Privacy Policy — How jl996 Handles Your Personal Data

This Privacy Policy describes how jl996 (jl996.app) — referred to throughout this document as "jl996", "we", "us", or "our" — collects, processes, stores, and protects the personal information of users who access or register on our Platform.

This Privacy Policy applies to all personal data collected through jl996.app, including data collected during account registration, KYC verification, platform use, customer support interactions, and marketing communications. It applies to all registered players and visitors located in the Philippines, as well as any person whose personal data is processed by jl996 in connection with the provision of our services.

This Privacy Policy should be read together with jl996's Terms & Conditions (available at /terms-conditions). In the event of any inconsistency between the two documents on a privacy matter, this Privacy Policy shall prevail.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, jl996 is the Personal Information Controller (PIC) in respect of personal data collected and processed through the Platform.

As the Personal Information Controller, jl996 is responsible for determining the purposes and means of processing personal data collected through the Platform and for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with RA 10173 and PAGCOR's data handling requirements for licensed operators.

Where jl996 engages third-party service providers to process personal data on its behalf — including payment processors, game providers, and cloud infrastructure providers — those parties act as Personal Information Processors (PIPs) and are bound by contractual obligations that require them to process personal data only on jl996's instructions and in accordance with applicable Philippine data protection law.

jl996 collects the following categories of personal data in the course of providing our services to you. We collect only the minimum data necessary for the stated purpose — a principle of data minimization that we apply consistently across all collection points on the Platform.

jl996 collects personal data through the following channels:

• Direct collection from you: When you register an Account, complete KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or interact with any feature of the Platform that requires you to submit information.
• Automated technical collection: Through cookies, session tokens, log files, and analytics tools that record technical data about how you interact with the Platform. See Section 10 (Cookies & Tracking) for full details.
• Payment providers: When you deposit or withdraw funds, jl996 receives transaction confirmation data from payment providers such as GCash, Maya, BPI, and BDO. jl996 does not receive or store your full payment account credentials — only the reference data necessary to reconcile transactions.
• Identity verification services: Where jl996 uses a third-party KYC verification partner to validate the authenticity of identity documents, that partner may return verification results and risk flags to jl996. The processing of your identity document images by the KYC provider is governed by the provider's own data processing agreement with jl996.
• Third-party game providers: Game providers integrated into the Platform (such as JILI, PG Soft, Pragmatic Play) may share game session data with jl996 for the purpose of account reconciliation, wagering verification, and responsible gaming monitoring.

Under RA 10173, jl996 processes personal data only where there is a recognized legal basis for doing so. The legal basis applicable to each processing activity is set out below:

• Contractual necessity: Processing of Identity Data, Contact Data, Financial Data, Account Data, and Gaming Activity Data is necessary for jl996 to perform its contractual obligations to you — specifically, to operate your Account, accept deposits, settle wagers, and process withdrawals.
• Legal obligation: Processing required by PAGCOR licensing, Republic Act No. 9160 (Anti-Money Laundering Act), and related AML/KYC regulations is carried out pursuant to jl996's legal obligations as a licensed operator. This includes identity verification, transaction monitoring, suspicious activity reporting, and record retention obligations.
• Legitimate interests: Processing of Technical Data and Communication Data for fraud prevention, platform security, and customer support is carried out on the basis of jl996's legitimate interest in protecting the Platform and its users, provided such interests are not overridden by your data protection rights.
• Consent: Processing of Marketing Data for promotional communications is carried out only where you have provided explicit, freely given consent. You may withdraw this consent at any time without affecting the lawfulness of processing prior to withdrawal.

jl996 uses the personal data it collects for the following purposes:

• Account creation and management: To register your Account, verify your identity, maintain your player profile, and administer your Wallet balance.
• Service delivery: To process deposits and withdrawals, settle game outcomes, apply bonuses, deliver customer support, and provide all other features of the Platform.
• KYC and AML compliance: To verify your identity in compliance with PAGCOR licensing requirements and to monitor transactions for suspicious activity under the AML Act. jl996 may be legally required to report certain transactions or player activities to PAGCOR, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities.
• Fraud detection and security: To identify and prevent fraudulent activity, multi-account violations, bonus abuse, and unauthorized access to player Accounts.
• Responsible gaming: To monitor gaming patterns and, where necessary, apply responsible gaming interventions — including deposit limits, cooling-off periods, and self-exclusion — as required by PAGCOR regulation.
• Platform improvement: To analyze aggregated, anonymized gaming data to improve game selection, platform performance, and user experience.
• Marketing communications: Where you have consented, to send promotional offers, bonus notifications, and platform news via SMS, email, or in-app notifications. You may opt out at any time through your Account settings or by contacting support.
• Legal proceedings: To establish, exercise, or defend legal claims in the event of disputes, regulatory proceedings, or law enforcement requests.

jl996 does not sell, rent, or trade your personal data. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, GrabPay, and InstaPay receive transaction reference data necessary to process your deposits and withdrawals. These providers are independent data controllers in respect of the data they receive and operate under their own privacy policies and relevant Philippine financial regulations.
• Game providers: JILI, PG Soft, Pragmatic Play, and other integrated game providers receive your account reference ID and session data necessary to serve game content and record wagering outcomes. Game providers do not receive your full personal profile.
• KYC and identity verification partners: Third-party KYC providers process identity document data on jl996's behalf, under contractual data processing agreements that bind them to RA 10173 standards.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and Philippine law enforcement agencies may receive personal data where required by law, court order, or lawful regulatory instruction.
• Technology and infrastructure providers: Cloud hosting providers, cybersecurity partners, and analytics providers who process personal data on jl996's behalf under contractual arrangements are classified as Personal Information Processors under RA 10173 and are bound by data processing agreements with jl996.

jl996 retains personal data for the minimum period necessary to fulfill the purpose for which it was collected, subject to any longer retention period required by applicable law. The following retention periods apply:

• KYC and identity documents: Retained for a minimum of five (5) years following the closure of your Account, in compliance with PAGCOR licensing requirements and AMLA record-keeping obligations.
• Financial transaction records: Retained for a minimum of five (5) years in compliance with AMLA, PAGCOR, and BIR record-keeping requirements applicable to licensed gaming operators.
• Gaming activity logs: Retained for a minimum of two (2) years following Account closure, or longer where required for dispute resolution or regulatory investigation.
• Customer support records: Retained for three (3) years following the closure of the relevant support ticket or Account, whichever is later.
• Marketing consent records: Retained for the duration of the marketing relationship and for one (1) year following withdrawal of consent, as evidence of the lawful basis for prior communications.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with jl996's data destruction procedures. Anonymous aggregated data may be retained indefinitely for statistical and analytical purposes.

jl996 is a Philippines-based platform and stores the majority of its data on infrastructure located in the Philippines or in jurisdictions recognized by the National Privacy Commission as providing an adequate level of data protection.

Where personal data is processed by third-party game providers or technology partners whose systems are located outside the Philippines, jl996 ensures that appropriate contractual safeguards — including standard contractual clauses or binding corporate rules equivalent to those recognized under RA 10173 — are in place prior to any such transfer.

jl996 does not transfer personal data to jurisdictions that are identified by the National Privacy Commission or applicable Philippine law as lacking adequate data protection standards, unless specific derogations apply (such as your explicit consent, or the transfer being necessary for the performance of a contract in your interests).

jl996 uses cookies and similar tracking technologies on its Platform for the following purposes:

• Strictly Necessary Cookies: Session management, authentication tokens, and security cookies required for the Platform to function. These cookies cannot be disabled without preventing access to the Platform.
• Functional Cookies: Cookies that remember your preferences, such as language settings or game lobby display options. These improve your experience but are not essential to Platform operation.
• Analytics Cookies: Aggregated, anonymized data about how users interact with the Platform — page load times, feature usage rates, navigation paths. This data helps jl996 improve Platform performance and user experience.

jl996 does not use advertising cookies, cross-site tracking cookies, or behavioral profiling cookies. We do not share cookie data with social media platforms or advertising networks.

You may control cookies through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in or using the Platform's core features.

jl996 implements technical and organizational security measures commensurate with the sensitivity of the personal data it processes. These measures include:

• Encryption in transit: All data transmitted between your device and jl996's servers is encrypted using 256-bit SSL/TLS protocols. This is the same encryption standard used by major Philippine banks for online banking.
• Encryption at rest: Sensitive personal data stored in jl996's databases — including identity documents and financial data — is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to jl996 staff who require it to perform their job functions. All staff access is logged, role-based, and subject to regular access control reviews.
• Penetration testing and security audits: jl996 conducts regular independent security assessments to identify and remediate vulnerabilities in its platform and data infrastructure.
• Incident response: jl996 maintains a documented data breach incident response procedure. In the event of a breach involving your personal data, jl996 will notify the National Privacy Commission and affected players in accordance with the timelines prescribed by RA 10173.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights as a data subject. jl996 is committed to facilitating the exercise of these rights promptly and without undue restriction:

The jl996 Platform is strictly restricted to persons who are at least 21 years of age in accordance with PAGCOR licensing requirements and Philippine law. jl996 does not knowingly collect personal data from any person under the age of 21.

If jl996 discovers or is notified that personal data has been collected from a person under the age of 21, we will immediately suspend the associated Account, delete the personal data, and return any deposited funds to the original payment method where technically possible.

In the event of a personal data breach that poses a real risk to the rights and freedoms of affected players, jl996 will:

• Notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, in accordance with the requirements of RA 10173 and NPC Circular No. 16-03;
• Notify affected players — via their registered email address and, where possible, via in-Platform notification — without undue delay, providing a clear description of the nature of the breach, the categories and approximate number of records affected, the likely consequences, and the measures taken or proposed to address the breach;
• Maintain an internal breach register documenting all personal data breaches, their effects, and the remedial actions taken, regardless of whether notification to the NPC or players was required.

jl996 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, our data processing practices, or the services we offer. When material changes are made, jl996 will update the Effective Date at the top of this document and post a notice on the Platform.

Where changes are significant — for example, a change in the legal basis for processing or the introduction of a new category of data sharing — jl996 will provide advance notice via email to registered players and, where required by RA 10173, seek fresh consent before implementing the change.

Your continued use of the Platform following the posting of any amendment to this Privacy Policy constitutes your acknowledgment of the updated terms. We encourage you to review this Privacy Policy periodically.

jl996 has appointed a Data Protection Officer (DPO) as required by the National Privacy Commission for personal information controllers of our scale. The DPO is responsible for overseeing jl996's compliance with RA 10173 and for acting as the point of contact for data subjects and the NPC.

For all privacy-related inquiries, data subject rights requests, consent withdrawals, or data breach reports, please contact jl996 through the following channels:

• Email (Data Privacy): [email protected] — please include "Data Privacy" or "DPO Request" in the subject line.
• Live Chat: Available 24/7 through jl996.app — fastest response channel for general privacy inquiries.

jl996 is committed to responding to all data subject rights requests within the timelines prescribed by RA 10173. If you are not satisfied with jl996's response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines through the NPC's official complaint mechanisms.