Privacy Policy – jllpub Online Casino

1. Introduction and Scope

This Privacy Policy ("Policy") applies to all personal data collected, processed, stored, and shared by jllpub ("jllpub", "we", "us", "our") in connection with your use of the online gaming platform accessible at jllpub.app, including all associated pages, features, mobile interfaces, and customer support channels (collectively, the "Platform").

By registering an account on jllpub, accessing the Platform, or submitting any personal information to us, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with the terms of this Policy, please discontinue your use of the jllpub Platform and contact us to close your account.

This Policy is to be read alongside jllpub's Terms & Conditions. In the event of any conflict between this Policy and the Terms & Conditions regarding data privacy matters, this Policy shall prevail.

2. Data Controller

jllpub is the data controller responsible for the personal data of all registered members and visitors to the Platform. As data controller, jllpub determines the purposes for which and the means by which your personal data is processed.

jllpub's data privacy practices are designed to comply with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) of the Philippines, and its implementing rules and regulations as administered by the National Privacy Commission (NPC).

For all data privacy enquiries, please contact our designated Data Privacy Officer at [email protected].

3. Personal Data We Collect

jllpub collects the following categories of personal data from its members and Platform visitors:

Identity and Contact Information:

• Full legal name as it appears on a government-issued ID;
• Date of birth (for age verification purposes — minimum 21 years);
• Nationality and country of residence;
• Email address and Philippine mobile number;
• Residential address, including barangay, city or municipality, and province.

Financial and Payment Data:

• GCash account number or Maya mobile number linked to your jllpub wallet;
• Philippine bank account details (BPI, BDO, UnionBank, Metrobank) where used for withdrawals;
• Transaction records including deposit amounts, withdrawal requests, and bonus activity;
• USDT wallet addresses where cryptocurrency transactions are conducted.

Identity Verification Documents (KYC):

• Copies of government-issued identification (UMID, PhilSys ID, passport, driver's license, SSS/GSIS ID);
• Selfie photographs submitted for facial verification purposes;
• Proof of address documents where requested.

Platform Usage and Technical Data:

• IP address, device type, browser type, and operating system;
• Login timestamps, session durations, and access logs;
• Game history, wagering records, and account activity logs;
• Geolocation data (city-level) where permitted by your device settings.

4. How We Collect Your Data

jllpub collects personal data through the following channels:

• Account Registration: Information you provide directly when creating your jllpub account, including name, email, date of birth, and contact number;
• KYC Verification: Documents and photographs submitted in response to jllpub's identity verification requests;
• Payment Processing: Transaction data received from Philippine e-wallet providers (GCash, Maya), banks, and cryptocurrency gateways when you deposit or withdraw funds;
• Platform Interaction: Automatically collected data generated by your use of the Platform, including login events, game participation, and support interactions;
• Cookies and Tracking: Technical data collected via cookies, web beacons, and similar technologies as described in Section 8 of this Policy;
• Customer Support: Information you provide when contacting jllpub's support team via live chat or email.

5. Legal Basis for Processing

jllpub processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its implementing rules:

• Consent: Where you have given explicit consent to the processing of your personal data for specific purposes, such as receiving promotional communications;
• Contractual Necessity: Where processing is necessary to perform the contract between you and jllpub — specifically, to operate your account, process deposits and withdrawals, and provide access to Platform features;
• Legal Obligation: Where processing is required to comply with applicable Philippine law, including Anti-Money Laundering Act (AMLA) obligations, PAGCOR reporting requirements, and NPC data breach notification requirements;
• Legitimate Interests: Where processing is necessary for jllpub's legitimate business interests, including fraud prevention, platform security, and service improvement, provided such interests do not override your fundamental rights and freedoms.

6. How We Use Your Personal Data

jllpub uses the personal data collected from you for the following purposes:

• To create, manage, and maintain your jllpub account;
• To verify your identity and age (21+ requirement) in compliance with PAGCOR regulations and jllpub's KYC obligations;
• To process deposits, withdrawals, and other financial transactions via GCash, Maya, Philippine banks, and other supported payment methods;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To provide personalized game recommendations and promotional offers where you have consented to receive such communications;
• To deliver customer support and respond to account enquiries;
• To comply with anti-money laundering (AML) reporting obligations under Philippine law;
• To conduct platform analytics and improve the jllpub user experience;
• To enforce jllpub's Terms & Conditions and Responsible Gaming policies, including self-exclusion requests.

7. Sharing and Disclosure of Personal Data

jllpub does not sell, rent, or trade your personal data to third parties for their independent marketing purposes. jllpub may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash (GXI), Maya (PayMaya Philippines), BancNet, and other financial institutions through which your transactions are processed;
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged by jllpub to perform identity and document verification;
• Game Software Providers: Licensed game studios whose products are integrated into the jllpub Platform, to the extent necessary for gameplay and audit purposes;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law;
• IT and Cloud Service Providers: Hosting, security, and infrastructure providers operating under data processing agreements with jllpub that require them to protect your data to equivalent standards;
• Professional Advisors: Legal counsel, auditors, and compliance consultants, under strict obligations of confidentiality.

Any third party receiving personal data from jllpub is contractually required to handle such data securely, use it only for the specified purpose, and comply with the Data Privacy Act of 2012.

8. Cookies and Tracking Technologies

jllpub uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Strictly necessary to enable core Platform functionality, including login session management, security, and account access. These cannot be disabled.
• Functional Cookies: Used to remember your preferences, language settings, and session history to provide a more personalized experience on jllpub.
• Analytics Cookies: Used to collect aggregated, anonymized data about how visitors use the Platform, enabling jllpub to identify improvement opportunities. No individual player is personally identified through analytics data.
• Security Cookies: Used to detect and prevent fraudulent login attempts, account takeover activity, and bot traffic.

You may manage your cookie preferences through your browser settings. Please note that disabling non-essential cookies may affect the functionality of certain jllpub Platform features. jllpub does not use third-party advertising cookies or behavioral tracking for cross-site advertising purposes.

9. Data Retention

jllpub retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and Identity Data: Retained for the lifetime of your jllpub account and for a minimum of five (5) years following account closure, as required by Philippine AMLA obligations;
• Transaction Records: Retained for a minimum of five (5) years from the date of the relevant transaction, in accordance with AMLC record-keeping requirements;
• KYC Documents: Retained for the duration of the account relationship and for five (5) years post-closure;
• Support and Communication Records: Retained for a period of two (2) years from the date of the relevant communication;
• Technical and Log Data: Retained for a period of twelve (12) months from the date of collection.

Upon expiry of the applicable retention period, jllpub will securely delete or anonymize your personal data in accordance with NPC guidelines.

10. Data Security

jllpub implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the jllpub Platform;
• Encryption of sensitive data fields (including payment credentials and KYC documents) at rest;
• Role-based access controls limiting employee access to personal data strictly to those with a legitimate operational need;
• Regular penetration testing and security audits of jllpub's infrastructure;
• Multi-factor authentication requirements for internal system access by jllpub staff;
• Data breach incident response procedures aligned with NPC notification requirements.

While jllpub takes all reasonable steps to secure your data, no online platform can guarantee absolute security. You are encouraged to use a strong, unique password for your jllpub account and to enable two-factor authentication where available.

11. Your Rights Under Philippine Data Privacy Law

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

• Right to be Informed: The right to be notified of the manner in which your personal data is being processed;
• Right to Access: The right to request a copy of the personal data jllpub holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure / Blocking: The right to request deletion or blocking of personal data where processing is no longer necessary or lawful, subject to legal retention obligations;
• Right to Object: The right to object to processing of your personal data for direct marketing or where processing is based on legitimate interests;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to Damages: The right to be indemnified for damages sustained due to inaccurate, incomplete, or unlawfully obtained personal data.

To exercise any of these rights, please submit a written request to jllpub's Data Privacy Officer at [email protected]. jllpub will respond to all valid data subject requests within 15 business days. If you are unsatisfied with jllpub's response, you have the right to file a complaint with the National Privacy Commission of the Philippines.

12. Children and Minors

The jllpub Platform is strictly for individuals aged 21 years and above in accordance with PAGCOR's minimum age requirements for online gambling in the Philippines. jllpub does not knowingly collect personal data from any person under the age of 21.

If jllpub becomes aware that personal data has been collected from a person under the age of 21 without verified parental or guardian consent, jllpub will take immediate steps to delete such data and close the associated account. If you believe that a minor has created a jllpub account, please notify us immediately at [email protected].

13. Third-Party Links and Services

The jllpub Platform may contain references to third-party payment service providers (such as GCash and Maya) and game software providers. These third parties operate their own independent privacy policies, which govern any personal data you submit directly to them in connection with payment processing or account management on their own platforms.

jllpub is not responsible for the privacy practices of any third-party service. We encourage you to review the privacy policies of GCash, Maya, and any other third-party provider you interact with in connection with your jllpub account.

14. Changes to This Privacy Policy

jllpub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made, jllpub will notify registered members via email or an in-platform notification prior to the revised Policy taking effect.

The effective date at the top of this Policy indicates when it was last updated. Your continued use of the jllpub Platform after any revision constitutes your acceptance of the updated Privacy Policy. We recommend reviewing this Policy periodically to stay informed of how jllpub protects your personal data.

15. Contact and Data Privacy Officer

For all questions, requests, or concerns relating to this Privacy Policy or jllpub's personal data processing practices, please contact our designated Data Privacy Officer:

• Email: [email protected]
• Platform: jllpub.app
• Response Time: Within 15 business days of receiving a written request
• Language: English and Filipino

If you believe jllpub has breached its obligations under the Data Privacy Act of 2012, you have the right to file a complaint directly with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph. jllpub will cooperate fully with any NPC investigation.