Privacy Policy

1 Introduction & Data Controller

This Privacy Policy describes how jlpj ("jlpj", "we", "us", "our"), the operator of the online gaming platform accessible at jlpj.asia, collects, processes, stores, and discloses personal data relating to individuals ("you", "your", "the Player") who access, register with, or use our platform and Services.

jlpj is the data controller in respect of personal data processed under this Privacy Policy. As data controller, jlpj is responsible for ensuring that personal data is processed in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and other applicable Philippine privacy and data protection legislation.

By registering an account with jlpj or otherwise using the platform, you acknowledge that you have read, understood, and agreed to the collection and processing of your personal data as described in this Privacy Policy. If you do not agree, please discontinue use of the platform and contact us at [email protected] to request account closure.

Note for Filipino Players: This Privacy Policy is aligned with the National Privacy Commission's (NPC) requirements under RA 10173. If you have unresolved privacy concerns, you retain the right to lodge a complaint with the NPC.

2 Personal Data We Collect

jlpj collects personal data from and about you in order to deliver the Services, comply with our legal obligations, and maintain the security and integrity of the platform. The categories of personal data we collect are:

Category	Examples	When Collected
Identity Data	Full legal name, date of birth, nationality, government-issued ID details	Account registration; KYC verification
Contact Data	Philippine mobile number, email address	Account registration
Financial Data	GCash/Maya account reference, bank account details (for withdrawals), transaction history	Deposit / withdrawal processing
Usage Data	Login timestamps, game history, session duration, wager amounts, bonus usage	Ongoing during platform use
Device & Technical Data	IP address, device type, browser type, operating system, screen resolution	Automatically on each visit
Communications Data	Support chat transcripts, emails, in-app messages exchanged with jlpj	When you contact jlpj support
Verification Documents	Copies of Philippine passport, SSS ID, UMID, PhilSys ID, driver's license, PRC ID	KYC verification before first withdrawal
Responsible Gaming Data	Self-exclusion status, deposit limits set, session limit settings	When responsible gaming tools are used

jlpj does not intentionally collect special categories of personal data (such as health information, religious beliefs, or political opinions) unless such data is volunteered by you in the context of a responsible gaming support interaction, in which case it is processed solely for the purpose of providing appropriate support.

3 How We Collect Your Data

jlpj collects personal data through the following means:

Directly from you: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or using responsible gaming tools;
Automatically: Technical and usage data collected through cookies, web server logs, and similar technologies when you access or use the platform. This includes device identifiers, session data, and behavioral analytics;
From payment service providers: Transaction confirmation data from GCash, Maya, BPI, BDO, Metrobank, and card networks (Visa, Mastercard), limited to what is necessary to process and confirm your transactions;
From identity verification providers: Confirmation of identity document authenticity and age verification results from third-party KYC service providers engaged by jlpj;
From fraud prevention services: Risk scores and fraud indicators from third-party fraud detection systems used to protect the platform and all players;
From regulatory authorities: Where required, jlpj may receive information from PAGCOR or other Philippine regulatory authorities in connection with compliance obligations.

4 Purposes of Processing & Legal Basis

jlpj processes your personal data only for defined and lawful purposes. The table below sets out the primary purposes for which jlpj processes personal data and the corresponding legal basis under RA 10173 and its Implementing Rules:

Purpose	Legal Basis
Account registration and management	Performance of contract (Terms & Conditions)
Identity and age verification (KYC)	Legal obligation; Compliance with PAGCOR requirements and RA 9160 (AMLA)
Processing deposits and withdrawals	Performance of contract
Fraud detection and prevention	Legitimate interests of jlpj and protection of all players
Customer support and complaint resolution	Performance of contract; legitimate interests
Regulatory reporting and compliance	Legal obligation
Responsible gaming monitoring and tools	Legal obligation; legitimate interests in player protection
Platform security and technical maintenance	Legitimate interests
Service improvement and analytics	Legitimate interests (using anonymized/aggregated data where possible)
Direct marketing communications	Consent (you may opt out at any time)

jlpj will not use your personal data for any purpose that is incompatible with the purposes set out in this section without first providing you with notice and, where required, obtaining your consent.

5 Disclosure to Third Parties

jlpj does not sell, rent, or trade your personal data. We share personal data with third parties only where necessary and only to the extent required for the specific purpose, subject to appropriate confidentiality obligations. The categories of third parties with whom jlpj may share your data are:

Payment Service Providers: GCash, Maya, GrabPay, BPI, BDO, Metrobank, Visa, and Mastercard — for the purpose of processing and confirming your financial transactions. These providers act as independent data controllers in respect of your payment data under their own privacy policies;
KYC and Identity Verification Providers: Third-party identity verification services engaged to confirm the authenticity of documents you submit as part of the KYC process;
Fraud Prevention and Security Providers: Services that assist jlpj in detecting, investigating, and preventing fraudulent activity on the platform;
Game Technology Providers: Software providers whose games are offered through the jlpj platform may receive pseudonymized gameplay data necessary for game operation, dispute resolution, and RNG certification. These providers do not receive your full identity data;
Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies where disclosure is required by law or regulation;
Professional Advisors: Lawyers, accountants, and auditors engaged by jlpj under strict professional confidentiality obligations;
IT and Hosting Providers: Cloud infrastructure and IT service providers that host or process data on behalf of jlpj as data processors, subject to data processing agreements that bind them to jlpj's security and privacy standards.

jlpj will never sell or share your personal data with third-party advertisers, data brokers, or commercial data aggregators. Any third party receiving your data from jlpj is contractually prohibited from using it for their own independent commercial purposes.

6 International Data Transfers

Some of the third-party service providers engaged by jlpj may process your personal data outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that afforded under Philippine law, jlpj takes appropriate steps to ensure that such transfers are conducted lawfully, including:

Implementing binding contractual clauses with the receiving entity that replicate the protections of RA 10173;
Verifying that the recipient country has been recognized by the National Privacy Commission as providing adequate protection; or
Applying appropriate technical and organizational measures to protect the transferred data.

The primary regions where jlpj's cloud infrastructure and service providers operate include Southeast Asia and, in limited circumstances, the European Economic Area and the United States. In all cases, jlpj remains responsible for ensuring that your personal data is handled in accordance with this Privacy Policy regardless of where it is processed.

7 Data Security

jlpj implements a layered security framework designed to protect your personal data against unauthorized access, loss, alteration, disclosure, or destruction. Our current security measures include, but are not limited to:

Encryption in Transit: TLS 1.3 for all data transmitted between your device and jlpj's servers, including login credentials, financial data, and personal information;
Encryption at Rest: AES-256 encryption applied to personal and financial data stored in jlpj's databases;
Access Controls: Role-based access controls ensuring that only authorized personnel can access specific categories of personal data. All internal access to player data is logged and monitored;
Authentication Controls: Multi-factor authentication required for all jlpj staff accessing player data systems;
Security Monitoring: 24/7 automated monitoring of systems for intrusion, unusual access patterns, and security anomalies;
Penetration Testing: Regular independent penetration tests conducted on all systems handling personal and financial data;
Incident Response: A documented data breach response procedure including NPC notification requirements in accordance with the Data Privacy Act and its Implementing Rules.

In the event of a personal data breach that is likely to result in a risk to your rights, jlpj will notify affected individuals and the National Privacy Commission within the timeframes required by law. We will provide clear information on what data was affected, what steps we have taken, and what you can do to protect yourself.

8 Cookies & Similar Technologies

jlpj uses cookies and similar tracking technologies (including local storage and session storage) to operate the platform, remember your preferences, and analyze how the platform is used. The categories of cookies we use are:

Strictly Necessary Cookies: Required for the platform to function. These include session cookies that keep you logged in, security tokens, and cookies that manage your session balance display. These cannot be disabled without impairing platform functionality;
Preference Cookies: Remember your chosen settings such as language preference, last-visited game category, and account display options. These improve your experience on return visits;
Analytics Cookies: Collect anonymized data about how players navigate and use the platform, helping jlpj identify performance issues and improve user experience. jlpj uses self-hosted analytics tools and does not share analytics data with third-party advertising networks;
Security Cookies: Used by fraud prevention systems to identify trusted devices and detect unusual access patterns indicative of account compromise.

jlpj does not use third-party advertising or retargeting cookies. Your browsing activity on jlpj is not shared with advertisers or ad networks.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the platform; disabling analytics or preference cookies will not prevent you from accessing games or managing your account.

9 Data Retention & Deletion

jlpj retains personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the minimum retention periods required by applicable Philippine law and regulation. The following retention schedule applies:

Data Category	Retention Period	Basis
Account and identity data	Duration of account + 5 years after closure	AMLA / regulatory requirement
KYC verification documents	Duration of account + 5 years after closure	AMLA / PAGCOR requirement
Transaction records	Duration of account + 5 years after closure	AMLA / tax and financial regulation
Game history and session logs	2 years from date of session	Dispute resolution; regulatory audit
Support communications	3 years from date of communication	Dispute resolution; legitimate interests
Marketing preferences	Until opt-out or account closure	Consent
Device and technical logs	90 days	Security monitoring

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with you as an individual. Data retained solely for legal compliance purposes is access-restricted and not used for any operational, marketing, or analytical purpose during the retention period.

10 Your Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, you have the following rights in respect of your personal data held by jlpj. You may exercise any of these rights by contacting the jlpj Data Protection Officer as described in Section 14.

Right to Access

You have the right to request confirmation of whether jlpj holds personal data about you, and to receive a copy of that data along with information about how it is being used.

Right to Rectification

You have the right to request correction of any personal data that is inaccurate, incomplete, or out of date. You may update certain information directly through your Account Settings.

Right to Erasure

You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and no other legal basis applies. Erasure requests will be assessed against applicable legal retention obligations.

Right to Object

You may object to processing carried out on the basis of legitimate interests, or to the use of your data for direct marketing purposes. Objections to direct marketing take effect immediately upon receipt. Objections to other processing will be assessed on a case-by-case basis.

Right to Data Portability

Where processing is based on your consent or on contract performance, you may request a copy of the personal data you have provided to jlpj in a structured, commonly used, and machine-readable format.

Right to Restrict Processing

You may request that jlpj restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data you have contested is being verified, or while an objection is being assessed.

Right to Withdraw Consent

Where processing is based solely on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of your rights, contact jlpj's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." jlpj will respond within 15 business days in accordance with NPC guidelines. Verification of your identity may be required before processing a request. If you are not satisfied with jlpj's response, you may lodge a complaint with the National Privacy Commission of the Philippines.

11 Children & Minors

The jlpj platform is strictly intended for individuals who are 21 years of age or older, in compliance with PAGCOR's minimum age requirements for online gaming in the Philippines. jlpj does not knowingly collect personal data from persons under 21 years of age.

As part of our KYC verification process, jlpj verifies the age of every account holder before processing any withdrawal. Any account found to belong to a person under 21 years of age will be immediately and permanently suspended, and any personal data associated with that account will be handled in accordance with applicable legal requirements.

If you are a parent or guardian and believe that a person under 21 years of age has registered an account with jlpj using false information, please contact us immediately at [email protected]. We will investigate and take appropriate action without delay.

12 Marketing Communications

With your consent, jlpj may send you promotional communications via SMS to your registered Philippine mobile number, or via in-platform notifications, regarding bonuses, new game releases, promotions, and platform updates relevant to your account.

You may withdraw your consent to marketing communications at any time through any of the following methods:

Updating your communication preferences in Account Settings;
Replying STOP to any SMS marketing message;
Contacting jlpj support via live chat or at [email protected] and requesting removal from marketing lists.

Withdrawal of marketing consent will take effect within 3 business days. Withdrawal of marketing consent does not affect the lawfulness of any processing that occurred prior to withdrawal, and does not affect transactional communications (such as deposit confirmations, withdrawal status updates, and security alerts) which jlpj continues to send regardless of marketing preferences.

jlpj does not send marketing communications on behalf of third parties, and does not share your contact details with third-party advertisers or marketing services for the purpose of direct marketing to you.

13 Changes to This Privacy Policy

jlpj reserves the right to update or amend this Privacy Policy at any time in response to changes in applicable law, regulatory requirements, or our data processing practices. When material changes are made, jlpj will notify you by one or more of the following means prior to the change taking effect: an in-platform notification upon login, an SMS to your registered mobile number, or a prominent notice on the jlpj homepage.

The updated Privacy Policy will display the revised effective date at the top of this page. Your continued use of the jlpj platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you should discontinue use of the platform and request account closure before the effective date.

We encourage you to review this Privacy Policy periodically to stay informed of how jlpj protects your personal data. The most current version will always be accessible at jlpj.asia/privacy-policy.

14 Contact & Data Protection Officer

jlpj has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act of 2012. If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a privacy-related concern, you may contact the jlpj DPO through the following channels:

Email: [email protected] — subject line: "Data Privacy Request" or "DPO Inquiry";
Live Chat: Available 24/7 from within your jlpj account — ask to be connected to the Data Privacy team;
Response Time: jlpj commits to acknowledging all privacy-related requests within 3 business days and to providing a substantive response within 15 business days.

If you are not satisfied with jlpj's handling of your privacy concern or data rights request, you have the right to file a complaint with:

National Privacy Commission (NPC) — Republic of the Philippines

The NPC is the Philippine government authority responsible for administering and implementing the Data Privacy Act of 2012. Complaints can be filed through the NPC's official complaint portal at privacy.gov.ph. jlpj cooperates fully with all NPC inquiries and investigations.

jlpj is committed to resolving privacy concerns at the first point of contact. Our support team and DPO are trained to handle data privacy matters with care, confidentiality, and urgency. Please do not hesitate to reach out — we are here to help.

What We Collect

How We Protect It

Your Rights

No Data Selling

Cookies & Tracking

Retention & Deletion