Privacy Policy

1. Introduction

jl100 ("jl100," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the jl100 online gaming platform at jl100.org ("the Platform"). This Privacy Policy ("Policy") describes how jl100 collects, uses, stores, shares, and protects your personal information when you register for an account, access the Platform, or interact with any jl100 service.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). It also reflects the data handling obligations imposed on jl100 as a PAGCOR-regulated gaming operator.

By registering a jl100 account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform and contact us to close your account.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, jl100 is the personal information controller responsible for your personal data collected through the Platform. Our designated Data Protection Officer ("DPO") oversees compliance with this Policy and applicable data privacy laws.

If you have any questions, concerns, or requests relating to your personal data, you may contact our Data Protection Officer at: [email protected]

3. Personal Data We Collect

jl100 collects only the personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including city, province, and postal code)
• Email address and mobile phone number
• Nationality and country of residence

3.2 Verification & KYC Data

• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID)
• Proof of address documents (e.g., utility bills, bank statements)
• Proof of payment method ownership where required
• Selfie or liveness verification images where required for identity confirmation

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, dates, and payment method references
• GCash or PayMaya account reference numbers (we do not store full wallet credentials)
• Bank account details used for withdrawals (bank name, account name, account number)
• Bonus and promotional transaction history

3.4 Gaming Activity Data

• Game session logs, including games played, wager amounts, wins, and losses
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, cooling-off periods)
• Account login history, including timestamps and IP addresses

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Cookie identifiers and session tokens (see Section 8)
• Platform usage analytics and performance data

3.6 Communications Data

• Records of your communications with jl100 customer support, including chat transcripts and email correspondence
• Survey responses and feedback you voluntarily provide

4. How We Collect Your Data

jl100 collects your personal data through the following means:

• Direct collection: Information you provide when registering your jl100 account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from our KYC and anti-money laundering service providers; fraud prevention data from risk management partners; payment confirmation data from GCash, PayMaya, and banking partners.
• Regulatory sources: Information shared with jl100 by PAGCOR or other Philippine regulatory authorities in connection with our licensing obligations.

5. How We Use Your Personal Data

jl100 uses your personal data for the following purposes:

6. Legal Basis for Processing

jl100 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfil our obligations to you under the jl100 Terms and Conditions, including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act.
• Legitimate interests: Processing necessary for jl100's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent, particularly for marketing communications and the processing of sensitive personal information. You may withdraw your consent at any time by contacting us.

7. Data Sharing & Disclosure

jl100 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 stated purpose:

• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where required by law or regulatory obligation.
• Identity verification providers: Third-party KYC and anti-money laundering service providers engaged to verify your identity and screen against sanctions lists.
• Payment processors: GCash, PayMaya, and Philippine banking partners engaged to process your deposits and withdrawals. These providers receive only the data necessary to complete your transaction.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and platform technology providers who process data on jl100's behalf under strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants bound by confidentiality obligations.
• Law enforcement: Philippine law enforcement agencies where jl100 is legally compelled to disclose data or where disclosure is necessary to prevent or investigate criminal activity.

All third parties with whom jl100 shares personal data are required to handle that data in accordance with the Philippine Data Privacy Act and jl100's data protection standards.

8. Cookies & Tracking Technologies

jl100 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse usage patterns. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function, including session authentication and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options to personalise your jl100 experience.
• Analytics cookies: Collect anonymised data about how players use the Platform to help us identify areas for improvement. No personally identifiable information is shared with analytics providers.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jl100 Platform. By continuing to use the Platform, you consent to our use of cookies as described in this Policy.

9. Data Retention

jl100 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Our general retention periods are as follows:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing conditions and the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity logs: Retained for a minimum of two (2) years from the date of each session.
• Customer support communications: Retained for two (2) years from the date of the last communication.
• Marketing consent records: Retained until you withdraw your consent, plus one (1) year thereafter for compliance documentation purposes.

When personal data is no longer required, jl100 will securely delete or anonymise it in accordance with our data disposal procedures.

10. Data Security

jl100 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the jl100 Platform.
• Encryption of sensitive data at rest, including KYC documents and financial records.
• Role-based access controls ensuring that only authorised jl100 personnel can access personal data, and only to the extent required for their role.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform infrastructure.
• Incident response procedures to detect, contain, and report personal data breaches in accordance with NPC notification requirements.

While jl100 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your jl100 login credentials and for notifying us immediately if you suspect any unauthorised access to your account.

11. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl100:

• Right to be informed: The right to know what personal data jl100 collects about you and how it is used – which is the purpose of this Policy.
• Right of access: The right to request a copy of the personal data jl100 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 where it is no longer necessary for the purposes for which it was collected, subject to jl100's legal retention obligations.
• 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 data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jl100 has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within fifteen (15) business days in accordance with NPC guidelines.

12. Children & Minors

jl100 is strictly an adult gaming platform. In accordance with Philippine gaming regulations, jl100 services are available only to individuals who are 21 years of age or older. jl100 does not knowingly collect personal data from individuals under the age of 21.

If jl100 discovers that personal data has been collected from a person under 21 years of age, we will immediately close the relevant account, void any associated transactions, and securely delete the personal data in question. If you believe a minor has registered on jl100, please notify us immediately at [email protected].

13. Changes to This Privacy Policy

jl100 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, jl100 will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically. Your continued use of the jl100 Platform following the publication of an updated Policy constitutes your acceptance of the revised terms.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way jl100 handles your personal data, please contact our Data Protection Officer:

Email: [email protected]

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. For more information, visit the NPC's official channels.

For responsible gaming support, self-exclusion requests, or account closure, please visit our Responsible Gaming page.