JL128 Privacy Policy

1 About This Privacy Policy

This Privacy Policy ("Policy") describes how JL128 ("JL128," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of players and visitors ("you" or "your") who access or use the JL128 online gaming platform at jl128.app and through the JL128 mobile application (collectively, the "Platform").

This Policy forms part of the JL128 Terms & Conditions and should be read alongside them. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

JL128 is committed to complying with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

If you have any questions about this Policy or how JL128 handles your personal data, please contact our Data Protection Officer using the details provided in Section 13 of this Policy.

2 Personal Data We Collect

JL128 collects personal data in the following categories, depending on how you interact with the Platform:

2.1 Registration & Identity Data

When you create a JL128 account, we collect:

• Full legal name;
• Date of birth (to verify the 21+ age requirement);
• Mobile number and email address;
• Username and encrypted password;
• Residential address (for identity verification purposes).

2.2 Identity Verification (KYC) Data

To comply with Philippine anti-money laundering regulations and PAGCOR requirements, we may collect:

• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID);
• Proof of address documents;
• Selfie or facial image for document verification;
• Source of funds documentation where required.

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records;
• Payment method details (GCash mobile number, Maya account, bank account details for BPI, BDO, Metrobank);
• Transaction amounts, dates, and reference numbers;
• Wagering history and game activity records.

2.4 Technical & Usage Data

• IP address and approximate geographic location;
• Device type, operating system, and browser information;
• Session duration, pages visited, and features used;
• Login timestamps and access logs;
• Crash reports and error logs.

2.5 Communications Data

• Records of your communications with JL128 support via live chat or email;
• Feedback, survey responses, and promotional opt-in preferences.

3 How We Use Your Personal Data

JL128 uses the personal data we collect for the following purposes:

3.1 Account Management & Service Delivery

• Creating and maintaining your JL128 player account;
• Processing deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other supported payment channels;
• Providing access to games, promotions, and the JL128 Rewards program;
• Delivering customer support and responding to your enquiries.

3.2 Regulatory Compliance

• Verifying your identity and age (21+) as required under Philippine gaming regulations;
• Complying with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations;
• Maintaining transaction records as required by applicable Philippine law;
• Responding to lawful requests from Philippine regulatory authorities, including PAGCOR and the NPC.

3.3 Security & Fraud Prevention

• Detecting and preventing fraudulent activity, bonus abuse, and multi-accounting;
• Monitoring for suspicious transactions and unusual account behaviour;
• Protecting the integrity of the JL128 platform and its player community.

3.4 Platform Improvement

• Analysing usage patterns to improve game offerings, platform performance, and user experience;
• Conducting internal research and analytics to develop new features;
• Troubleshooting technical issues and resolving platform errors.

3.5 Marketing & Promotions

Where you have provided consent, JL128 may use your contact details to send you information about promotions, bonuses, new games, and platform updates. You may withdraw your consent to receive marketing communications at any time by updating your notification preferences in your account settings or by contacting our support team.

4 Legal Basis for Processing

JL128 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its implementing rules:

• Contractual Necessity: Processing required to fulfil our obligations under the JL128 Terms & Conditions, including account management and payment processing;
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including AML/CTF obligations and PAGCOR licensing requirements;
• Legitimate Interests: Processing necessary for JL128's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications and certain optional data collection activities. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 Data Sharing & Disclosure

JL128 does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

5.1 Service Providers

JL128 engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, Maya, BPI, BDO, Metrobank), identity verification providers, cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only on JL128's instructions and in accordance with applicable data protection laws.

5.2 Regulatory & Law Enforcement Authorities

JL128 may disclose your personal data to Philippine government agencies, regulatory bodies (including PAGCOR and the NPC), law enforcement authorities, or courts where required to do so by applicable law, court order, or regulatory direction. JL128 will notify you of such disclosure where permitted by law.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of JL128's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Policy that result from it.

5.4 With Your Consent

JL128 may share your personal data with other third parties where you have provided your explicit consent to such sharing. You may withdraw this consent at any time.

6 Cookies & Tracking Technologies

JL128 uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session security, and analyse platform usage. The types of cookies we use include:

• Essential Cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled without affecting Platform functionality;
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping us identify areas for improvement;
• Preference Cookies: Used to remember your settings and preferences, such as language and display options;
• Marketing Cookies: Used, with your consent, to deliver relevant promotional content within the JL128 Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the JL128 Platform. For more information on managing cookies, refer to your browser's help documentation.

7 Data Security

JL128 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and JL128's servers;
• AES-256 encryption for sensitive data stored in our databases;
• Two-factor authentication (2FA) available for all player accounts;
• Regular security audits and penetration testing by independent security professionals;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Comprehensive staff training on data protection and information security practices.

8 Data Retention

JL128 retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by AML regulations;
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with Philippine financial record-keeping requirements;
• KYC documentation: Retained for the duration of your account and for five (5) years following account closure;
• Communications and support records: Retained for three (3) years from the date of the communication;
• Technical and usage logs: Retained for up to twelve (12) months, after which they are anonymised or deleted.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, JL128 will securely delete or anonymise the data in accordance with our internal data disposal procedures.

9 Your Data Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by JL128:

• Right to be Informed: The right to be informed about how your personal data is collected and processed, as set out in this Policy;
• Right of Access: The right to request a copy of the personal data JL128 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 where it is no longer necessary for the purposes for which it was collected, subject to JL128's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• 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 (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact JL128's Data Protection Officer using the contact details in Section 13. JL128 will respond to all verified data rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified of any such extension.

10 Children's Privacy

The JL128 Platform is strictly intended for adults aged 21 years and older. JL128 does not knowingly collect personal data from persons under the age of 21. If you are under 21, you must not register an account or use the Platform.

If JL128 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the JL128 Platform, please contact our support team immediately.

11 Third-Party Links

The JL128 Platform may contain links to third-party websites or services, such as payment provider portals. JL128 is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party services you access through or in connection with the JL128 Platform.

This Policy applies solely to personal data collected by JL128 through the Platform. It does not apply to data collected by third-party payment processors or other external services, which are governed by their own privacy policies.

12 Changes to This Privacy Policy

JL128 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or regulatory requirements. Where changes are material, JL128 will provide reasonable advance notice via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the JL128 Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure.

We encourage you to review this Policy periodically to stay informed about how JL128 protects your personal data.

13 Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or JL128's data protection practices, please contact our Data Protection Officer (DPO):

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data rights under the Data Privacy Act of 2012 have not been respected by JL128.