jlj2 Casino Privacy Policy

1. Introduction

jlj2 ("we", "us", "our", or "jlj2") is the operator of the online gaming platform accessible at jlj2.app and all associated sub-domains and mobile interfaces (the "Platform"). jlj2 is committed to protecting the personal data of all individuals who interact with the Platform, including registered players, prospective users, and visitors.

This Privacy Policy ("Policy") describes how jlj2 collects, uses, stores, shares, and protects personal information in connection with your use of the Platform. It applies to all personal data processed by jlj2 in the course of its operations, whether collected directly from you or obtained from third parties.

This Policy is intended to comply with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. It also reflects jlj2's compliance obligations under the Philippine Amusement and Gaming Corporation (PAGCOR) licensing framework.

By accessing or using the jlj2 Platform, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, you should discontinue use of the Platform.

2. Personal Data We Collect

jlj2 collects personal data in the following categories, depending on how you interact with the Platform:

2.1 Registration and Account Data

• Full legal name as it appears on a Philippine government-issued identification document;
• Date of birth (for age verification — players must be 21 or older);
• Email address and mobile phone number registered in the Philippines;
• Username and encrypted password;
• Residential address in the Philippines.

2.2 Identity Verification (KYC) Data

• Copies of valid Philippine government-issued identification documents (e.g., PhilSys National ID, passport, UMID, driver's licence, SSS/GSIS ID, voter's ID);
• Proof of residential address (e.g., utility bill, bank statement);
• Source of funds documentation where required by anti-money laundering regulations;
• Selfie or biometric verification data where applicable.

2.3 Financial and Transaction Data

• GCash mobile number, Maya account reference, or other payment method identifiers;
• Transaction history including deposits, withdrawals, wagers, and bonus redemptions;
• Account balance history;
• Bank account details where applicable (BPI, BDO, Metrobank, UnionBank).

2.4 Gaming and Behavioural Data

• Game session logs, wager amounts, game outcomes, and bet history;
• Login timestamps, session duration, and frequency of play;
• Game preferences and navigation patterns within the Platform;
• Responsible gaming tool usage (deposit limit settings, self-exclusion requests).

2.5 Technical and Device Data

• IP address at time of login and during active sessions;
• Device type, operating system, and browser type and version;
• Mobile network operator (e.g., Globe, Smart, DITO);
• Cookie identifiers and similar tracking technology data (see Section 6).

2.6 Communications Data

• Records of customer support interactions via live chat and email;
• Feedback and survey responses submitted through the Platform;
• Content of any disputes or complaints submitted to jlj2.

3. How We Use Your Personal Data

jlj2 uses the personal data we collect for the following purposes:

Purpose	Categories of Data Used
Account registration and management	Registration data, KYC data
Identity verification and age verification (21+)	KYC data, registration data
Processing deposits and withdrawals	Financial data, KYC data
Delivering gaming services and game personalisation	Gaming data, technical data
Anti-money laundering (AML) compliance and fraud prevention	Financial data, KYC data, technical data
Customer support and dispute resolution	Communications data, account data
Responsible gaming monitoring and intervention	Gaming data, registration data
Marketing and promotional communications (with consent)	Registration data, gaming data
Platform security, fraud detection, and abuse prevention	Technical data, gaming data
Regulatory reporting to PAGCOR and AMLC	All categories as required
Analytics and platform improvement	Technical data, gaming data (aggregated/anonymised)

4. Legal Basis for Processing

jlj2 processes your personal data only where a lawful basis exists under the Data Privacy Act of 2012. The applicable legal bases for jlj2's data processing activities are:

1. Performance of a Contract: Processing necessary to fulfil our obligations to you under the Terms & Conditions, including account management, payment processing, and game delivery;
2. Compliance with a Legal Obligation: Processing required to comply with Philippine law, including the Anti-Money Laundering Act, the Data Privacy Act, and PAGCOR licensing requirements;
3. Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and analytics, where jlj2's legitimate interests are not overridden by your data protection rights;
4. Consent: Processing for direct marketing and certain cookie-based tracking, where we have obtained your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing and Disclosure

jlj2 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients where necessary and in accordance with applicable law:

• PAGCOR: As our licensing authority, PAGCOR may require access to player data for regulatory audit and compliance purposes;
• Anti-Money Laundering Council (AMLC): jlj2 is required by law to report suspicious transactions and provide player data in connection with AML investigations;
• Payment Processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), and other payment service providers who process your deposits and withdrawals on jlj2's behalf, subject to their own privacy policies and data protection obligations;
• Game Providers: Third-party game studios (e.g., JILI Technology, Pragmatic Play, PG Soft) may receive session and wager data necessary to operate their games on the jlj2 Platform;
• KYC and Identity Verification Services: Third-party identity verification providers who assist jlj2 in completing required KYC checks;
• Technology and Cloud Service Providers: Infrastructure, hosting, and security service providers who process data on jlj2's behalf under data processing agreements consistent with the DPA;
• Law Enforcement and Courts: Where disclosure is required by a valid court order, subpoena, or applicable Philippine law.

All third parties with whom jlj2 shares personal data are required to maintain the confidentiality and security of that data and to use it only for the specified purposes. jlj2 does not transfer personal data outside the Philippines except where required by the nature of the service and subject to equivalent data protection safeguards.

6. Cookies and Tracking Technologies

jlj2 uses cookies and similar tracking technologies (such as web beacons and local storage) to operate the Platform and improve your experience. The categories of cookies used by jlj2 are:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without impairing Platform functionality;
• Functional Cookies: Remember your preferences such as language settings, game lobby layout, and login status on trusted devices;
• Analytical Cookies: Collect anonymised data on how players navigate and use the Platform, used to improve performance and usability. These are set only with your consent;
• Marketing Cookies: Used to deliver relevant promotional communications and track the effectiveness of marketing campaigns, set only with your consent.

You may manage your cookie preferences through your browser settings or through jlj2's cookie consent interface. Note that disabling non-essential cookies does not affect your ability to play games or make transactions on jlj2.

7. Data Retention

jlj2 retains your personal data for as long as necessary to fulfil the purposes described in this Policy, and in any event for the minimum periods required by applicable Philippine law:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and the Anti-Money Laundering Act;
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Gaming session logs: Retained for two (2) years unless a longer retention period is required for dispute resolution or regulatory purposes;
• Customer support communications: Retained for two (2) years from the date of the interaction;
• Marketing consent records: Retained for the duration of the consent plus one (1) year following withdrawal.

After applicable retention periods expire, jlj2 will securely delete or anonymise your personal data.

8. Data Security

jlj2 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and jlj2's servers;
• Encryption of sensitive personal data at rest, including passwords (hashed and salted) and financial identifiers;
• Role-based access controls ensuring that jlj2 personnel access personal data only on a need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Intrusion detection and monitoring systems;
• Optional two-factor authentication for player accounts.

Notwithstanding these measures, no method of transmission over the internet or electronic storage is completely secure. jlj2 cannot guarantee absolute security and advises players to maintain strong, unique passwords and enable two-factor authentication on their accounts.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jlj2 will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules.

9. Your Rights Under the Data Privacy Act

As a data subject under the Republic Act No. 10173, you have the following rights in respect of your personal data held by jlj2:

1. Right to Be Informed: The right to be informed of the existence of processing, the nature of the data processed, and the purposes for which it is processed — as provided in this Policy;
2. Right to Access: The right to request a copy of the personal data jlj2 holds about you and information about how it is processed;
3. Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
4. Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where processing is no longer necessary, was unlawful, or where consent has been withdrawn — subject to jlj2's legal retention obligations;
5. Right to Object: The right to object to processing based on legitimate interests or direct marketing;
6. Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
7. Right to Damages: The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of personal data;
8. Right to Complain: The right to lodge a complaint with the National Privacy Commission (NPC) at privacy.gov.ph if you believe your data protection rights have been violated.

To exercise any of these rights, please contact jlj2's Data Protection Officer at [email protected] with the subject line "Data Privacy Request". jlj2 will respond within thirty (30) days of receiving a valid request, subject to identity verification.

10. Children's Privacy

The jlj2 Platform is strictly intended for individuals who are at least twenty-one (21) years of age. jlj2 does not knowingly collect personal data from persons under the age of 21. If jlj2 becomes aware that personal data has been collected from a person under 21, jlj2 will immediately close the associated account, delete all collected data, and return any deposited funds to the payment source used.

If you are a parent or guardian and believe that your child under 21 has provided personal data to jlj2, please contact jlj2 support immediately at [email protected].

11. Third-Party Links

The jlj2 Platform does not contain links to third-party websites. Where game content is delivered by third-party providers (e.g., live dealer game studios), such providers operate within the jlj2 Platform interface and are bound by data processing agreements with jlj2. jlj2 is not responsible for the privacy practices of third-party game studios beyond the scope of those agreements.

12. Changes to This Privacy Policy

jlj2 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform operations. When we make material changes to this Policy, we will update the "Last Updated" date at the top of this page and, where reasonably practicable, notify registered players via email or in-Platform notification prior to the changes taking effect.

Your continued use of the jlj2 Platform following the effective date of any revision constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or jlj2's data processing practices, please contact:

• Data Protection Officer, jlj2
• Email: [email protected] (subject: "Data Privacy Request")
• Live Chat: Available daily 6:00 AM – 2:00 AM PST via the jlj2 Platform

For complaints regarding data privacy violations, you may also contact the National Privacy Commission (NPC) of the Philippines.