jl95 Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how jl95 ("jl95," "we," "us," or "our") collects, uses, stores, shares, and protects the personal data of users ("you," "Player," or "Data Subject") who access or use the jl95 platform at jl95.org, including all associated games, services, and features (collectively, the "Platform").

jl95 is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. This Policy is drafted in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines of the National Privacy Commission (NPC) of the Philippines.

By registering for a jl95 account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

02 Personal Data We Collect

jl95 collects the following categories of personal data from players:

jl95 does not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect data relating to race, religion, political affiliation, or health status unless specifically required by law.

03 How We Collect Your Data

jl95 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including IP addresses, device identifiers, browser type, and session activity via cookies and similar technologies.
• Third-party sources: Identity verification data from licensed KYC service providers; payment data from GCash, PayMaya, and Philippine banking partners; fraud detection signals from security service providers.
• Regulatory sources: Data shared with or received from PAGCOR and other Philippine regulatory bodies in connection with licensing and compliance obligations.

04 How We Use Your Personal Data

jl95 uses the personal data we collect for the following purposes:

• Account management: Creating, maintaining, and securing your jl95 account; verifying your identity and age (21+ requirement); processing login and authentication.
• Platform operation: Enabling you to play games, place bets, and access all features of the jl95 platform.
• Financial transactions: Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers; maintaining accurate transaction records.
• Legal and regulatory compliance: Meeting obligations under Philippine law, PAGCOR regulations, anti-money laundering (AML) requirements, and the Data Privacy Act of 2012.
• Responsible gaming: Monitoring gaming activity to identify potential problem gambling behavior; enforcing deposit limits, cool-off periods, and self-exclusion requests.
• Fraud prevention and security: Detecting and preventing unauthorized access, fraudulent transactions, bonus abuse, and other prohibited conduct.
• Customer support: Responding to your inquiries, resolving disputes, and improving our support services.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates — only where you have given explicit consent and subject to your right to opt out at any time.
• Platform improvement: Analyzing aggregated, anonymized usage data to improve game offerings, user experience, and platform performance.

jl95 will not use 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 for processing.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, jl95 processes your personal data on the following legal bases:

• Consent: Where you have given clear, informed consent to specific processing activities, such as receiving marketing communications.
• Contractual necessity: Processing required to fulfill our obligations under the jl95 Terms and Conditions, including account management, game operation, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AML obligations, and tax reporting.
• Legitimate interests: Processing necessary for jl95's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights and freedoms.

Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

06 Data Sharing and Disclosure

jl95 does not sell, rent, or trade your personal data to third parties. We may share your data only in the following circumstances:

• Service providers: Third-party vendors engaged to support Platform operations, including KYC verification providers, payment processors (GCash, PayMaya, Philippine banks), IT infrastructure providers, and customer support platforms. All service providers are bound by data processing agreements requiring them to protect your data.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law or regulation.
• Law enforcement: Where jl95 is legally compelled to disclose data in response to a valid court order, subpoena, or lawful request from Philippine law enforcement authorities.
• Business transfers: In the event of a merger, acquisition, or sale of jl95 assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.
• With your consent: Any other sharing of your data will only occur with your explicit prior consent.

07 Data Retention

jl95 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation. Specific retention periods include:

• Account data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• KYC and identity verification documents: Retained for the period required by PAGCOR licensing conditions and applicable law.
• Support communications: Retained for up to three (3) years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• Marketing consent records: Retained until you withdraw consent, plus a reasonable period thereafter to demonstrate compliance.

When personal data is no longer required, jl95 will securely delete or anonymize it in accordance with our data disposal procedures. Anonymized data that can no longer identify you may be retained indefinitely for analytical purposes.

08 Security Measures

jl95 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and jl95 servers is encrypted using SSL/TLS protocols. Sensitive data at rest is encrypted using industry-standard algorithms.
• Access controls: Access to personal data is restricted to authorized jl95 personnel on a strict need-to-know basis. All staff with data access undergo privacy and security training.
• Firewalls and intrusion detection: jl95 employs network firewalls, intrusion detection systems, and regular vulnerability assessments to protect Platform infrastructure.
• Two-factor authentication: Available for player accounts to provide an additional layer of login security.
• Incident response: jl95 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights, jl95 will notify the National Privacy Commission and affected players within the timeframes required by RA 10173.

While jl95 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying jl95 immediately if you suspect unauthorized access to your account.

09 Cookies and Tracking Technologies

jl95 uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the Platform. The types of cookies we use include:

• Essential cookies: Required for the Platform to function, including session management, login authentication, and security features. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences, such as language settings and display options, to personalize your experience.
• Analytics cookies: Collect anonymized data about how players use the Platform, including pages visited and features used, to help us improve performance and user experience.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats.

jl95 does not use third-party advertising cookies or tracking pixels that follow you across unrelated websites. You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect your ability to use some Platform features.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by jl95:

• Right to be informed: The right to know what personal data jl95 collects about you and how it is used — as described in this Policy.
• Right of access: The right to request a copy of the personal data jl95 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 legal retention obligations.
• Right to object: The right to object to certain processing activities, including direct marketing communications.
• 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 file a complaint with the National Privacy Commission (NPC) if you believe jl95 has violated your data privacy rights.

To exercise any of these rights, please contact the jl95 Data Privacy Officer at the contact details provided in Section 13. jl95 will respond to all valid data subject requests within thirty (30) days, as required by Philippine law. We may request proof of identity before processing your request.

11 Children's Privacy and Age Restriction

jl95 is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. jl95 does not knowingly collect personal data from individuals under the age of 21.

If jl95 discovers that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, void any bets or transactions, and securely delete the data. If you believe that a minor has registered on jl95, please contact our support team immediately.

12 Changes to This Privacy Policy

jl95 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, jl95 will notify registered players via email or through a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Platform after any amendments have been published 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 by contacting jl95 support.

We encourage you to review this Policy periodically to stay informed about how jl95 protects your personal data.

13 Contact Our Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by jl95, please contact our designated Data Privacy Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.