PRIVACY POLICY

1. INTRODUCTION

JL117 Casino (hereinafter "JL117," "we," "us," or "our") operates the online gaming platform accessible at jl117.cam and related mobile applications. We are committed to protecting the privacy and security of personal information provided by our users (hereinafter "you," "your," or "User"). This Privacy Policy governs the collection, processing, storage, disclosure, and protection of personal data in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and applicable PAGCOR directives.

By creating an account with JL117, accessing our services, or providing personal information through any channel, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, you must immediately discontinue use of JL117 services.

2. DATA CONTROLLER INFORMATION

JL117 Casino is the data controller responsible for processing your personal information. We are registered with the National Privacy Commission (NPC) of the Philippines and maintain compliance with all applicable data protection regulations. For privacy-related inquiries, data subject requests, or complaints, you may contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: "Privacy Request" or "Data Protection Inquiry"
• Response Time: We will respond to all privacy-related requests within fifteen (15) business days

3. PERSONAL INFORMATION WE COLLECT

3.1 Information You Provide Directly

When you register for a JL117 account, we collect the following personal information:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification numbers (passport, driver's license, national ID card)
• Contact Information: Email address, mobile telephone number, residential address including street, barangay, city/municipality, province, and postal code
• Account Credentials: Username, password (stored in encrypted format), security questions and answers
• Financial Information: GCash mobile number, PayMaya account details, bank account numbers, payment transaction history, deposit and withdrawal records
• Verification Documents: Copies of government-issued identification, proof of address documents (utility bills, bank statements), selfie photographs for identity verification

3.2 Information We Collect Automatically

When you access JL117 services, we automatically collect certain technical and usage information:

• Device Information: Device type (mobile, tablet, desktop), operating system and version, browser type and version, device identifiers, screen resolution
• Connection Information: IP address, internet service provider, geographic location (city/region level), connection type (WiFi, mobile data)
• Usage Data: Pages visited, games played, bet history, session duration, timestamps, click patterns, features accessed
• Cookies and Similar Technologies: Session cookies, persistent cookies, local storage data, advertising identifiers

3.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment Processors: Transaction confirmation, payment status, fraud detection signals from GCash, PayMaya, and banking partners
• Identity Verification Services: Validation of government-issued IDs, fraud prevention data, sanctions screening results
• Marketing Partners: Referral source information, campaign performance data (provided you consented to such sharing)

4. HOW WE USE YOUR PERSONAL INFORMATION

JL117 processes your personal information for the following lawful purposes:

4.1 Account Management and Service Provision

• Creating and maintaining your JL117 user account
• Verifying your identity and age (21+ requirement) in compliance with PAGCOR regulations
• Processing deposits, withdrawals, and financial transactions
• Providing customer support and responding to inquiries
• Administering bonuses, promotions, and loyalty rewards
• Maintaining game history and transaction records

4.2 Legal and Regulatory Compliance

• Complying with PAGCOR licensing requirements and gaming regulations
• Fulfilling anti-money laundering (AML) and counter-terrorism financing (CTF) obligations under Republic Act No. 9160 (Anti-Money Laundering Act), as amended
• Conducting Know Your Customer (KYC) verification procedures
• Responding to legal requests, court orders, or law enforcement inquiries
• Investigating and preventing fraud, illegal activities, and terms violations
• Maintaining audit trails and compliance records as required by regulators

4.3 Security and Fraud Prevention

• Detecting and preventing fraudulent transactions, account takeovers, and security breaches
• Monitoring for unusual betting patterns, collusion, or advantage play
• Protecting against unauthorized access, malware, and cyber attacks
• Enforcing our Terms and Conditions and protecting our legal rights

4.4 Communication and Marketing

• Sending transactional emails and SMS notifications regarding your account (deposits, withdrawals, important updates)
• Providing promotional offers, bonus announcements, and marketing communications (only if you have consented)
• Conducting customer satisfaction surveys and collecting feedback
• Notifying you of changes to our Terms, Privacy Policy, or services

4.5 Service Improvement and Analytics

• Analyzing user behavior to improve platform performance, user experience, and game offerings
• Conducting research and statistical analysis on gaming trends and player preferences
• Testing new features and optimizing website functionality
• Personalizing content and game recommendations based on your preferences

5. LEGAL BASIS FOR PROCESSING

Under the Philippine Data Privacy Act, we process your personal information based on the following legal grounds:

• Consent: You have provided explicit consent for specific processing activities, such as receiving marketing communications
• Contract Performance: Processing is necessary to fulfill our contractual obligations under the Terms and Conditions you agreed to when registering
• Legal Obligation: Processing is required to comply with PAGCOR regulations, anti-money laundering laws, tax obligations, and other Philippine legal requirements
• Legitimate Interests: Processing is necessary for our legitimate business interests in preventing fraud, maintaining security, and improving services, provided such interests do not override your fundamental rights and freedoms

6. DATA SHARING AND DISCLOSURE

JL117 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality obligations:

6.1 Service Providers and Business Partners

• Payment Processors: GCash, PayMaya, banking institutions, and payment gateways to process deposits and withdrawals
• Game Providers: JILI Gaming, Pragmatic Play, Evolution Gaming, and other licensed game developers to deliver gaming content
• Identity Verification Services: Third-party KYC providers to verify your identity and comply with regulatory requirements
• Cloud Hosting Providers: Secure data centers and cloud infrastructure providers that store our data with appropriate security measures
• Customer Support Tools: Live chat platforms and helpdesk software providers to deliver customer service
• Analytics Providers: Services that help us understand user behavior and improve platform performance (data is anonymized where possible)

6.2 Regulatory and Legal Authorities

We may disclose your personal information to government authorities, regulators, and law enforcement when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with PAGCOR audits, investigations, or regulatory requests
• Cooperate with law enforcement investigations or criminal proceedings
• Respond to valid court orders, subpoenas, or legal processes
• Report suspicious transactions under anti-money laundering regulations
• Protect the rights, property, or safety of JL117, our users, or the public

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor organization, subject to the same privacy protections outlined in this Privacy Policy.

7. DATA SECURITY MEASURES

JL117 implements comprehensive technical, organizational, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and JL117 servers is protected by 256-bit SSL/TLS encryption. Sensitive data stored in our databases is encrypted at rest.
• Access Controls: Strict role-based access controls ensure that only authorized personnel can access personal data on a need-to-know basis. All access is logged and monitored.
• Secure Infrastructure: Our servers are hosted in secure, ISO 27001-certified data centers with 24/7 monitoring, fire suppression systems, and redundant power supplies.
• Regular Security Audits: We conduct regular vulnerability assessments, penetration testing, and security audits performed by independent cybersecurity firms.
• Employee Training: All JL117 personnel undergo mandatory data protection and information security training.
• Incident Response: We maintain a comprehensive incident response plan to quickly detect, contain, and remediate security breaches.

While we implement industry-standard security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security but will promptly notify you and relevant authorities in the event of any data breach affecting your personal information, as required by the Data Privacy Act.

8. DATA RETENTION

JL117 retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal obligations:

• Active Accounts: Personal data is retained for the duration of your active account relationship with JL117.
• Closed Accounts: After you close your account, we retain necessary records for seven (7) years to comply with PAGCOR regulations, anti-money laundering laws, tax requirements, and to resolve disputes or enforce our Terms.
• Transaction Records: Financial transaction records, bet history, and compliance documentation are retained for at least seven (7) years as required by Philippine gaming and financial regulations.
• Marketing Data: If you unsubscribe from marketing communications, we will retain only the minimum data necessary to honor your opt-out request and prevent future contact.

After the applicable retention period expires, your personal information will be securely deleted or anonymized such that it can no longer identify you.

9. YOUR PRIVACY RIGHTS

Under the Philippine Data Privacy Act, you have the following rights regarding your personal information:

• Right to be Informed: You have the right to know how your personal data is collected, used, shared, and stored, as described in this Privacy Policy.
• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Rectification: You may request correction or update of inaccurate or incomplete personal information.
• Right to Erasure: You may request deletion of your personal data under certain circumstances, such as when it is no longer necessary for the purposes collected or if you withdraw consent (subject to legal retention obligations).
• Right to Object: You may object to processing of your personal information for direct marketing purposes or when processing is based on legitimate interests.
• Right to Data Portability: You may request to receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission if you believe your privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with "Privacy Request" in the subject line. We will respond to your request within fifteen (15) business days. Identity verification may be required before we process your request to protect your information from unauthorized access.

10. COOKIES AND TRACKING TECHNOLOGIES

JL117 uses cookies and similar tracking technologies to enhance your user experience, analyze platform performance, and deliver personalized content. Cookies are small text files stored on your device that help us recognize you on subsequent visits.

10.1 Types of Cookies We Use

• Essential Cookies: Required for core functionality including login authentication, session management, and security features. These cannot be disabled.
• Performance Cookies: Collect anonymous usage statistics to help us understand how users interact with JL117 and identify areas for improvement.
• Functional Cookies: Remember your preferences such as language settings, game favorites, and display options.
• Advertising Cookies: Track your browsing behavior to deliver relevant promotional offers and measure campaign effectiveness (only with your consent).

You can manage cookie preferences through your browser settings. However, disabling certain cookies may limit your ability to use some features of JL117 services.

11. CHILDREN'S PRIVACY

JL117 services are strictly intended for individuals 21 years of age or older in compliance with Philippine gaming laws. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected data from someone under 21, we will immediately delete that information and terminate the account. Parents or guardians who believe their child has provided information to JL117 should contact us immediately.

12. INTERNATIONAL DATA TRANSFERS

Your personal information is primarily stored on servers located within the Philippines. However, some of our service providers may process data outside the Philippines. When we transfer data internationally, we ensure appropriate safeguards are in place through standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms to protect your information in accordance with Philippine data protection standards.

13. CHANGES TO THIS PRIVACY POLICY

JL117 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. The "Last Updated" date at the top of this document indicates when the most recent changes were made. Material changes will be communicated to you via email, account notification, or prominent notice on our website at least thirty (30) days before taking effect. Your continued use of JL117 services after changes become effective constitutes acceptance of the updated Privacy Policy.

14. CONTACT INFORMATION

For questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact:

• Data Protection Officer Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Response Time: Within 15 business days

You may also file complaints with the National Privacy Commission of the Philippines if you believe your privacy rights have been violated.