jl95 Privacy Policy

This Privacy Policy ("Policy") describes how jl95 ("jl95," "we," "us," or "our") collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," or "Player") who access or use the jl95 online gaming platform available at https://jl95.app and any associated mobile-optimized interfaces (collectively, the "Platform").

jl95 is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

By registering an account on jl95, accessing the Platform, or otherwise providing us with your personal data, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

For the purposes of the Data Privacy Act of 2012 and this Policy, jl95 acts as the Personal Information Controller (PIC) in respect of the personal data collected through the Platform. As PIC, jl95 determines the purposes and means of processing your personal data.

Where jl95 engages third-party service providers to process personal data on its behalf — such as payment processors, KYC verification providers, and analytics platforms — those providers act as Personal Information Processors (PIPs) and are contractually bound to process your data only in accordance with jl95's instructions and applicable Philippine data protection law.

jl95 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection legislation. You may contact the DPO using the details provided in Section 13 of this Policy.

jl95 collects only the personal data that is necessary and proportionate to the purposes described in this Policy. The categories of personal data we collect include:

jl95 does not intentionally collect sensitive personal information as defined under the Data Privacy Act (such as health data, religious beliefs, or political affiliations) unless specifically required by law or regulatory obligation, such as for responsible gaming assessments.

jl95 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions.
• Automatically — through cookies, web beacons, log files, and similar tracking technologies when you access and interact with the Platform. See Section 9 for full details on our cookie practices.
• From third parties — including identity verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), fraud prevention services, and analytics providers, where necessary to verify your identity, process transactions, or comply with legal obligations.

jl95 processes your personal data only where there is a lawful basis for doing so under the Data Privacy Act of 2012. The primary purposes for which we process your data, and the corresponding legal bases, are as follows:

• Account Registration & Management: To create and manage your jl95 player account, verify your identity, and provide you with access to the Platform. Legal basis: Performance of a contract.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods. Legal basis: Performance of a contract.
• KYC & Age Verification: To verify that you meet the minimum age requirement of 21 years and to comply with anti-money laundering obligations. Legal basis: Legal obligation.
• Regulatory Compliance: To comply with applicable Philippine laws and regulations, including reporting obligations to PAGCOR and the Anti-Money Laundering Council (AMLC). Legal basis: Legal obligation.
• Responsible Gaming: To monitor gaming behavior, identify potential problem gambling indicators, and administer responsible gaming tools such as deposit limits and self-exclusion. Legal basis: Legitimate interest and legal obligation.
• Customer Support: To respond to your inquiries, complaints, and support requests. Legal basis: Performance of a contract and legitimate interest.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the Platform. Legal basis: Legitimate interest and legal obligation.
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the functionality and user experience of the jl95 Platform. Legal basis: Legitimate interest.
• Marketing Communications: To send you promotional offers, bonus notifications, and news about jl95 — but only where you have given your explicit consent to receive such communications. Legal basis: Consent. You may withdraw your consent at any time by contacting our support team.

jl95 will not process your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing a separate lawful basis.

jl95 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to facilitate deposits and withdrawals from your jl95 account.
• KYC & Identity Verification Providers: Third-party providers engaged to verify your identity and age in compliance with applicable regulations.
• Fraud Prevention & Security Services: Providers that assist jl95 in detecting and preventing fraudulent activity, account takeovers, and other security threats.
• IT & Platform Infrastructure Providers: Cloud hosting, database management, and technical support providers who process data on jl95's behalf under strict contractual data processing agreements.
• 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, court order, or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies, where jl95 is legally required or permitted to disclose personal data in connection with the investigation or prosecution of criminal activity.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by jl95, subject to professional confidentiality obligations.

Where jl95 shares your data with third-party processors, we ensure that appropriate data processing agreements are in place, requiring those processors to handle your data securely and only in accordance with jl95's instructions and applicable Philippine data protection law.

jl95 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with jl95, and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
• Transaction & Financial Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC Documentation: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory authority.
• Gaming History: Retained for a minimum of three (3) years from the date of the gaming activity, for responsible gaming monitoring and dispute resolution purposes.
• Support Communications: Retained for a minimum of two (2) years from the date of the last communication, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the duration of your consent and for a reasonable period thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, jl95 will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless a longer retention period is required by law.

jl95 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the jl95 Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols. Sensitive data stored in our systems is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorized jl95 personnel and third-party processors who have a legitimate need to access it. All access is logged and monitored.
• Firewalls & Intrusion Detection: jl95's infrastructure is protected by enterprise-grade firewalls and intrusion detection systems that monitor for and respond to suspicious activity in real time.
• Regular Security Audits: jl95 conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in the Platform.
• Staff Training: All jl95 personnel who handle personal data receive regular training on data protection obligations and security best practices.

While jl95 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl95 will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act.

You also have a role to play in keeping your data secure. Please ensure that your jl95 account password is strong and unique, and that you do not share your login credentials with anyone. Contact our support team immediately if you suspect unauthorized access to your account.

jl95 uses cookies and similar tracking technologies (such as web beacons and local storage) to operate the Platform, maintain your session, and improve your experience. The types of cookies we use are as follows:

Strictly necessary cookies are placed automatically as they are essential for the Platform to operate. For all other cookie types, jl95 will seek your consent where required by applicable law.

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the jl95 Platform — in particular, disabling strictly necessary cookies may prevent you from logging in or using core Platform features.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by jl95. You may exercise any of these rights by contacting our Data Protection Officer using the details in Section 13:

jl95 will respond to all data subject requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case jl95 will notify you of the extension and the reasons for it. jl95 reserves the right to verify your identity before processing any data subject request.

The jl95 Platform is strictly intended for use by individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. jl95 does not knowingly collect personal data from individuals under the age of 21.

As part of the registration and KYC verification process, jl95 takes active steps to verify the age of all players. If jl95 discovers or has reasonable grounds to believe that a registered player is under 21 years of age, jl95 will:

• Immediately suspend the player's account pending investigation.
• Delete or anonymize any personal data collected from the underage individual, to the extent permitted by applicable law.
• Return any real-money deposits made by the underage individual, at jl95's discretion, following completion of the investigation.
• Withhold any winnings generated during the period of underage access.

If you are a parent or guardian and believe that your child under the age of 21 has registered an account on jl95 or provided personal data to jl95 without your consent, please contact us immediately using the details in Section 13 so that we can take appropriate action.

jl95 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 Policy, jl95 will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending a notification to the email address associated with your account.

The revised Policy will take effect on the date specified in the notice. Your continued use of the jl95 Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with the revised Policy, you must cease using the Platform and may close your account in accordance with the Terms & Conditions.

The "Effective Date" displayed at the top of this page indicates when the current version of this Policy was last updated. We encourage you to review this Policy periodically to stay informed of how jl95 is protecting your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jl95, please contact our Data Protection Officer using the details below. All data subject requests and privacy-related inquiries should be directed to the DPO in the first instance.

Data Protection Officer — jl95
Email: [email protected]
Platform: https://jl95.app

When submitting a data subject request, please include your full name, registered email address, and a clear description of your request so that we can process it efficiently. jl95 may request additional information to verify your identity before acting on any request.