jl989 Privacy Policy

1. Who We Are (Data Controller)

jl989 (operating at jl989.club) is the Data Controller responsible for the personal data of players and users of our platform. As a PAGCOR-regulated online casino and sports betting operator serving Filipino players across the Philippines, jl989 processes personal data as required to deliver our services, meet our regulatory obligations, and maintain platform integrity.

Our designated Data Protection Officer (DPO) oversees compliance with the Philippine Data Privacy Act of 2012 (RA 10173) and is the point of contact for all data privacy inquiries. Contact details for the DPO are provided in Section 14 of this Policy.

2. Categories of Personal Data We Collect

jl989 collects the following categories of personal data about players and users:

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or biometric data beyond what is contained in government-issued ID documents required for KYC verification.

3. How We Collect Personal Data

jl989 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, or contacting customer support.
• Automated collection: Technical and usage data collected automatically when you access and use the jl989 platform, including via cookies and server logs.
• Third-party payment providers: Transaction confirmation data received from GCash, PayMaya, and banking partners (BPI, BDO, Metrobank) when you deposit or withdraw.
• Identity verification services: Where jl989 uses a third-party KYC verification service, that provider may supply verification status data derived from the documents you submit.
• Regulatory and compliance sources: Watchlist screening data from legally mandated compliance databases as required by Philippine AML regulations.

4. Purposes of Processing

jl989 processes your personal data for the following purposes:

• Account management: Creating, maintaining, and administering your jl989 player account, including authentication and session management.
• Age and identity verification: Confirming that all players meet the PAGCOR-mandated 21+ age requirement and are who they claim to be.
• Payment processing: Processing deposits and withdrawals in Philippine Peso via your chosen payment method.
• Regulatory compliance: Meeting obligations under PAGCOR licensing conditions, RA 9160 (Anti-Money Laundering Act), and RA 10173 (Data Privacy Act).
• Responsible gaming: Monitoring gaming activity for signs of problem gambling and administering self-exclusion, deposit limit, and session time controls.
• Fraud prevention: Detecting and preventing fraudulent activity, account takeover, and misuse of the jl989 platform.
• Customer support: Responding to inquiries, complaints, and account disputes submitted via our support channels.
• Platform improvement: Analysing aggregated usage data to improve the performance, design, and game offering of the jl989 platform.
• Marketing communications: Sending promotional offers and updates to players who have opted in to receive such communications, with the right to opt out at any time.

5. Legal Bases for Processing

Under the Philippine Data Privacy Act, jl989 relies on the following legal bases for processing personal data:

• Contractual necessity: Processing required to perform the contract between jl989 and the player (account operation, payment processing, game provision).
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AML obligations, and other applicable Philippine legal requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and aggregated analytics, where such processing does not override the player's privacy rights.
• Consent: Processing for marketing communications, where you have explicitly opted in. This consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Third-Party Disclosure

jl989 does not sell your personal data to third parties. We share personal data only in the following circumstances and with appropriate data processing agreements in place:

• Payment service providers: GCash, PayMaya, BPI, BDO, and Metrobank receive the transaction data necessary to process deposits and withdrawals.
• KYC and identity verification providers: Third-party KYC vendors process identification documents on jl989's behalf under strict confidentiality obligations.
• Game content providers: Game software providers may receive anonymised session data necessary to deliver their games through the jl989 platform.
• Regulatory authorities: PAGCOR, the AMLC, and other Philippine government authorities as required by law, court order, or regulatory direction.
• IT and infrastructure providers: Cloud hosting, security, and customer support platform providers who process data solely on jl989's instructions.

7. International Data Transfers

Some of jl989's service providers and game content partners may be located outside the Philippines. Where personal data is transferred internationally, jl989 ensures that appropriate safeguards are in place in accordance with National Privacy Commission (NPC) guidelines, including contractual data protection clauses that impose equivalent data protection standards on the recipient.

Players who have concerns about international data transfers may contact our DPO for further information about the specific safeguards applicable to their data.

8. Data Retention

jl989 retains personal data for as long as necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods mandated by Philippine law:

• Account and KYC records: Retained for a minimum of five (5) years from account closure, as required by PAGCOR licensing conditions and AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, per RA 9160 requirements.
• Customer support records: Retained for three (3) years from the date of the interaction unless a longer period is required for an ongoing dispute.
• Marketing opt-in records: Retained for the duration of the marketing relationship plus one (1) year after opt-out to demonstrate compliance.

Upon expiry of the applicable retention period, jl989 securely deletes or anonymises personal data in accordance with NPC guidelines.

9. Security Measures

jl989 implements industry-standard technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction, including:

• TLS/SSL encryption for all data transmitted between your device and the jl989 platform.
• Encryption at rest for stored sensitive data including financial and identity records.
• Multi-factor authentication for staff access to systems containing personal data.
• Role-based access controls ensuring staff can only access data necessary for their specific function.
• Regular security assessments and penetration testing of the jl989 platform.
• Incident response procedures for timely detection and reporting of personal data breaches to the NPC as required by RA 10173.

10. Cookies & Tracking Technologies

The jl989 platform uses cookies and similar tracking technologies to operate the platform, maintain your session, and analyse usage patterns. The following categories of cookies are used:

• Strictly necessary cookies: Essential for logging in, maintaining your session, and accessing secure areas of the jl989 platform. These cannot be disabled without disrupting core functionality.
• Functional cookies: Remember your preferences (e.g., language settings, game lobby display preferences) to improve your experience.
• Analytics cookies: Collect anonymised data about how players navigate and use the jl989 platform, used to identify areas for improvement. No individual player is identified in these reports.

You may control cookie settings through your browser preferences. Disabling strictly necessary cookies will prevent you from logging in and using jl989 services. Disabling other cookies may limit functionality but will not prevent basic platform access.

11. Your Data Subject Rights

As a data subject under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by jl989:

To exercise any of these rights, contact jl989's Data Protection Officer using the details in Section 14. We will respond within fifteen (15) business days as required by NPC guidelines. Identity verification may be required before processing your request.

12. Children's Privacy

The jl989 platform is strictly for adults aged 21 years and above, as mandated by PAGCOR. We do not knowingly collect personal data from persons under the age of 21. If jl989 discovers that personal data has been collected from an individual who is under 21 years of age, that account will be immediately closed, all data will be deleted to the extent not required for regulatory reporting purposes, and the matter will be reported to PAGCOR as required.

Parents or guardians who believe a minor has registered on the jl989 platform should contact our support team immediately.

13. Amendments to This Privacy Policy

jl989 may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or platform functionality. When material changes are made, we will notify registered players via their registered email address and publish the updated Policy on jl989.club with a revised "Last Updated" date.

Your continued use of the jl989 platform after the effective date of any amendments constitutes your acknowledgment of the updated Privacy Policy. If you do not accept the changes, you may request account closure before the effective date.

14. Contact & Data Protection Officer

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by jl989, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe that jl989 has processed your personal data in violation of RA 10173.