Privacy Policy

1.1 jl 111 Casino takes the privacy and security of your personal data seriously. This Policy applies to all personal data collected through the jl 111 platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and general platform use.

1.2 This Policy should be read together with the jl 111 Terms & Conditions, which govern your use of the platform. Terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

1.3 jl 111 is committed to processing your personal data lawfully, fairly, and transparently, and to collecting only the minimum data necessary for the purposes described in this Policy.

2.1 For the purposes of the Data Privacy Act of 2012 and this Policy, jl 111 Casino is the personal information controller responsible for your personal data collected through the jl111.live platform.

2.2 jl 111 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact the DPO using the contact details provided in Section 14 of this Policy.

2.3 Where jl 111 engages third-party service providers to process personal data on its behalf (for example, payment processors or identity verification services), those providers act as personal information processors and are contractually bound to process data only in accordance with jl 111's instructions and applicable law.

3.1 jl 111 collects the following categories of personal data, depending on how you interact with the platform:

Identity & Contact Data

Financial Data

Account & Gaming Data

Technical & Usage Data

3.2 jl 111 does not collect sensitive personal information (as defined under RA 10173) beyond what is strictly required for identity verification and regulatory compliance purposes. Where sensitive data is collected, explicit consent is obtained.

4.1 jl 111 collects personal data through the following channels:

• Account Registration: When you create a jl 111 account, you provide identity and contact data directly through the registration form.
• KYC Verification: When you submit identity documents for Know Your Customer verification prior to processing withdrawals.
• Deposits & Withdrawals: When you initiate financial transactions on the platform, payment data is collected and processed.
• Platform Use: Technical and usage data is collected automatically as you navigate and interact with the jl 111 platform.
• Customer Support: When you contact jl 111 support via live chat or email, the content of those communications is recorded.
• Promotions & Surveys: When you participate in jl 111 promotions, competitions, or voluntary surveys.

4.2 jl 111 does not collect personal data from third-party data brokers or social media platforms without your explicit consent.

5.1 jl 111 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and jl 111 — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable laws, including PAGCOR regulations, Anti-Money Laundering Act (AMLA) obligations, and tax reporting requirements.
• Legitimate Interests: Processing is necessary for jl 111's legitimate interests, including fraud prevention, platform security, and improving the quality of our services, provided those interests are not overridden by your rights.
• Consent: Where processing is not covered by the above bases — for example, sending you promotional communications — jl 111 will seek your explicit consent, which you may withdraw at any time.

6.1 jl 111 uses your personal data for the following purposes:

• To create, verify, and manage your jl 111 player account;
• To process deposits, withdrawals, and other financial transactions;
• To verify your identity and age (21+) in compliance with PAGCOR requirements;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity;
• To comply with Anti-Money Laundering Act (AMLA) reporting obligations;
• To provide customer support and respond to your enquiries;
• To administer bonuses, promotions, and loyalty programs you have opted into;
• To send you service-related communications (account notices, security alerts, policy updates);
• To send you promotional communications, where you have given consent;
• To monitor and improve platform performance, security, and user experience;
• To enforce our Terms & Conditions and other platform policies;
• To comply with any court order, legal process, or regulatory requirement.

6.2 jl 111 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.

7.1 jl 111 does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya/Maya, and banking partners, to process your deposits and withdrawals;
• Identity Verification Providers: Third-party KYC service providers who assist with document verification and age confirmation;
• Fraud Prevention Services: Providers of fraud detection and anti-money laundering screening tools;
• IT & Platform Infrastructure: Cloud hosting and platform technology providers who process data on jl 111's behalf under strict data processing agreements;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where required by law;
• Legal & Professional Advisors: Lawyers, auditors, and compliance consultants, subject to professional confidentiality obligations.

7.2 All third-party processors engaged by jl 111 are contractually required to implement appropriate technical and organizational security measures and to process personal data only in accordance with jl 111's documented instructions.

7.3 jl 111 does not transfer your personal data outside the Philippines except where necessary for payment processing or platform infrastructure, and only where adequate data protection safeguards are in place.

8.1 jl 111 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

8.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with jl 111's data disposal procedures.

9.1 jl 111 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jl 111 servers;
• AES-256 encryption for sensitive data stored at rest;
• Two-factor authentication (2FA) available for all player accounts;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular penetration testing and vulnerability assessments by independent security firms;
• 24/7 intrusion detection and monitoring systems;
• Secure, geographically redundant data storage facilities.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl 111 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required by law.

9.3 While jl 111 takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying jl 111 immediately if you suspect unauthorized access to your account.

10.1 The jl 111 platform uses cookies and similar tracking technologies to ensure the platform functions correctly and to improve your experience. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymized data about how players use the platform, helping jl 111 identify and fix performance issues. No personally identifiable information is collected through these cookies.
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming limits you have set.

10.2 jl 111 does not use advertising cookies, behavioral tracking cookies, or third-party social media tracking pixels on the platform.

10.3 You can control and delete cookies through your browser settings. Please note that disabling strictly necessary cookies may affect the functionality of the jl 111 platform, including your ability to log in and play.

11.1 Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by jl 111:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed — which this Policy fulfils;
• Right of Access: The right to request a copy of the personal data jl 111 holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to jl 111's legal retention obligations;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

11.2 To exercise any of the above rights, please contact jl 111's Data Protection Officer using the contact details in Section 14. jl 111 will respond to all data subject rights requests within thirty (30) days of receipt, as required by law.

12.1 The jl 111 platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gambling regulations. jl 111 does not knowingly collect personal data from individuals under the age of 21.

12.2 If jl 111 becomes aware that personal data has been collected from an individual under the age of 21, that account will be immediately suspended, all associated data will be deleted, and any deposits will be returned in accordance with our Terms & Conditions.

12.3 If you are a parent or guardian and believe that your child has registered on the jl 111 platform, please contact our support team immediately so that we can take appropriate action.

13.1 jl 111 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, jl 111 will notify registered players via the email address associated with their account and/or by posting a prominent notice on the platform.

13.2 The date of the most recent revision is displayed at the top of this Policy. Your continued use of the jl 111 platform following the posting of an updated Policy constitutes your acceptance of the revised terms.

13.3 We encourage you to review this Policy periodically to stay informed about how jl 111 protects your personal data.

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or jl 111's handling of your personal data, please contact our Data Protection Officer through the following channels:

14.2 If you are not satisfied with jl 111's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

14.3 This Privacy Policy, together with the jl 111 Terms & Conditions, constitutes the complete agreement between you and jl 111 with respect to the processing of your personal data.