jl9999 Casino – Privacy Policy

1. Introduction

1.1 jl9999 ("we," "us," "our," "the Platform") operates the online gaming platform accessible at jl9999.one and is committed to protecting the privacy and personal data of all users ("you," "the Player," "data subject") in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission of the Philippines ("NPC").

1.2 This Privacy Policy describes the categories of personal data jl9999 collects, the purposes for which that data is processed, the legal bases for such processing, how data is shared with third parties, how long data is retained, your rights as a data subject, and how to exercise those rights.

1.3 By registering an account on jl9999 or otherwise using the Platform, you acknowledge that you have read, understood, and freely consented to the collection and processing of your personal data as described in this Privacy Policy. If you do not consent, you must not register or continue to use jl9999.

2. Data Controller Identity

2.1 The data controller responsible for your personal data collected via jl9999 is the jl9999 operating entity, accessible via jl9999.one, operating under applicable Philippine regulatory frameworks including PAGCOR-aligned compliance requirements for online gaming platforms.

2.2 Questions relating to this Privacy Policy, data subject rights requests, and complaints regarding jl9999's data handling practices may be directed to our Data Protection Officer (DPO) at the contact details set out in Section 15 of this Policy.

3. Personal Data We Collect

3.1 jl9999 collects the following categories of personal data in the course of providing its services:

3.2 jl9999 does not collect sensitive personal information as defined under Section 3(l) of the DPA (such as race, religion, health data, sexual orientation) except where specifically required by law or with your explicit consent.

4. How We Use Your Personal Data

4.1 jl9999 processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and managing your jl9999 account, authenticating your identity at login, and processing account closure requests;
• KYC & Compliance: Verifying your identity and age (21+) as required by PAGCOR-aligned compliance obligations and Philippine anti-money laundering (AML) regulations;
• Payment Processing: Processing deposits (GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, PESONet) and withdrawal requests, detecting and preventing payment fraud;
• Game Provision: Delivering game content, recording game results for dispute resolution, and maintaining game integrity;
• Responsible Gaming: Enforcing deposit limits, self-exclusion lists, and session time controls; identifying problem gambling indicators per PAGCOR guidelines;
• Customer Support: Responding to inquiries, resolving disputes, and maintaining support correspondence records;
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have not opted out (opt-out available at any time via Account Settings or support);
• Platform Security: Detecting unauthorized access, bot activity, multi-accounting, and fraudulent transactions;
• Legal Compliance: Meeting reporting obligations to PAGCOR, AMLC, NPC, and other Philippine regulatory authorities as required by law.

5. Legal Bases for Processing

5.1 jl9999 processes your personal data on the following legal bases as provided under the DPA and its IRR:

• Consent (Section 12(a), DPA): Where you have freely given specific, informed consent — for example, for marketing communications;
• Contractual Necessity (Section 12(b), DPA): Processing necessary for the performance of our contract with you, including account management, game delivery, and payment processing;
• Legal Obligation (Section 12(c), DPA): Processing required to comply with Philippine law, including AML reporting, KYC, and PAGCOR compliance obligations;
• Legitimate Interests (Section 12(f), DPA): Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights and interests.

6. Sharing of Personal Data

6.1 jl9999 shares your personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: GCash (G-Xchange, Inc.), PayMaya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, and other licensed Philippine payment service providers, solely for the purpose of processing deposits and withdrawals;
• Game Providers: Licensed third-party game software providers who supply the game content on jl9999, to the extent required to deliver and maintain game services;
• Regulatory Authorities: PAGCOR, AMLC, NPC, and other Philippine government agencies where disclosure is required by law, court order, or regulatory direction;
• KYC Service Providers: Third-party identity verification providers engaged to assist with mandatory KYC processes, operating under data processing agreements with equivalent data protection standards;
• Professional Advisers: Legal, accounting, and audit firms engaged by jl9999, under strict confidentiality obligations.

6.2 jl9999 does not sell, rent, license, or otherwise commercially transfer your personal data to any third party for that party's independent use.

7. International Data Transfers

7.1 Some of jl9999's third-party game providers and technical infrastructure partners may be located outside the Philippines. Where personal data is transferred outside the Philippines, jl9999 ensures that such transfers are conducted in compliance with Section 21 of the DPA and are subject to adequate data protection safeguards, including contractual obligations consistent with NPC requirements.

7.2 jl9999 maintains records of all cross-border data transfers as required by the NPC. You may request information about specific transfers affecting your data by contacting our DPO.

8. Data Retention

8.1 jl9999 retains your personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: For the duration of your account plus five (5) years post-closure, as required by AML regulations and PAGCOR compliance obligations;
• Financial transaction records: Five (5) years from the date of transaction, per AMLA requirements;
• Game session records: Two (2) years for dispute resolution purposes;
• Support correspondence: Two (2) years from the close of the relevant support ticket;
• Marketing preferences and consent records: For the duration of account plus three (3) years;
• Self-exclusion records: Permanently, to prevent re-registration in violation of a permanent exclusion request.

8.2 Upon expiry of the applicable retention period, jl9999 will securely delete or anonymize your personal data so that it can no longer be attributed to you as an identified individual.

9. Your Data Subject Rights

9.1 Under the Data Privacy Act of 2012 and its IRR, you have the following rights with respect to your personal data held by jl9999:

9.2 To exercise any of the above rights, submit a written request to our DPO at the contact details in Section 15. jl9999 will respond within thirty (30) calendar days of receiving a complete and properly verified request.

10. Cookies & Tracking Technologies

10.1 jl9999 uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly Necessary Cookies: Required for core Platform functionality, including login session management, security tokens, and payment process continuity. These cannot be disabled without preventing use of jl9999;
• Performance & Analytics Cookies: Used to understand how Players interact with jl9999 (page visits, session duration, feature usage) to improve Platform performance. Data collected is aggregated and anonymized;
• Functional Cookies: Remember your preferences (language, notification settings, last visited game category) to provide a personalized experience.

10.2 You may control non-essential cookies through your browser settings. Note that disabling functional cookies may impair some Platform features. jl9999 does not use third-party advertising cookies or cross-site behavioral tracking technologies.

11. Children's Privacy (Under 21)

11.1 jl9999 strictly prohibits use of the Platform by persons under twenty-one (21) years of age, as required by applicable Philippine law governing online gaming. jl9999 does not knowingly collect personal data from persons under 21.

11.2 If jl9999 becomes aware that personal data has been collected from a person under 21 through misrepresentation, all data associated with that account will be immediately deleted, the account will be permanently closed, and any deposited funds will be returned to the originating payment method.

11.3 If you believe a minor has accessed jl9999 using your payment details or account credentials, contact jl9999 support immediately via live chat or at [email protected].

12. Security Measures

12.1 jl9999 implements the following technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data in transit between your device and jl9999 servers;
• AES-256 encryption for personal data stored in jl9999 databases;
• Role-based access controls (RBAC) limiting personal data access to authorized personnel only;
• Multi-factor authentication required for all staff accessing personal data systems;
• Regular independent security audits and penetration testing;
• Automated anomaly detection systems monitoring for unauthorized data access patterns;
• Physical and network security controls at all data processing facilities.

12.2 Despite these measures, no system is completely immune to security risks. In the unlikely event of a data breach affecting your personal data, jl9999 will notify you and the NPC in accordance with Section 20(f) of the DPA and NPC Circular 16-03.

13. Personal Data Breach Protocol

13.1 In the event jl9999 discovers or is notified of a personal data breach that is likely to give rise to a real risk of serious harm to affected data subjects, jl9999 will:

• Notify the NPC within seventy-two (72) hours of becoming aware of the breach, per NPC Circular 16-03;
• Notify affected data subjects within the timeframe prescribed by the NPC once notification has been made to the NPC and as soon as practicable thereafter;
• Provide details of the nature of the breach, the personal data involved, likely consequences, and measures taken or proposed to address the breach.

13.2 jl9999 maintains a Personal Data Breach Management Policy and a designated incident response team responsible for investigating, containing, and remediating data breaches.

14. Changes to This Privacy Policy

14.1 jl9999 may update this Privacy Policy from time to time to reflect changes in applicable law, NPC issuances, our data processing practices, or the services we offer. Material changes will be communicated to registered Players via the mobile number or email address on their account, or via an in-platform notification, with at least seven (7) days' advance notice before the change takes effect.

14.2 The current version of this Privacy Policy is always available at jl9999.one/privacy-policy. The "Last Updated" date at the top of this document indicates when the most recent amendment was made. Your continued use of jl9999 following the effective date of any update constitutes acceptance of the revised Policy.

15. Contact & Data Protection Officer

15.1 For data privacy inquiries, data subject rights requests, or complaints regarding jl9999's data handling practices, please contact our Data Protection Officer:

15.2 If you are not satisfied with jl9999's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on filing complaints with the NPC is available on the NPC's official website (privacy.gov.ph — note: not a link; please type this address into your browser).