Privacy Policy for jlgg

1 Introduction

This Privacy Policy ("Policy") describes how jlgg ("we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you," "your," or "Player") who access or use the jlgg website, mobile platform, and related services (collectively, the "Platform").

jlgg 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) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering an account on jlgg or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

This Policy should be read alongside jlgg's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, jlgg acts as the Personal Information Controller (PIC) in respect of the personal data you provide when using the Platform. This means jlgg determines the purposes and means by which your personal data is processed.

Where jlgg engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and customer support platforms — those parties act as Personal Information Processors (PIPs) and are contractually bound to process your data only in accordance with jlgg's instructions and this Policy.

If you have any questions about how jlgg handles your personal data, or wish to exercise any of your data subject rights, please contact our Data Protection Officer (DPO) using the details provided in Section 15 of this Policy.

3 Data We Collect

jlgg collects the following categories of personal data from players and platform visitors. We collect only what is necessary for the purposes described in this Policy.

4 How We Collect Your Data

jlgg collects personal data through the following means:

• Direct Interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions, you directly provide us with personal data.
• Automated Technologies: When you access the Platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. See Section 8 for more details on our cookie practices.
• Third-Party Sources: We may receive personal data about you from third parties, including identity verification providers (for KYC purposes), payment processors (for transaction verification), and fraud prevention services. All such third parties are contractually required to share data with us lawfully.
• Publicly Available Sources: In limited circumstances related to fraud prevention or regulatory compliance, we may collect data from publicly available sources such as government databases or sanctions lists.

5 How We Use Your Data

jlgg uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your jlgg player account, including processing your registration and verifying your identity.
• Service Delivery: To provide you with access to games, process bets, credit winnings, and deliver the full range of jlgg platform features.
• Financial Transactions: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment channels, and to maintain accurate financial records.
• Regulatory Compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and reporting requirements to relevant authorities such as the Anti-Money Laundering Council (AMLC).
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the Platform and its users.
• Responsible Gaming: To monitor gaming behavior, identify signs of problem gambling, enforce deposit limits and self-exclusion requests, and fulfill our duty of care to players.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the jlgg Platform.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, jlgg processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and jlgg — specifically, to provide you with access to the Platform and its services in accordance with our Terms & Conditions.
• Legal Obligation: Processing is necessary for jlgg to comply with applicable Philippine laws and regulations, including AML legislation, gaming regulations, and tax reporting requirements.
• Legitimate Interests: Processing is necessary for jlgg's legitimate business interests, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — jlgg relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

jlgg 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment service providers, for the purpose of processing your financial transactions.
• Identity Verification Providers: Third-party KYC and AML compliance service providers who assist us in verifying your identity and screening against sanctions lists.
• Game Providers: Software providers whose games are hosted on the jlgg Platform may receive limited technical data necessary to deliver their games to you.
• Customer Support Platforms: Third-party live chat and ticketing systems used to deliver customer support services.
• Regulatory Authorities: Government agencies and regulatory bodies in the Philippines, including PAGCOR, the AMLC, the National Privacy Commission, and law enforcement agencies, where disclosure is required by law or court order.
• Professional Advisors: Lawyers, auditors, and other professional advisors who are bound by confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of jlgg's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

8 Cookies & Tracking Technologies

jlgg uses cookies and similar tracking technologies to enhance your experience on the Platform, ensure its security, and gather analytics data. The following types of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Performance & Analytics Cookies: These cookies collect anonymized information about how visitors use the Platform — such as which pages are visited most frequently and whether error messages are received — to help us improve performance.
• Functional Cookies: These cookies allow the Platform to remember your preferences (such as language settings and display options) to provide a more personalized experience.
• Marketing Cookies: These cookies track your browsing activity to deliver relevant promotional content. They 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 Platform. For strictly necessary cookies, no consent is required as they are essential to service delivery.

9 Data Retention

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

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML legislation.
• KYC Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer Support Communications: Retained for up to three (3) years from the date of the interaction, for dispute resolution and quality assurance purposes.
• Technical and Usage Data: Retained for up to two (2) years, after which it is anonymized or deleted.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with jlgg's data disposal procedures.

10 Data Security

jlgg implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-Bit SSL Encryption: All data transmitted between your device and jlgg's servers is encrypted using industry-standard 256-bit SSL/TLS protocols.
• Access Controls: Access to personal data is restricted to authorized jlgg personnel and service providers on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Secure Data Storage: Personal data is stored on secure servers with physical and logical access controls, firewalls, and intrusion detection systems.
• Regular Security Audits: jlgg conducts regular security assessments and penetration testing to identify and address vulnerabilities in its systems.
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication (2FA) on their accounts for an additional layer of security.
• Data Breach Response: jlgg maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, jlgg will notify the National Privacy Commission and affected players in accordance with the requirements of 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 jlgg. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15.

• Right to Be Informed: You have the right to be informed about how your personal data is collected and processed. This Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data jlgg holds about you, along with information about how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have 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 jlgg's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: You have 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: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

jlgg will respond to all data subject rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with prior notification to you.

12 Children's Privacy

The jlgg Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. jlgg does not knowingly collect personal data from individuals under the age of 21.

If jlgg discovers or is notified that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be returned to the payment source after deducting any applicable processing fees.

If you are a parent or guardian and believe that your child has registered on jlgg, please contact our support team immediately so we can take appropriate action.

13 International Data Transfers

jlgg primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines — for example, where jlgg uses cloud infrastructure or third-party service providers with operations in other jurisdictions.

Where personal data is transferred outside the Philippines, jlgg ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual clauses, data processing agreements, or transfers to jurisdictions recognized as providing adequate data protection.

By using the jlgg Platform, you acknowledge and consent to the transfer of your personal data to other countries as described in this section, subject to the safeguards described above.

14 Changes to This Policy

jlgg reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. The date of the most recent revision is always displayed at the top of this page.

When material changes are made to this Policy, jlgg will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

Your continued use of the jlgg Platform following the posting of any changes constitutes your acceptance of the revised Policy. If you do not agree with the updated Policy, you must cease using the Platform and may request account closure in accordance with our Terms & Conditions.

15 Contact Us & DPO Details

If you have any questions, concerns, or requests relating to this Privacy Policy or the way jlgg handles your personal data, please contact our Data Protection Officer (DPO):

Data Protection Officer, jlgg
Email: [email protected]
Support: [email protected]

You may also reach us via live chat on the Platform, available 24 hours a day, 7 days a week. Our support team is based in the Philippines and is available in English. We aim to respond to all privacy-related inquiries within five (5) business days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.