jl1 Privacy Policy

1. Introduction

jl1 ("jl1," "we," "us," "our") operates the online gaming platform accessible at jl1.lat. We are committed to protecting the personal data of all players, visitors, and users ("you," "your") of the jl1 platform in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable PAGCOR licensing requirements.

This Privacy Policy describes the types of personal information we collect, the purposes for which we process it, with whom we share it, how long we retain it, and the rights available to you as a data subject under Philippine law.

By registering a jl1 account or using any part of the Platform, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read together with the jl1 Terms & Conditions.

2. Data Controller

jl1 is the personal information controller ("PIC") as defined under Republic Act 10173. jl1 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable law.

jl1 has appointed a Data Protection Officer ("DPO") in compliance with NPC requirements. Contact details for the DPO are available via jl1 Live Chat or the support email address in the footer of this page.

3. Personal Data We Collect

jl1 collects the following categories of personal data:

jl1 does not collect sensitive personal information (as defined under RA 10173) unless required for PAGCOR compliance or specifically consented to by you.

4. How We Collect Your Data

jl1 collects personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing KYC, making a deposit or withdrawal request, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically via cookies, log files, and analytics tools when you access and navigate the jl1 platform.
• Third-party payment processors: Transaction confirmation and verification data received from GCash, PayMaya, and Philippine banking partners when you process a deposit or withdrawal.
• Identity verification services: Data returned from KYC verification providers used to confirm your identity in compliance with PAGCOR requirements.
• PAGCOR and regulatory sources: Information received from PAGCOR in connection with regulatory compliance, including self-exclusion registrations.

5. Legal Basis for Processing

jl1 processes your personal data on the following legal bases as recognised under RA 10173:

• Contractual necessity: Processing required to fulfil the contract between jl1 and you as a registered player (e.g., account operation, payment processing, game delivery).
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) requirements, and other applicable Philippine laws.
• Legitimate interests: Processing carried out for jl1's legitimate business interests (e.g., fraud prevention, platform security, service improvement) where these interests are not overridden by your rights.
• Consent: Processing for optional activities such as marketing communications, where you have provided freely given, specific, and informed consent. You may withdraw marketing consent at any time.

6. How We Use Your Personal Data

jl1 uses personal data collected for the following purposes:

• To create, verify, and manage your jl1 player account;
• To process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers;
• To verify your age (21+) and identity as required by PAGCOR;
• To deliver the games and services available on the jl1 platform;
• To detect and prevent fraud, money laundering, and prohibited conduct under our Terms & Conditions;
• To comply with PAGCOR regulatory reporting, record-keeping, and audit requirements;
• To respond to your customer support enquiries;
• To send transactional communications (deposit confirmations, withdrawal status, security alerts);
• To send marketing communications about promotions and new features, where you have consented;
• To operate responsible gaming tools, including deposit limits, session reminders, and self-exclusion;
• To improve, personalise, and maintain the performance of the jl1 platform.

7. Data Sharing and Disclosure

jl1 does not sell your personal data. We may share your data with the following categories of recipients only as necessary:

• Payment processors: GCash (G-Xchange, Inc.), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank, for the purpose of processing your deposits and withdrawals;
• KYC / identity verification providers: Third-party services used to verify government-issued Philippine IDs in compliance with PAGCOR KYC requirements;
• PAGCOR: The Philippine Amusement and Gaming Corporation, as required by our operating license and applicable regulations;
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports and other disclosures required under the Anti-Money Laundering Act and its amendments;
• IT infrastructure and cloud providers: Hosting, database, and security service providers operating under contractual data processing agreements that require compliance with RA 10173;
• Law enforcement and courts: Where disclosure is required by a valid court order, subpoena, or statutory obligation.

Any third-party service providers acting as personal information processors on behalf of jl1 are bound by data processing agreements requiring equivalent data protection standards.

8. Cookies and Tracking Technologies

jl1 uses cookies and similar tracking technologies to operate the Platform, remember your session, detect fraud, and analyse usage patterns. The following types of cookies are used:

• Essential cookies: Required for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and wallet access.
• Analytics cookies: Used to understand how players navigate the Platform so we can improve the user experience. Data is aggregated and does not identify you individually.
• Security cookies: Used to detect unusual login behaviour and protect against account takeover and fraud.

You may manage non-essential cookies through your browser settings. Disabling essential cookies will impair your ability to use the jl1 Platform.

9. Data Retention

jl1 retains your personal data for as long as your account is active and for a minimum of five (5) years following account closure, as required by PAGCOR's record-keeping requirements and the Anti-Money Laundering Act.

Specific retention periods by data category:

• Account and identity data: 5 years post-account closure (PAGCOR / AMLA requirement);
• Transaction records: 5 years post-transaction (AMLA / PAGCOR requirement);
• Support communications: 2 years from the date of the interaction;
• Marketing consent records: Until consent is withdrawn, plus 1 year thereafter;
• Technical / session logs: 12 months from the date of collection.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised.

10. Data Security

jl1 implements technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction, including:

• SSL / TLS encryption for all data in transit;
• Encryption at rest for sensitive financial and identity data;
• Access controls limiting data access to authorised personnel on a need-to-know basis;
• Regular security assessments and penetration testing;
• Staff training on data privacy obligations under RA 10173.

In the event of a personal data breach that is likely to result in serious harm, jl1 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of discovery and will inform affected data subjects as required by law.

11. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl1:

• Right to be informed: The right to know what personal data jl1 collects and how it is processed — as described in this Policy;
• Right of access: The right to obtain a copy of the personal data jl1 holds about you;
• Right to rectification: The right to have inaccurate or incomplete personal data corrected;
• Right to erasure: The right to request deletion of personal data that is no longer necessary, subject to jl1's legal retention obligations;
• Right to object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to data portability: The right to receive your data in a structured, commonly used format;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, contact jl1 via Live Chat or the support email in the footer. jl1 will respond within thirty (30) calendar days of receiving a verified request.

12. Children's and Minors' Privacy

jl1 is strictly for adults 21 years of age or older as required by PAGCOR. The Platform does not knowingly collect or process personal data of persons under 21 years of age. If jl1 discovers that personal data has been collected from a person under the required age, that account will be suspended and the data deleted as soon as practicable.

If you are a parent or guardian and believe your child or a minor has accessed jl1 and provided personal data, please contact us immediately via Live Chat.

13. Third-Party Services and Links

The jl1 Platform does not contain links to external third-party websites. However, jl1 uses third-party service providers (payment processors, KYC verifiers, analytics providers) as described in Section 7. These providers operate under their own privacy policies and data processing agreements with jl1.

jl1 is not responsible for the privacy practices of third-party services accessed independently outside of the jl1 Platform (e.g., your GCash or PayMaya app, or your bank's internet banking portal).

14. Changes to This Privacy Policy

jl1 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, PAGCOR requirements, or applicable law. Material changes will be notified to registered players via email or prominent in-platform notice at least fourteen (14) days before the revised Policy takes effect.

The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the jl1 Platform after the effective date of a revised Policy constitutes acceptance of the updated terms.

15. Contact and Complaints

For all data privacy enquiries, requests to exercise your rights, or complaints regarding jl1's handling of your personal data, please contact jl1's Data Protection Officer via:

• Live Chat: Available 24/7 directly on the jl1 Platform;
• Email: [email protected] (displayed as plain text — not a clickable link).

If you are not satisfied with jl1's response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which has jurisdiction over data privacy matters under RA 10173. Further information about the NPC's complaint process is available on the NPC's official government website.