JLJLWIN PRIVACY POLICY — YOUR DATA, YOUR RIGHTS

JLJLWIN ("we," "us," "our," or "the Platform") operates the online gaming website accessible at jljlwin.net. JLJLWIN is the data controller responsible for the personal data of players who register and use the platform. We are committed to handling your personal information with transparency, integrity, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA") and its Implementing Rules and Regulations.

As the data controller, JLJLWIN determines the purposes and means by which your personal data is processed. We have designated a Data Protection Officer ("DPO") who oversees our data privacy compliance program and serves as the primary point of contact for data privacy concerns. You may reach our DPO through the contact details provided in Section 14 of this policy.

This Privacy Policy applies to all users of the JLJLWIN platform, including registered players, visitors who browse the website without registering, and any individual who contacts JLJLWIN through our support channels.

JLJLWIN collects the following categories of personal data, depending on how you interact with the platform:

JLJLWIN does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive data — such as government ID numbers — is collected, it is handled with heightened security measures and access controls.

JLJLWIN collects personal data through the following means:

• Direct submission: When you register a JLJLWIN account, complete identity verification, make a deposit or withdrawal, contact our support team, or participate in promotions, you provide data directly to us.
• Automated collection: When you visit the JLJLWIN website, our servers automatically collect technical data such as your IP address, browser type, device identifiers, and browsing behavior through cookies and similar tracking technologies.
• Third-party sources: We may receive data from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank) to verify transactions, and from identity verification service providers to confirm the authenticity of documents submitted during KYC.
• Gaming activity: All gameplay actions on the JLJLWIN platform — including bets placed, games played, and session activity — are automatically recorded by our gaming systems for fairness, security, and regulatory compliance purposes.

JLJLWIN uses your personal data for the following purposes:

• Account creation and management: To register your JLJLWIN account, verify your identity, and maintain your account in good standing.
• Service delivery: To provide access to games, process deposits and withdrawals in Philippine Peso (₱), and deliver the full range of JLJLWIN platform features.
• Identity and age verification: To confirm that you meet the minimum age requirement of 21 years and are eligible to use the JLJLWIN platform under Philippine law.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other security threats.
• Regulatory compliance: To fulfill our obligations under Philippine gaming regulations, anti-money laundering laws, and the Data Privacy Act of 2012.
• Customer support: To respond to your inquiries, resolve disputes, and provide assistance through our support channels.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform improvement: To analyze usage patterns, troubleshoot technical issues, and improve the overall JLJLWIN user experience.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where we have a legitimate interest, and always with an easy opt-out option.

Under the Philippine Data Privacy Act of 2012, JLJLWIN processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and JLJLWIN — specifically, to provide the gaming services you have registered for, process your transactions, and manage your account.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, gaming regulations administered by PAGCOR, and the Data Privacy Act itself.
• Legitimate interests: JLJLWIN processes certain data — such as technical and gaming activity data — based on our legitimate interests in maintaining platform security, preventing fraud, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent — for example, for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

JLJLWIN does not sell, rent, or trade your personal data to third parties. We may share your data with the following categories of recipients only where necessary and under strict data protection obligations:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers receive the minimum data necessary to process your deposits and withdrawals securely.
• Identity verification providers: Third-party KYC service providers may process your identity documents and biometric data to verify your identity on our behalf. These providers are bound by confidentiality agreements and data processing agreements.
• Game providers: Game software providers — such as PG Soft, Pragmatic Play, and Ezugi — may receive anonymized or pseudonymized session data necessary to deliver their games on the JLJLWIN platform.
• Regulatory authorities: JLJLWIN is required by law to share certain data with PAGCOR and other Philippine regulatory and law enforcement authorities upon lawful request, including in connection with anti-money laundering investigations.
• IT and security service providers: Cloud hosting, cybersecurity, and platform infrastructure providers may have access to data as part of their service delivery, subject to strict contractual data protection obligations.
• Professional advisors: Legal counsel, auditors, and compliance consultants may access data on a need-to-know basis and are bound by professional confidentiality obligations.

All third parties with whom JLJLWIN shares personal data are required to handle that data in accordance with the Philippine Data Privacy Act and any applicable contractual data protection requirements. JLJLWIN remains responsible for ensuring that third-party processors handle your data appropriately.

JLJLWIN uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and analyze how the site is used. A cookie is a small text file stored on your device when you visit a website.

The types of cookies used on the JLJLWIN platform include:

• Essential cookies: Required for the platform to function correctly. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery. These cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences — such as language settings and display options — to provide a more personalized experience on JLJLWIN.
• Analytics cookies: Help us understand how players navigate the JLJLWIN platform, which pages are most visited, and where technical issues occur. This data is used in aggregated, anonymized form to improve the platform.
• Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of JLJLWIN marketing campaigns. These are only placed with your consent.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Note that disabling essential cookies may prevent you from logging in or using certain features of the JLJLWIN platform.

JLJLWIN implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• TLS/SSL encryption: All data transmitted between your device and the JLJLWIN platform is encrypted using Transport Layer Security (TLS) protocols.
• Encryption at rest: Sensitive personal data stored in our systems — including identity documents and financial information — is encrypted at rest using industry-standard algorithms.
• Access controls: Access to personal data is restricted to authorized JLJLWIN personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Two-factor authentication: JLJLWIN supports two-factor authentication for player accounts to provide an additional layer of security against unauthorized access.
• Regular security audits: Our platform undergoes regular security assessments, penetration testing, and vulnerability scans to identify and address potential weaknesses.
• Incident response: JLJLWIN maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act.

JLJLWIN retains your personal data for as long as is necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable Philippine law. The following general retention periods apply:

• Account data: Retained for the duration of your active JLJLWIN account, and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
• Transaction records: Financial transaction records are retained for a minimum of five (5) years as required by Philippine AML regulations.
• KYC and identity documents: Retained for the duration of your account and for five (5) years after account closure, or longer if required by a regulatory investigation or legal proceeding.
• Gaming activity logs: Retained for a minimum of two (2) years for dispute resolution and regulatory compliance purposes.
• Support communications: Retained for two (2) years from the date of the last communication, unless the matter relates to an ongoing dispute or legal proceeding.
• Marketing consent records: Retained for as long as you remain a JLJLWIN player, and for one (1) year following account closure or withdrawal of consent.

When personal data is no longer required and no legal retention obligation applies, JLJLWIN will securely delete or anonymize the data so that it can no longer be associated with you.

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

• Right to be informed: You have the right to know what personal data JLJLWIN collects about you, how it is used, and with whom it is shared. This Privacy Policy fulfills that obligation.
• Right of access: You may request a copy of the personal data JLJLWIN holds about you at any time. We will respond to verified access requests within thirty (30) days.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You may update basic account information directly through your JLJLWIN account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations. Note that we cannot delete data we are legally required to retain.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though we may be able to demonstrate compelling grounds to continue.
• Right to data portability: You may request that JLJLWIN provide your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: If you believe JLJLWIN has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 14. We may need to verify your identity before processing your request. We will respond within the timeframes required by the Data Privacy Act.

The JLJLWIN platform is strictly intended for individuals who are 21 years of age or older. JLJLWIN does not knowingly collect personal data from individuals under the age of 21. The minimum age requirement is enforced through mandatory identity and age verification during the account registration process.

If JLJLWIN becomes aware that personal data has been collected from a person under the age of 21 — whether through a false declaration of age or any other means — we will immediately suspend the relevant account, void any transactions, and delete the personal data of the underage individual as promptly as possible, subject to any legal obligations to retain records of the incident.

Parents and guardians who believe that a minor in their care has registered a JLJLWIN account are encouraged to contact our support team immediately so that the account can be investigated and closed without delay.

The JLJLWIN platform may contain references to third-party game providers and payment services. While JLJLWIN takes care to work only with reputable partners, we are not responsible for the privacy practices of third-party services that operate independently of the JLJLWIN platform.

When you interact with a third-party payment provider — such as GCash or PayMaya — to fund your JLJLWIN account, you are also subject to that provider's own privacy policy and terms of service. JLJLWIN encourages you to review the privacy policies of any third-party services you use in connection with your JLJLWIN account.

JLJLWIN does not control and is not responsible for the content, privacy practices, or data handling of any third-party services, and this Privacy Policy does not apply to those services.

JLJLWIN may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email or a prominent in-platform notification prior to the changes taking effect.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how JLJLWIN protects your personal data.

Your continued use of the JLJLWIN platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with any update, you may request account closure by contacting our support team.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way JLJLWIN handles your personal data, please contact our Data Protection Officer. We are committed to addressing all data privacy inquiries promptly and transparently.

You can reach the JLJLWIN Data Protection Officer and general support team through our 24/7 live chat on the platform, or by email. Our contact email is displayed below as plain text — please copy it manually:

If you are not satisfied with JLJLWIN's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). The NPC is the government body responsible for administering and enforcing the Data Privacy Act of 2012.