rights described in Section 3 of this Policy — including access, rectification, erasure, objection, or restriction — you may submit a written request to jl97's Data Protection Officer using the contact details in Section 16. Your request should include:

• Your full name and registered jl97 mobile number;
• A description of the right you wish to exercise and the specific data it relates to;
• Sufficient information to verify your identity (jl97 may request a copy of your identity document for verification purposes).

jl97 will respond to verified data subject rights requests within fifteen (15) business days. Where requests are complex or numerous, jl97 may extend this period by a further fifteen (15) business days with written notice and explanation. jl97 will not charge a fee for processing data subject rights requests unless requests are manifestly unfounded or excessive.

13. Cross-Border Data Transfers

Some of jl97's service providers — including game content providers, cloud infrastructure partners, and KYC verification services — may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to the Philippines, jl97 implements appropriate safeguards including: (a) contractual data transfer clauses requiring the recipient to apply data protection standards equivalent to the DPA; and (b) where applicable, obtaining your explicit consent to the transfer. jl97 will not transfer your personal data to a jurisdiction where adequate protection cannot be ensured.

14. Data Breach Response Protocol

In the event of a personal data breach that is likely to result in harm to affected Players, jl97 will:

• Notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular 16-03;
• Notify affected Players as soon as practicable after the breach is confirmed, describing the nature of the breach, the data affected, the likely consequences, and the steps taken or proposed to address it;
• Conduct a full internal investigation and implement corrective measures to prevent recurrence;
• Maintain a breach register as required by NPC regulations.

15. Amendments to This Policy

jl97 reserves the right to update or revise this Privacy Policy at any time to reflect changes in the Platform's data practices, applicable law, or NPC guidance. Where changes are material, jl97 will provide notice to Players via the Platform (on-screen notification upon next login) and/or via registered contact channels, with a minimum of fourteen (14) days' notice before the revised Policy takes effect. The "Last Updated" date at the top of this Policy will reflect the most recent revision. Your continued use of jl97 following the effective date of a revised Policy constitutes your acceptance of the changes.

16. Contact & Data Protection Officer

For all privacy-related enquiries, data subject rights requests, or complaints regarding jl97's data handling practices, please contact jl97's designated Data Protection Officer through the following channels:

• Live Chat: Available 24/7 via the jl97 website at jl97.org — reference "Data Privacy Request" at the start of your message;
• Email: [email protected] — include "Privacy Policy Enquiry" in the subject line (plain text address — not a clickable link).

If you are not satisfied with jl97'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.