Privacy Policy – JL92 Online Gaming

01 Introduction

JL92 ("JL92," "we," "us," or "our") operates the online gaming platform accessible at jl92.net and through the JL92 mobile application (collectively, the "Platform"). In the course of providing our services to players across the Philippines — from Metro Manila and Cebu to Davao and Quezon City — JL92 collects and processes certain personal data about you.

This Privacy Policy ("Policy") describes the types of personal data JL92 collects, the purposes for which it is processed, the parties with whom it may be shared, the measures we take to keep it secure, and the rights available to you under applicable Philippine data protection law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

This Policy should be read together with JL92's Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and JL92.

JL92 acts as the personal information controller in respect of the personal data collected through the Platform. If you have any questions about how JL92 handles your personal data, please refer to Section 13 of this Policy for contact details.

02 Data We Collect

JL92 collects the following categories of personal data from players and users of the Platform:

JL92 does not intentionally collect sensitive personal information beyond what is necessary for identity verification, age verification, and compliance with applicable regulations. Where sensitive information is collected — such as government ID details — it is handled with the highest level of care and stored securely.

03 How We Collect Data

JL92 collects personal data through the following means:

• Direct Interactions: Data you provide when registering for a JL92 account, completing identity or age verification, making deposits or withdrawals, contacting JL92 support, or participating in promotions.
• Automated Technologies: Data collected automatically when you access the JL92 Platform, including through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, and browsing behavior on the Platform.
• Payment Processors: Data received from payment service providers such as GCash, PayMaya, BPI, BDO, and Metrobank in connection with deposit and withdrawal transactions.
• Identity Verification Services: Data received from third-party identity verification providers used to confirm your identity and age in compliance with applicable regulations.
• Regulatory and Compliance Sources: Data received from regulatory bodies, law enforcement agencies, or other competent authorities where required by law.

04 Purpose of Processing

JL92 processes your personal data for the following purposes:

• Account Registration and Management: To create and maintain your JL92 account, verify your identity and age, and manage your account settings and preferences.
• Service Delivery: To provide access to JL92 games and features, process deposits and withdrawals, and deliver the services you have requested.
• Financial Transactions: To process payments, verify transaction details, prevent fraud, and comply with anti-money laundering obligations.
• Responsible Gaming: To monitor gaming activity, enforce responsible gaming tools such as deposit limits and self-exclusion, and identify players who may be at risk of problem gambling.
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance with your JL92 account.
• Legal and Regulatory Compliance: To comply with applicable Philippine laws and regulations, including the Data Privacy Act of 2012, anti-money laundering regulations, and gaming regulations.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the features and performance of the JL92 Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.

05 Legal Basis for Processing

JL92 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and JL92, including account registration, service delivery, and payment processing.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including anti-money laundering requirements, age verification obligations, and regulatory reporting duties.
• Legitimate Interests: Processing is necessary for JL92's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided that such interests are not overridden by your rights and interests.
• Consent: Where JL92 relies on your consent as the legal basis for processing — such as for marketing communications — you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

06 Data Sharing

JL92 does not sell your personal data to third parties. JL92 may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors used to facilitate deposits and withdrawals on the JL92 Platform. These providers process your financial data solely for the purpose of completing your transactions.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged by JL92 to verify the identity and age of players in compliance with applicable regulations.
• Technology and Infrastructure Providers: Cloud hosting, data storage, and platform infrastructure providers who process data on JL92's behalf under strict data processing agreements.
• Customer Support Providers: Third-party customer support platforms used to manage and respond to player inquiries and support tickets.
• Regulatory and Law Enforcement Authorities: Government agencies, regulatory bodies, and law enforcement authorities where disclosure is required by applicable Philippine law, court order, or regulatory directive.
• Anti-Money Laundering Compliance: Financial intelligence units and compliance bodies where JL92 is required to report suspicious transactions under applicable anti-money laundering regulations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of JL92's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

All third parties with whom JL92 shares personal data are required to handle such data in accordance with applicable data protection laws and JL92's data processing requirements. JL92 does not authorize third parties to use your personal data for their own independent purposes.

07 Data Retention

JL92 retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

• Active Accounts: Personal data associated with active JL92 accounts is retained for the duration of the account relationship and for a period of at least five (5) years following account closure, in accordance with applicable Philippine regulatory requirements.
• Financial Transaction Records: Records of deposits, withdrawals, and other financial transactions are retained for a minimum of five (5) years from the date of the transaction, as required by anti-money laundering regulations.
• Identity Verification Documents: Copies of identity documents submitted for KYC purposes are retained for the period required by applicable regulations and deleted securely thereafter.
• Support Communications: Records of customer support interactions are retained for a period of three (3) years from the date of the interaction.
• Marketing Data: Data processed for marketing purposes is retained until you withdraw your consent or opt out of marketing communications, after which it is deleted or anonymized.

When personal data is no longer required for the purposes for which it was collected and no legal obligation requires its continued retention, JL92 will securely delete or anonymize the data.

08 Data Security

JL92 takes the security of your personal data seriously. We implement appropriate technical and organizational measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the JL92 Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols. Sensitive data stored on JL92 systems is encrypted at rest.
• Access Controls: Access to personal data is restricted to JL92 personnel and authorized service providers who have a legitimate need to access it for the purposes described in this Policy. All personnel with access to personal data are subject to confidentiality obligations.
• Secure Payment Processing: Financial transactions on the JL92 Platform are processed through secure, PCI-DSS compliant payment channels. JL92 does not store full payment card details on its systems.
• Regular Security Assessments: JL92 conducts regular security assessments and vulnerability testing to identify and address potential security risks in the Platform.
• Incident Response: JL92 maintains an incident response plan to address data security breaches promptly. In the event of a breach that is likely to result in a risk to your rights and freedoms, JL92 will notify the relevant authorities and affected players in accordance with applicable law.

09 Your Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights in respect of your personal data held by JL92:

• Right to Be Informed: You have the right to be informed about how JL92 collects and processes your personal data. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data JL92 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request that JL92 correct any inaccurate or incomplete personal data held about you. You may update certain account information directly through your JL92 account settings.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to JL92's legal obligations to retain certain data.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, subject to JL92's overriding legitimate grounds.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that JL92 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact JL92's data privacy team using the contact details provided in Section 13 of this Policy. JL92 will respond to your request within thirty (30) days of receipt, in accordance with applicable law.

10 Cookies & Tracking Technologies

JL92 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security and fraud prevention measures. The following types of cookies are used on the JL92 Platform:

• Strictly Necessary Cookies: These cookies are essential for the operation of the JL92 Platform. They enable core functions such as account login, session management, and security features. These cookies cannot be disabled without affecting the functionality of the Platform.
• Performance and Analytics Cookies: These cookies collect information about how players use the JL92 Platform, such as which pages are visited most frequently and whether error messages are received. This data is used to improve the Platform's performance and user experience.
• Functional Cookies: These cookies allow the JL92 Platform to remember your preferences and settings, such as your preferred language and display options, to provide a more personalized experience.
• Security Cookies: These cookies are used to detect and prevent fraudulent activity, unauthorized account access, and other security threats on the JL92 Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the JL92 Platform. For strictly necessary cookies, no opt-out is available as they are required for the Platform to function.

11 Minors

The JL92 Platform is strictly intended for individuals who are 21 years of age or older. JL92 does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the registration and KYC process to enforce this requirement.

If JL92 becomes aware that personal data has been collected from an individual under the age of 21, JL92 will take immediate steps to delete that data and close the associated account. Any winnings accrued on an account found to belong to an underage individual will be forfeited in accordance with JL92's Terms & Conditions.

12 Policy Changes

JL92 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or the features and 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, JL92 will notify registered players via the email address associated with their account and/or by posting a prominent notice on the Platform. Your continued use of the JL92 Platform following the posting of a revised Privacy Policy constitutes your acknowledgment of the changes.

JL92 recommends that you review this Privacy Policy periodically to stay informed of how we are protecting your personal data. If you do not agree with any changes to this Policy, you should stop using the Platform and may request account closure in accordance with JL92's Terms & Conditions.

13 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or JL92's handling of your personal data, please contact our data privacy team. JL92 is committed to addressing all privacy-related inquiries promptly and transparently.