Privacy Policy

1. Introduction

Welcome to the jllpub Privacy Policy. jllpub ("we," "us," "our") operates the online gaming platform accessible at jllpub.com, offering a wide range of gaming products including live casino games, slot games, bingo, Go Rush, and Pool Rummy to players across the Philippines.

This Privacy Policy describes how jllpub collects, uses, stores, shares, and protects the personal information of individuals who visit our Platform, register an Account, or otherwise interact with our services. It also describes the rights you have in relation to your personal data and how you can exercise those rights.

By registering an Account on jllpub or by continuing to use our Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, you must not use the jllpub Platform.

This Privacy Policy should be read in conjunction with our Terms and Conditions and our Responsible Gaming Policy, both of which are available on the jllpub Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, jllpub acts as the personal information controller in respect of all personal data collected through the jllpub Platform. This means that jllpub determines the purposes and means of processing your personal data.

jllpub is registered with and operates under the oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). As a PAGCOR-regulated operator, jllpub is subject to additional data handling obligations imposed by PAGCOR in connection with anti-money laundering compliance, player verification, and responsible gaming requirements.

If you have any questions about how jllpub processes your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

jllpub collects the following categories of personal data in connection with your use of the Platform:

• Identity Data: Full legal name, date of birth, gender, nationality, and copies of government-issued identification documents (such as Philippine passport, SSS ID, PhilHealth ID, UMID, or driver's licence) submitted during KYC verification.
• Contact Data: Registered Philippine mobile number, email address, and residential address.
• Financial Data: GCash or PayMaya account numbers, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records, and wallet balance information.
• Account Data: Username, encrypted password, account registration date, login history, session duration records, and account preferences.
• Gaming Data: Game participation history, wagering records, bonus usage, win/loss records, and responsible gaming tool settings (deposit limits, self-exclusion status).
• Technical Data: IP address, device type and identifier, browser type and version, operating system, referring URLs, and pages visited on the Platform.
• Communications Data: Records of your communications with jllpub's customer support team, including live chat transcripts and email correspondence.
• Marketing Data: Your preferences regarding receipt of marketing communications from jllpub.

jllpub does not collect sensitive personal information (as defined under the Data Privacy Act of 2012) unless strictly required for regulatory compliance purposes, in which case such collection will be clearly disclosed to you at the time of collection.

4. How We Collect Your Data

jllpub collects personal data through the following means:

• Direct Interactions: Data you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Technologies: Technical data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and similar tracking technologies. Please refer to Section 8 for more information on our use of cookies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud service providers; payment data from payment processors including GCash, PayMaya, and partner banks.
• Regulatory Sources: Data received from PAGCOR or other regulatory authorities in connection with compliance obligations, including self-exclusion lists and anti-money laundering checks.

5. How We Use Your Personal Data

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

• Account Management: To create, maintain, and manage your jllpub Account, including verifying your identity and age (21+ requirement) during registration and KYC processes.
• Service Delivery: To provide you with access to the Games and other features of the jllpub Platform, process your deposits and withdrawals, and manage your Wallet.
• Regulatory Compliance: To comply with our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws. This includes conducting enhanced due diligence on high-value transactions and reporting suspicious activity to the Anti-Money Laundering Council (AMLC) where required.
• Responsible Gaming: To monitor gaming behaviour, enforce deposit limits and self-exclusion requests, and identify players who may be exhibiting signs of problem gambling.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and other marketing communications where you have consented to receive them. You may withdraw your consent at any time by updating your Account preferences or contacting our support team.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the functionality, security, and user experience of the jllpub Platform.
• Legal Claims: To establish, exercise, or defend legal claims in connection with your use of the Platform.

6. Legal Basis for Processing

jllpub processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary for the performance of our contract with you (the Terms and Conditions), including Account management, game provision, and financial transaction processing.
• Legal Obligation: Processing necessary to comply with our legal obligations under PAGCOR regulations, AMLA, and other applicable Philippine laws.
• Legitimate Interests: Processing necessary for jllpub's legitimate interests, including fraud prevention, Platform security, and business analytics, where such interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly in relation to marketing communications and the use of non-essential cookies.

Where jllpub relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing and Disclosure

jllpub does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients in the circumstances described below:

• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law or regulation.
• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your deposits and withdrawals.
• KYC and Fraud Prevention Providers: Third-party identity verification and fraud prevention service providers engaged by jllpub to assist with regulatory compliance and Platform security.
• Game Providers: Third-party game software providers whose games are available on the jllpub Platform, to the extent necessary for game operation and dispute resolution.
• IT and Infrastructure Providers: Cloud hosting, data storage, and IT security service providers engaged by jllpub to operate and maintain the Platform.
• Legal and Professional Advisers: Lawyers, accountants, and other professional advisers engaged by jllpub in connection with legal claims or regulatory matters.

All third parties with whom jllpub shares personal data are required to process such data in accordance with applicable data protection laws and are bound by appropriate data processing agreements or equivalent contractual safeguards.

8. Cookies and Tracking Technologies

jllpub uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain your session, and collect analytical data. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the Platform, including session management, authentication, and security. These cookies cannot be disabled.
• Functional Cookies: Used to remember your preferences and settings, such as your preferred language and display options.
• Analytical Cookies: Used to collect anonymised data about how players use the Platform, helping jllpub improve its services. These cookies are only placed with your consent.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your gaming activity and preferences. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jllpub Platform. For more information about the specific cookies used on the Platform, please contact our support team.

9. Data Retention

jllpub retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

The following retention periods apply as a general guide:

• Account Data and Gaming Records: Retained for a minimum of five (5) years from the date of Account closure, in accordance with PAGCOR record-keeping requirements and AMLA obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under the AMLA and its implementing rules.
• KYC Documents: Retained for a minimum of five (5) years from the date of Account closure or the date of the last transaction, whichever is later.
• Customer Support Communications: Retained for two (2) years from the date of the communication, unless retention for a longer period is required in connection with a legal claim or regulatory investigation.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

Upon expiry of the applicable retention period, jllpub will securely delete or anonymise your personal data in accordance with its data disposal procedures.

10. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jllpub Platform;
• Encryption of sensitive data at rest, including financial data and KYC documents;
• Role-based access controls limiting access to personal data to authorised personnel only;
• Regular security audits and penetration testing of the Platform;
• Multi-factor authentication for administrative access to systems containing personal data;
• Staff training on data protection obligations and security best practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jllpub will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the Data Privacy Act of 2012.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jllpub:

• Right to be Informed: The right to be informed whether your personal data is being processed, and to receive clear and accessible information about how it is being used — which is the purpose of this Privacy Policy.
• Right to Access: The right to obtain a copy of the personal data jllpub holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data jllpub holds about you. You may update certain Account details directly through your Account dashboard.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jllpub's legal retention obligations under PAGCOR regulations and the AMLA.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. You may exercise this right at any time by updating your marketing preferences in your Account settings.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that jllpub has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact jllpub's Data Protection Officer using the contact details in Section 14. jllpub will respond to all verified data subject requests within fifteen (15) business days of receipt. We may require you to verify your identity before processing your request.

Please note that certain rights are subject to limitations and exceptions under applicable law. For example, jllpub may be unable to delete personal data that it is required to retain under PAGCOR regulations or the AMLA, even upon your request.

12. Children's Privacy

The jllpub Platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. jllpub does not knowingly collect personal data from individuals under the age of 21.

If jllpub becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated Account. All deposits made by underage players will be returned in accordance with applicable law, and any winnings will be forfeited.

If you are a parent or guardian and believe that your child under the age of 21 has registered an Account on jllpub, please contact our support team immediately so that we can take appropriate action.

13. Changes to This Privacy Policy

jllpub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this Privacy Policy, jllpub will notify registered players via the email address associated with their Account and by displaying a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the jllpub Platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how jllpub protects your personal data.

If any amendment to this Privacy Policy requires your consent under applicable law, jllpub will seek that consent before the amended policy takes effect in relation to your personal data.

14. Contact Us

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

• Live Chat: Available 24/7 directly through the jllpub Platform. Our support team can escalate data privacy matters to the Data Protection Officer on your behalf.
• Email: [email protected] — data subject requests and privacy-related enquiries only. Responses within fifteen (15) business days.
• General Support: [email protected] — for all other Account and Platform enquiries.

If you are not satisfied with jllpub's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC's complaint process is available through official Philippine government channels.