Privacy Policy

1 Overview and Scope

This Privacy Policy ("Policy") applies to all personal data collected, processed, stored, and used by jljph ("jljph," "we," "us," or "our") in connection with the operation of the jljph website, mobile application, and all associated gaming and support services (collectively, the "Platform").

This Policy applies to all registered players, prospective players, and visitors to the jljph Platform, regardless of the device or method used to access it. By registering on jljph or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read alongside our Terms and Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and jljph.

jljph acts as the data controller in respect of all personal data collected through the Platform. If you have any questions about how jljph handles your data, please refer to the contact details in Section 13 of this Policy.

2 Personal Data We Collect

jljph collects the following categories of personal data from players and Platform users:

jljph does not collect sensitive personal information (as defined under the Data Privacy Act of 2012) unless strictly required for regulatory compliance purposes, in which case such collection will be clearly disclosed to you at the time of collection.

3 How We Collect Your Data

jljph collects personal data through the following means:

• Direct collection: Information you provide when registering an account on jljph, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the jljph Platform, including through cookies, web beacons, and similar tracking technologies. See Section 9 for full details on our cookie practices.
• Third-party sources: Identity and fraud-check data received from third-party KYC verification providers, payment processors (such as GCash and BPI), and fraud prevention services, where you have authorised such sharing or where jljph is legally required to conduct such checks.

jljph will always inform you at the point of collection if providing certain personal data is mandatory (e.g., for account registration or withdrawal processing) or optional. Failure to provide mandatory data may prevent jljph from delivering certain services to you.

4 How We Use Your Personal Data

jljph uses the personal data it collects for the following purposes:

• To create, manage, and maintain your jljph player account.
• To verify your identity and age in compliance with applicable Philippine gaming regulations, including the requirement that all players be at least 21 years of age.
• To process deposits and withdrawals through your chosen payment method (GCash, PayMaya, BDO, BPI, Metrobank, or other supported channels).
• To deliver the games, promotions, and other services available on the jljph Platform.
• To detect, investigate, and prevent fraud, money laundering, and other illegal or prohibited activities on the Platform.
• To monitor gaming patterns for responsible gaming purposes, including identifying players who may be at risk of problem gambling.
• To communicate with you regarding your account, transactions, promotions, and any changes to jljph's policies.
• To respond to your customer support enquiries and resolve disputes.
• To comply with applicable legal and regulatory obligations, including reporting requirements under Philippine law.
• To improve the jljph Platform through analytics, user research, and performance monitoring.
• To personalise your experience on jljph, including recommending games and promotions that may be of interest to you.

jljph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

5 Legal Basis for Processing

jljph processes your personal data on the following legal bases, as applicable under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform the contract between you and jljph — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) requirements, gaming regulations, and tax reporting obligations.
• Legitimate interests: Processing necessary for jljph's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for marketing communications or optional personalisation features. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing and Disclosure

jljph does not sell your personal data to third parties. jljph may share your personal 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, BDO, BPI, Metrobank, and other payment service providers, solely for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers engaged by jljph to verify player identities in compliance with regulatory requirements.
• Fraud prevention and security services: Third-party providers that assist jljph in detecting and preventing fraudulent activity, money laundering, and other prohibited conduct on the Platform.
• Technology and hosting providers: Cloud hosting, data storage, and software service providers that support the operation of the jljph Platform, all of whom are bound by strict data processing agreements.
• Regulatory and law enforcement authorities: Government agencies, regulatory bodies, and law enforcement authorities in the Philippines where jljph is legally required or permitted to disclose your data, including in response to lawful requests, court orders, or regulatory investigations.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by jljph in connection with the operation of its business, subject to professional confidentiality obligations.

Any third party with whom jljph shares personal data is required to handle that data in accordance with applicable data protection laws and jljph's data protection standards. jljph remains responsible for ensuring that such third parties provide adequate protection for your personal data.

7 Data Retention

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

• Account and identity data: Retained for the duration of your active account on jljph, and for a minimum of five (5) years following account closure, in compliance with Philippine AML and gaming regulatory requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine financial regulations.
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and regulatory compliance purposes.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Technical and usage data: Retained for up to twelve (12) months from collection, unless required for longer for security or fraud investigation purposes.

Upon expiry of the applicable retention period, jljph will securely delete or anonymise your personal data in accordance with its data disposal procedures. Where anonymisation is not practicable, data will be securely destroyed.

8 Data Security

jljph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Industry-standard SSL/TLS encryption for all data transmitted between your device and the jljph Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Strict access controls ensuring that personal data is accessible only to jljph personnel and authorised third parties who have a legitimate need to access it.
• Regular security audits, vulnerability assessments, and penetration testing of the jljph Platform and supporting infrastructure.
• Multi-factor authentication requirements for access to systems containing personal data.
• Comprehensive staff training on data protection obligations and security best practices.
• Incident response procedures to detect, contain, and report data breaches in accordance with applicable legal requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jljph will notify you and the National Privacy Commission of the Philippines in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

9 Cookies and Tracking Technologies

jljph uses cookies and similar tracking technologies on the Platform to enhance your experience, ensure the Platform functions correctly, and gather analytics data. The following types of cookies are used on jljph:

• Strictly necessary cookies: Essential for the operation of the jljph Platform, including maintaining your login session, remembering your preferences, and ensuring secure transactions. These cookies cannot be disabled without affecting Platform functionality.
• Performance and analytics cookies: Used to collect anonymised information about how players use the jljph Platform, including which pages are visited most frequently and how players navigate between pages. This data helps jljph improve the Platform experience.
• Functionality cookies: Used to remember your preferences and settings on jljph, such as your preferred language or display settings, to provide a more personalised experience.
• Security cookies: Used to detect and prevent fraudulent activity, protect against unauthorised access, and support jljph's overall security infrastructure.

You may control cookie settings through your browser preferences. Please note that disabling certain cookies may affect the functionality of the jljph Platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the Platform.

jljph does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

10 Your Data Privacy Rights

As a data subject under the Data Privacy Act of 2012 of the Philippines, you have the following rights in respect of your personal data held by jljph:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data jljph holds about you, along with information about how it is being used.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data jljph holds about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jljph'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 jljph's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe jljph has processed your personal data in violation of applicable data protection law.

To exercise any of the above rights, please contact jljph's Data Protection Officer using the contact details provided in Section 13. jljph will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with the requirements of the Data Privacy Act of 2012.

Please note that certain rights are subject to limitations and exceptions under applicable law. For example, jljph may be unable to delete data that it is legally required to retain for regulatory compliance purposes.

11 Protection of Minors

The jljph Platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming regulations. jljph does not knowingly collect personal data from individuals under the age of 21.

jljph employs age verification procedures at the point of registration and may conduct additional verification checks at any time. If jljph discovers that personal data has been collected from a person under the age of 21, it will immediately close the associated account, delete the personal data in question, and return any deposited funds where legally required.

If you are a parent or guardian and believe that your child under the age of 21 has registered on jljph or provided personal data to jljph, please contact us immediately using the details in Section 13 so that we can take appropriate action without delay.

12 Changes to This Privacy Policy

jljph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services offered on the Platform. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Policy, jljph will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect. Your continued use of the jljph Platform following the effective date of any amendment constitutes your acknowledgement of the revised Policy.

jljph recommends that you review this Privacy Policy periodically to stay informed of how your personal data is being protected. If you do not agree with any changes to this Policy, you should cease using the Platform and may request account closure.

13 Contact Our Data Protection Officer

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

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. jljph encourages you to contact us first so we can address your concern directly and promptly.