Privacy Policy

1. Introduction

JL3 PH ("jl3 ph", "we", "us", or "our") is committed to protecting the privacy and personal data of all players and users of the jl3 ph platform. This Privacy Policy describes how jl3 ph collects, uses, stores, shares, and protects personal information in connection with the operation of our online gaming platform, which is accessible via our website and mobile application.

This policy is issued in compliance with Republic Act No. 10173, the Philippine Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC) of the Philippines. It also reflects internationally recognized data protection principles.

By registering an account, accessing, or otherwise using the jl3 ph platform, 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 are a minor or do not meet the 21-year age requirement under Philippine gaming regulations, you must not use jl3 ph.

2. Personal Data We Collect

2.1 Registration & Account Data

When you create a jl3 ph account, we collect the following information:

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Residential address (including city — Manila, Cebu, Davao, Quezon City, Makati, or elsewhere in the Philippines)
• Email address and mobile number
• Username and encrypted password
• Preferred currency (Philippine Peso / PHP)

2.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) obligations, jl3 ph may collect copies of government-issued identification documents such as a Philippine passport, SSS ID, UMID, driver's license, or PhilSys National ID. We may also collect proof of address documents and proof of payment method ownership.

2.3 Financial & Transaction Data

jl3 ph collects data related to your deposits, withdrawals, and gaming transactions. This includes payment method details (e.g., GCash account reference, PayMaya account reference, BDO, BPI, or Metrobank account details), transaction amounts in Philippine Peso (₱), transaction timestamps, and transaction reference numbers. We do not store full bank account numbers or card numbers on our servers.

2.4 Gaming Activity Data

We collect data about your activity on the jl3 ph platform, including games played, bets placed, wagering history, session durations, login timestamps, and device information. This data is used to operate the platform, detect fraud, and support responsible gaming monitoring.

2.5 Technical & Device Data

When you access jl3 ph, we automatically collect certain technical data, including your IP address, browser type and version, operating system, device identifiers, referring URLs, and pages visited. This data is collected via cookies and similar tracking technologies as described in Section 7.

2.6 Communications Data

If you contact jl3 ph customer support, we retain records of your communications, including emails, live chat transcripts, and support ticket content, for quality assurance and dispute resolution purposes.

3. How We Collect Your Data

jl3 ph collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions.
• Automatically — through cookies, web beacons, and similar tracking technologies when you access the jl3 ph website or mobile application.
• From third-party service providers — including payment processors (GCash, PayMaya, BDO, BPI, Metrobank), identity verification providers, and fraud detection services, who may share data with us in connection with your use of jl3 ph.
• From publicly available sources — where permitted by law, for the purpose of verifying your identity or detecting fraudulent activity.

4. How We Use Your Personal Data

jl3 ph uses the personal data we collect for the following purposes:

5. Legal Basis for Processing

jl3 ph processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given jl3 ph your explicit consent to process your data for a specific purpose, such as receiving marketing communications.
• Contractual Necessity: Where processing is necessary to perform our contract with you — specifically, to operate your jl3 ph account and deliver gaming services.
• Legal Obligation: Where processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations and gaming regulatory requirements.
• Legitimate Interests: Where processing is necessary for jl3 ph's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.

6. Data Sharing & Disclosure

jl3 ph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We 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 Service Providers: GCash, PayMaya, BDO, BPI, Metrobank, and other payment processors, to facilitate deposits and withdrawals in Philippine Peso.
• Identity Verification Providers: Third-party KYC and age verification service providers who assist jl3 ph in verifying player identities and meeting regulatory obligations.
• Fraud Detection & Security Providers: Service providers who assist jl3 ph in detecting and preventing fraudulent activity and ensuring platform security.
• IT & Hosting Providers: Cloud hosting and infrastructure providers who store and process data on behalf of jl3 ph under strict data processing agreements.
• Regulatory & Law Enforcement Authorities: Where required by Philippine law, court order, or regulatory directive, jl3 ph may disclose personal data to government agencies, law enforcement bodies, or gaming regulators.
• Professional Advisors: Legal, accounting, and auditing professionals who require access to data in the course of providing professional services to jl3 ph, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of jl3 ph are required to do so in accordance with our instructions and applicable data protection laws.

7. Cookies & Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the jl3 ph website or use our mobile application. They help us recognize your device, remember your preferences, and improve your experience on the platform.

7.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the operation of jl3 ph, including session management, login authentication, and security functions. These cannot be disabled.
• Performance & Analytics Cookies: Help us understand how players use jl3 ph, which pages are most visited, and where technical issues occur. This data is aggregated and anonymized.
• Functional Cookies: Remember your preferences, such as language settings and display options, to personalize your jl3 ph experience.
• Marketing Cookies: Used to deliver relevant promotional content about jl3 ph. These are only placed where you have provided consent.

7.3 Managing Cookies

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the jl3 ph platform. Strictly necessary cookies cannot be disabled as they are essential to platform operation.

8. Data Retention

jl3 ph retains personal data for as long as is necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, accounting, and reporting obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active jl3 ph account, plus a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering record-keeping requirements.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer Support Communications: Retained for a minimum of two (2) years from the date of the last communication.
• Marketing Consent Records: Retained until you withdraw consent or for three (3) years from the date of last interaction, whichever is earlier.

Upon expiry of the applicable retention period, jl3 ph will securely delete or anonymize your personal data in accordance with our data disposal procedures.

9. Data Security

jl3 ph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the jl3 ph platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the jl3 ph platform.
• Multi-factor authentication requirements for administrative access to jl3 ph systems.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While jl3 ph takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, jl3 ph will notify you and the National Privacy Commission in accordance with applicable legal requirements.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl3 ph:

• Right to Be Informed: The right to be informed about how jl3 ph collects and processes your personal data — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data jl3 ph 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 jl3 ph's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe jl3 ph has violated your data privacy rights.

To exercise any of these rights, please contact the jl3 ph data protection team using the contact details in Section 15. We will respond to all verified requests within thirty (30) days of receipt.

11. Children's Privacy

The jl3 ph platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. jl3 ph 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 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on jl3 ph, please contact our support team immediately so we can investigate and take appropriate action.

12. International Data Transfers

jl3 ph primarily processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines, jl3 ph ensures that such transfers are conducted in accordance with the requirements of the Philippine Data Privacy Act of 2012, including the implementation of appropriate safeguards such as data processing agreements that require the recipient to provide a level of data protection equivalent to that required under Philippine law.

By using jl3 ph, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the operation of the platform, subject to the safeguards described above.

13. Third-Party Links & Services

The jl3 ph platform may contain references to third-party payment services (such as GCash and PayMaya) in the context of processing your transactions. These third-party services operate under their own privacy policies, which are independent of this Privacy Policy. jl3 ph is not responsible for the privacy practices of third-party service providers. We encourage you to review the privacy policies of any third-party services you use in connection with your jl3 ph account.

14. Updates to This Privacy Policy

jl3 ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When we make material changes, we will notify registered players via email or an in-platform notification, and the updated policy will be posted on this page with a revised effective date.

Your continued use of jl3 ph following the posting of any amendments constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how jl3 ph protects your personal data.

15. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by jl3 ph, please contact our Data Protection Officer (DPO) or customer support team. We are committed to addressing all privacy-related inquiries promptly and transparently.