Privacy Policy

This Privacy Policy ("Policy") describes how jjl33 Casino, accessible at https://jjl33.cam ("jjl33," "we," "us," or "the Platform"), collects, processes, stores, uses, discloses, and protects the personal data of individuals ("players," "users," or "data subjects") who access or use the jjl33 platform and its associated services.

jjl33 is committed to upholding the data privacy rights of every Filipino player on the platform in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all personal data collected through:

• The jjl33 website at https://jjl33.cam and all subpages.
• Account registration, login, KYC verification, and account management processes.
• Deposit, withdrawal, and payment processing transactions.
• Customer support communications, including live chat and email.
• Promotional campaigns, loyalty programs, and responsible gaming tools.
• Cookies, analytics, and tracking technologies deployed on the platform.

jjl33 Casino acts as the personal information controller ("PIC") in respect of all personal data processed through the platform, as defined under Section 3(h) of the Data Privacy Act of 2012.

As a personal information controller, jjl33:

• Determines the purposes and means for which personal data collected through the platform is processed.
• Is responsible for ensuring that processing activities comply with the Data Privacy Act of 2012, its Implementing Rules and Regulations, and relevant NPC circulars and advisories.
• Has designated a Data Privacy Officer ("DPO") responsible for overseeing compliance with this Policy and handling data subject requests and complaints.

Contact details for the jjl33 Data Privacy Officer are provided in Section 14 of this Policy.

jjl33 collects personal data in the following categories, depending on how you interact with the platform:

jjl33 processes personal data only where a lawful basis for processing exists under the Data Privacy Act of 2012. The applicable legal bases for jjl33's processing activities are as follows:

• Consent (Section 12(a), RA 10173): Processing of personal data for marketing communications and non-essential analytical purposes is carried out on the basis of your express consent, which may be withdrawn at any time through your jjl33 account settings.
• Contractual Necessity (Section 12(b), RA 10173): Processing required to perform the contract between jjl33 and the player — including account management, payment processing, and game service delivery — is carried out on the basis of contractual necessity.
• Legal Obligation (Section 12(c), RA 10173): Processing required to fulfill jjl33's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act of 2012, and other applicable Philippine statutes is carried out on the basis of legal obligation.
• Legitimate Interests (Section 12(f), RA 10173): Processing for fraud detection, account security monitoring, responsible gaming interventions, and platform performance improvement is carried out on the basis of jjl33's legitimate interests, provided these interests are not overridden by the data subject's privacy rights.

jjl33 uses your personal data exclusively for the following purposes:

• Account Registration and Management: Creating, maintaining, and administering your jjl33 player account, including authentication, password management, and account settings.
• Identity Verification (KYC): Verifying your identity and age in compliance with PAGCOR licensing requirements and Philippine AML obligations before processing any withdrawal.
• Payment Processing: Processing deposits from and withdrawals to your GCash account, PayMaya, BDO, BPI, Metrobank, UnionBank, or other supported payment channels registered in your verified name.
• Regulatory Compliance: Meeting jjl33's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act, and other applicable Philippine regulations, including reporting obligations to the AMLC where triggered.
• Fraud Prevention and Security: Detecting and preventing unauthorized account access, fraudulent transactions, money laundering, and abuse of bonus systems. This includes automated monitoring of account activity patterns and technical data such as IP addresses and device identifiers.
• Customer Support: Responding to inquiries, resolving complaints, processing responsible gaming requests, and providing technical assistance through live chat and email.
• Responsible Gaming: Monitoring account activity to identify indicators of problem gambling and providing proactive responsible gaming interventions, including cooling-off suggestions, deposit limit notifications, and self-exclusion processing.
• Platform Improvement: Analyzing anonymized or aggregated platform usage data to improve game recommendations, site navigation, and the overall player experience.
• Marketing Communications (Consent-Based): Sending promotional offers, bonus notifications, and event announcements to players who have opted in to receive marketing communications from jjl33. These communications may reference PBA season promotions, Philippine national holidays, UFC events, and other locally relevant campaigns.

jjl33 shares personal data with third parties only in the following limited and defined circumstances:

• Payment Processing Partners: GCash (GXI), PayMaya (Voyager Innovations), and Philippine bank partners (BDO, BPI, Metrobank, UnionBank) receive the minimum financial data necessary to process your specific transaction. These entities are independently regulated financial institutions subject to BSP oversight and their own data protection obligations.
• KYC and Identity Verification Providers: Third-party identity verification service providers engaged by jjl33 to process government-issued ID documents and perform biometric matching for KYC purposes. These providers operate under strict data processing agreements and are prohibited from retaining or using verification data beyond the scope of the verification service.
• Game Providers: Certified game studios whose titles appear in the jjl33 lobby receive session identifiers and wagering data necessary to deliver game functionality. They do not receive full profile data or payment information. All game providers are subject to PAGCOR certification standards and independent RNG auditing.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities in response to lawful regulatory requests, court orders, or mandatory reporting obligations under Philippine law.
• Platform Technology Providers: Cloud hosting, cybersecurity, and analytics service providers who process data solely on jjl33's instructions under written data processing agreements that impose equivalent data protection obligations.

All third-party service providers who access personal data on behalf of jjl33 are classified as personal information processors under RA 10173 and are contractually required to process data solely for the purposes instructed by jjl33, to maintain appropriate security measures, and to notify jjl33 promptly of any data security incident affecting personal data processed on our behalf.

jjl33 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR licensing conditions. The following general retention periods apply:

• Account Data and KYC Records: Retained for the duration of the active account relationship plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping obligations and AML record retention requirements under RA 9160.
• Transaction Records: Deposit, withdrawal, and wagering transaction records are retained for a minimum of five (5) years from the date of each transaction, consistent with AML record-keeping obligations.
• Customer Support Communications: Live chat transcripts and email correspondence are retained for a minimum of three (3) years from the date of the interaction, or longer where the subject matter involves an open dispute or regulatory inquiry.
• Marketing Preferences and Consent Records: Retained for as long as your account remains active, plus a minimum of one (1) year following account closure or withdrawal of consent, to demonstrate compliance with consent requirements.
• Technical and Security Logs: IP address logs, device records, and security event logs are retained for a minimum of twelve (12) months, or longer where they are relevant to an ongoing security investigation or regulatory inquiry.

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymized in accordance with jjl33's data disposal procedures. Anonymized data may be retained indefinitely for statistical and analytical purposes, as it no longer constitutes personal data under RA 10173.

jjl33 implements comprehensive technical and organizational security measures to protect personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption in Transit: All connections between players' browsers and the jjl33 platform are protected by 256-bit SSL/TLS encryption, the same standard used by Philippine financial institutions including BDO, BPI, and Metrobank for online banking.
• Encryption at Rest: Personal data stored in jjl33's databases, including KYC documents and financial records, is encrypted at rest using AES-256 encryption.
• Access Controls: Internal access to personal data is restricted on a strict need-to-know basis. Employees, contractors, and agents who require access to personal data for their job functions are granted the minimum level of access necessary and are required to authenticate using multi-factor authentication.
• Network Security: jjl33's technical infrastructure is protected by firewalls, intrusion detection systems, and regular penetration testing conducted by independent cybersecurity specialists.
• Incident Response: jjl33 maintains a documented security incident response plan. In the event of a personal data breach affecting the rights of Filipino data subjects, jjl33 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay in accordance with the NPC's breach notification requirements.
• Staff Training: All jjl33 staff with access to personal data undergo mandatory data privacy and security training upon onboarding and on an annual basis thereafter.

The jjl33 platform uses cookies and similar tracking technologies to enable core platform functionality, improve the player experience, and support our security and compliance obligations. The following categories of cookies are used:

• Strictly Necessary Cookies: Session cookies required to maintain your logged-in state, preserve game session continuity, and enable basic platform navigation. These cookies cannot be disabled without impairing your ability to use the platform. No consent is required for strictly necessary cookies under Philippine data privacy law.
• Analytics Cookies: Cookies that collect anonymized or aggregated data about how players navigate and use the jjl33 platform — such as which game categories are most visited, average session duration, and feature usage rates. This data is used solely to improve the platform and is not linked to individual player identities in its analytical form.
• Security and Fraud Prevention Cookies: Cookies and device fingerprinting technologies used to identify unusual login patterns, detect duplicate account attempts, and prevent unauthorized access. These cookies are essential to jjl33's security infrastructure and PAGCOR compliance obligations.
• Preference Cookies: Cookies that remember your language preference, display settings, and other account customizations to improve your experience across sessions.

You may manage non-essential cookie categories through your browser settings (Chrome, Safari, Firefox, and other major browsers all provide cookie management tools in their privacy settings). Blocking analytics or preference cookies will not prevent you from accessing your jjl33 account or playing games. Blocking strictly necessary cookies will impair platform functionality.

As a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights in relation to your personal data held by jjl33:

To exercise any of the above rights, submit a written request to the jjl33 Data Privacy Officer via the contact details provided in Section 14. jjl33 will acknowledge your request within five (5) business days and respond substantively within fifteen (15) business days, extendable by a further fifteen (15) days where the request is complex or voluminous, with prior written notice.

jjl33 Casino is an adult gaming platform. Use of the platform is restricted to individuals aged 21 years and above, in compliance with PAGCOR's minimum age requirements for gambling in the Philippines. jjl33 does not knowingly collect, process, or retain personal data from individuals under the age of 21.

Age verification is a mandatory component of the jjl33 account registration process. Players are required to submit a valid Philippine government-issued ID demonstrating that they are at least 21 years old before withdrawal processing is enabled on their account.

If jjl33 becomes aware that personal data has been submitted by or on behalf of an individual under the age of 21, it will:

• Immediately suspend the account pending investigation.
• Delete the personal data collected without undue delay.
• Refund any real-money deposits made during the period of unauthorized access, after deducting any withdrawals already processed, in accordance with jjl33's Terms & Conditions.
• Report the incident to PAGCOR where required under applicable licensing conditions.

If you believe that a minor may have registered on jjl33 without authorization, please contact us immediately via 24/7 live chat or at the email address provided in Section 14.

Certain personal data processed by jjl33 may be transferred to, stored, or processed outside the Philippines where jjl33's technology infrastructure partners or game provider partners operate servers or data centers in other jurisdictions. Such transfers are carried out in accordance with the Data Privacy Act of 2012 and applicable NPC regulations on cross-border data transfers.

jjl33 ensures that any international transfer of personal data is subject to adequate safeguards, which may include:

• Contractual data protection clauses equivalent to those required under Philippine law, incorporated into data processing agreements with all international third-party processors.
• Transfer to jurisdictions that the NPC has recognized as providing an adequate level of data protection substantially equivalent to Philippine standards.
• Technical measures, including encryption, that protect data during transmission and storage regardless of the jurisdiction in which it is held.

Where required, jjl33 will obtain your explicit consent prior to any international transfer of sensitive personal information (as defined under Section 3(l) of RA 10173), unless such transfer is mandated by law or necessary for the performance of a contract to which you are a party.

jjl33 reserves the right to amend, update, or replace any provision of this Privacy Policy at any time to reflect changes in our data processing practices, updates to Philippine data protection law, new NPC advisories, or changes to the platform's features and services. The current version of this Policy, bearing the most recent effective date, is always accessible at https://jjl33.cam/privacy-policy.

Material amendments — those that affect the basis on which we process your personal data, the categories of data we collect, the purposes for which we use it, or your rights as a data subject — will be communicated to registered players via:

• Email notification to the address registered on your jjl33 account, sent no fewer than fourteen (14) days before the amendment takes effect.
• An in-platform notification displayed upon next login, requiring acknowledgment before platform access continues.

Continued use of the jjl33 platform after the effective date of any amendment constitutes acceptance of the revised Privacy Policy. If you do not agree with the amended Policy, you may exercise your right to request account closure and data erasure (subject to mandatory retention obligations) as described in Sections 10 and 7 of this Policy.

For all matters relating to this Privacy Policy, including requests to exercise your data subject rights, questions about jjl33's data processing practices, or concerns about a potential data privacy violation, please contact the jjl33 Data Privacy Officer through the following channels:

• Email: [email protected] — please include "Data Privacy Request" in the subject line for DPO correspondence.
• 24/7 Live Chat: Accessible directly on the jjl33 platform after login. For data privacy requests, ask to be connected to the Data Privacy Officer or submit your request in writing via chat.

jjl33 will acknowledge all data privacy requests within five (5) business days and will endeavor to resolve substantive requests within fifteen (15) business days.

If you are not satisfied with jjl33's response to your data privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). The NPC's complaint process and contact information are published on the NPC's official website. jjl33 cooperates fully with NPC inquiries and investigations.