Privacy Policy — jl33 Online Casino & Betting Platform

jl33.biz ("jl33," "we," "us," "our") respects the privacy of its Players and is committed to protecting their personal information. This Privacy Policy ("Policy") explains what personal data jl33 collects from users of the jl33 platform, the purposes for which that data is used, how it is stored and protected, and the rights available to Players in relation to their personal data.

This Policy applies to all individuals who access jl33.biz, register a jl33 account, or otherwise interact with any jl33 service. It should be read together with jl33's Terms & Conditions, which govern the broader relationship between jl33 and its Players.

jl33 processes personal data in accordance with Republic Act No. 10173, the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and applicable guidelines issued by the National Privacy Commission ("NPC") of the Philippines. jl33's data practices also align with PAGCOR's requirements for licensed online gambling operators serving the Philippine market.

For the purposes of the Philippine Data Privacy Act, jl33.biz is the Personal Information Controller ("PIC") in respect of all personal data collected through its platform. This means jl33 determines the purposes for which and the manner in which personal data is processed.

Any service providers engaged by jl33 to assist with platform operations — such as payment processors, identity verification providers, and technology infrastructure vendors — act as Personal Information Processors ("PIPs") and are contractually bound to process data only on jl33's documented instructions and in accordance with applicable Philippine privacy law.

Contact details for the jl33 Data Protection Officer are provided in Section 15 of this Policy.

jl33 collects the following categories of personal information from its Players. Only data that is necessary for the specified purpose is collected — jl33 does not collect excessive or irrelevant personal information.

jl33 does not collect sensitive personal information beyond what is strictly required for age verification (date of birth from government ID) and anti-money laundering compliance. jl33 does not collect information on race, religion, political affiliations, or health status.

jl33 collects personal data through the following methods:

• Direct submission by the Player — during account registration, KYC verification, deposit and withdrawal requests, and customer support interactions;
• Automated collection during platform use — through server logs, session tracking, and platform analytics tools that record technical data such as IP addresses, device characteristics, and gameplay activity as Players use jl33;
• Cookies and similar technologies — as described in Section 10 of this Policy;
• Third-party payment providers — payment references and transaction confirmation data received from GCash, Maya, BPI, BDO, and other payment processors when Players conduct financial transactions on jl33;
• Identity verification providers — in cases where jl33 uses a third-party identity verification service to assist with KYC document authentication, that service returns a verification result and confidence score to jl33, but does not share the underlying document data beyond what jl33 itself already holds.

jl33 processes personal data for the following specific, documented purposes:

1. Account creation and management — to register a Player account, maintain account records, and authenticate Player identity on login;
2. Age and identity verification (KYC) — to verify that Players are at least 21 years of age in compliance with PAGCOR requirements, and to confirm account holder identity for withdrawal security;
3. Payment processing — to process deposits, withdrawals, and refunds in Philippine Pesos via GCash, Maya, and other supported payment methods;
4. Anti-money laundering (AML) compliance — to monitor transactions for patterns consistent with money laundering or financial fraud, and to fulfill reporting obligations under Philippine AML law;
5. Game administration and fair play — to record game outcomes, resolve disputes, enforce bet limits, and detect prohibited activities such as multi-accounting or bot usage;
6. Responsible gaming — to administer deposit limits, self-exclusion, cool-off periods, and session tracking tools, and to identify Players who may be showing signs of problem gambling;
7. Customer support — to respond to Player queries, complaints, and dispute resolution requests;
8. Security and fraud prevention — to detect and investigate unauthorized account access, payment fraud, and other security incidents;
9. Regulatory compliance — to fulfill reporting and record-keeping obligations to PAGCOR and other competent Philippine authorities;
10. Platform improvement — to analyze aggregated, anonymized usage data to improve jl33's game library, user interface, and service quality;
11. Marketing communications — to send promotional offers, bonus notifications, and platform updates to Players who have opted in to receive such communications. Players may withdraw marketing consent at any time via account settings.

Under the Philippine Data Privacy Act, jl33 relies on the following legal bases for processing personal data:

• Contractual necessity — Processing required to fulfill jl33's obligations under the Terms & Conditions agreed to by the Player at registration, including account management, payment processing, and game administration;
• Legal obligation — Processing required to comply with Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act, and the Data Privacy Act itself;
• Legitimate interests — Processing for fraud prevention, platform security, and responsible gaming monitoring, where jl33's legitimate interest in maintaining a safe and fair platform does not override the Player's privacy rights;
• Consent — Processing for marketing communications, where the Player has given explicit opt-in consent. Consent for marketing is not a condition of using jl33 and may be withdrawn at any time.

jl33 does not sell, rent, or trade personal data to third-party marketers or data brokers under any circumstances.

jl33 may share personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment service providers — GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other payment processors, for the purpose of executing deposits and withdrawals. These providers receive only the data necessary to process the specific transaction;
• Identity verification providers — third-party KYC services engaged by jl33 to assist with identity document authentication, bound by confidentiality agreements;
• Technology infrastructure providers — cloud hosting, security, and platform monitoring vendors who process data on jl33's behalf under documented data processing agreements;
• PAGCOR and Philippine regulatory authorities — jl33 is required to provide player records, transaction data, and other information to PAGCOR and other competent authorities upon lawful request;
• Anti-money laundering authorities — financial transaction data may be reported to the Anti-Money Laundering Council (AMLC) of the Philippines where jl33 is required to do so by law;
• Law enforcement agencies — personal data may be disclosed to Philippine law enforcement agencies in response to a valid court order, warrant, or legal obligation;
• Successor entities — in the event of a business merger, acquisition, or transfer of substantially all assets, Player data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

All third parties who receive personal data from jl33 are contractually required to protect that data in accordance with Philippine privacy law and to use it only for the specific purposes for which it was shared.

jl33 retains personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification, unless a specific legal hold requires further retention.

jl33 implements a combination of technical and organizational security measures to protect Player personal data against unauthorized access, accidental loss, destruction, or disclosure. Key security measures include:

• 256-bit SSL/TLS encryption on all data transmission between Players' devices and jl33's servers;
• Encryption of sensitive data at rest, including passwords (stored as salted cryptographic hashes) and financial account references;
• Two-factor authentication (2FA) for Player account access on unrecognized devices, using SMS codes to registered Philippine mobile numbers;
• Role-based access controls limiting jl33 staff access to personal data to those with a documented operational need;
• Segregation of player funds — deposits are held in accounts separate from jl33's operational funds, in accordance with PAGCOR requirements;
• Intrusion detection and security monitoring systems that identify and respond to suspicious access patterns in real time;
• Regular security assessments of jl33's platform infrastructure to identify and remediate vulnerabilities;
• Staff training on data protection obligations and secure data handling practices.

In the event of a personal data breach that is likely to affect Player rights and freedoms, jl33 will notify affected Players and the National Privacy Commission in accordance with the timelines and requirements of the Philippine Data Privacy Act and NPC Circular No. 16-03.

jl33 uses cookies and similar technologies on jl33.biz to support platform functionality and improve the Player experience. The following categories of cookies are in use:

• Strictly necessary cookies — required for core platform functions such as maintaining login sessions, preserving game state, and enabling secure payment flows. These cookies cannot be disabled without impairing platform functionality;
• Functional cookies — remember Player preferences such as language settings, game lobby filters, and responsible gaming tool configurations between sessions;
• Analytics cookies — collect anonymized aggregate data about how Players navigate jl33.biz, which pages are most visited, and where technical errors occur. This data helps jl33 improve the platform. No individually identifiable data is collected through analytics cookies;
• Session cookies — temporary cookies that expire when the Player closes their browser, used to maintain a secure, authenticated session during gameplay.

jl33 does not use third-party advertising cookies or behavioral tracking technologies that profile Players for external advertising purposes. Players may manage cookie preferences through their browser settings. Disabling strictly necessary cookies will impair the ability to use jl33's platform.

Parents and guardians who believe that a minor may have accessed or registered on jl33 should contact jl33 support immediately via live chat or at [email protected]. jl33 will investigate and act on all such reports promptly. jl33 encourages the use of parental control tools on shared devices and recommends that adults keep their jl33 login credentials private and inaccessible to minors in the household.

Under the Philippine Data Privacy Act of 2012, Players have the following rights with respect to their personal data held by jl33. Requests to exercise any of these rights should be directed to jl33's Data Protection Officer using the contact details in Section 15.

jl33 will respond to all verified data rights requests within fifteen (15) business days of receipt. Some requests may be subject to legal limitations — for example, where retention is required by PAGCOR regulation or AML law — in which case jl33 will explain the applicable restriction in its response.

jl33 primarily processes personal data within the Philippines. Where it is necessary to transfer personal data to a service provider or infrastructure vendor operating outside the Philippines — for example, a cloud hosting provider whose data centers are located in other jurisdictions — jl33 ensures that such transfers are conducted in compliance with Section 21 of the Philippine Data Privacy Act and applicable NPC guidelines on cross-border data transfers.

Specifically, jl33 implements contractual safeguards with all overseas recipients of personal data, requiring them to maintain a level of data protection equivalent to that required under Philippine law. Players may request details of any such arrangements by contacting jl33's Data Protection Officer.

jl33 may update this Privacy Policy from time to time to reflect changes in its data practices, legal obligations, or platform services. The "Last Updated" date at the top of this page indicates when the most recent revision was made.

Material changes to this Policy — particularly those that affect how jl33 uses or shares Player data — will be communicated to registered Players via a notification displayed on the jl33 platform upon login, and/or via SMS to the Player's registered Philippine mobile number, prior to the changes taking effect.

Continued use of jl33 after notification of a Policy update constitutes acceptance of the revised Policy. If a Player does not agree with any material change, they may close their account in accordance with Section 9 of the jl33 Terms & Conditions.

The current version of this Policy, as published at jl33.biz/privacy-policy, supersedes all prior versions of the jl33 Privacy Policy.

For questions, requests to exercise data rights, or concerns about jl33's data handling practices, Players may contact jl33's Data Protection Officer through the following channels. All privacy-related correspondence will be treated confidentially and responded to within fifteen (15) business days.

jl33 takes all privacy complaints seriously. Where a complaint cannot be resolved through jl33's internal process, Players are entitled to escalate to the National Privacy Commission without restriction. jl33 will cooperate fully with any NPC investigation.