Privacy Policy — jl169 Casino

1. Introduction

1.1 jl169 Casino ("jl169," "we," "us," or "our") is committed to protecting the personal data of every individual who accesses jl169.club, creates an account, deposits funds, places wagers, or otherwise interacts with our platform and support services.

1.2 This Privacy Policy is issued in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC"). Where applicable, jl169 also observes internationally recognised data protection principles consistent with the DPA's intent.

1.3 By registering an account on jl169 or by continuing to use the Platform after being presented with this Policy, you acknowledge that you have read and understood how jl169 handles your personal data as described herein. If you do not agree, please discontinue use of the Platform and contact us to close your account.

1.4 This Policy applies to all personal data collected from players, prospective players, and visitors through jl169.club and any jl169-branded communications.

2. Data Controller

2.1 jl169 Casino is the personal information controller ("PIC") in respect of personal data collected through jl169.club. As PIC, jl169 determines the purposes and means of processing your personal data and bears primary responsibility for compliance with the DPA.

2.2 jl169 has designated a Data Protection Officer ("DPO") responsible for overseeing data privacy compliance and serving as the point of contact for data subjects exercising their rights under the DPA. Contact details for the DPO are set out in Section 14 of this Policy.

3. Personal Data We Collect

3.1 Registration and Identity Data

When you create a jl169 account, we collect: full legal name, date of birth, nationality, gender, residential address (including city, province, and postal code), Philippine mobile number, email address, and account username.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR regulatory requirements and Philippine AML law, jl169 collects copies of government-issued identification documents such as the PhilSys National ID, UMID, Driver's License, or Philippine Passport. This may include facial images where submitted as part of a liveness check.

3.3 Financial and Transaction Data

We collect deposit and withdrawal records, payment method identifiers (e.g., GCash-registered mobile number, bank account details), transaction amounts in Philippine Peso (PHP), timestamps, and processing references. Full payment card numbers, if applicable, are processed by licensed payment processors and are not stored on jl169 servers.

3.4 Gaming and Activity Data

jl169 records all game sessions, bet amounts, game outcomes, bonus utilisation, session start and end times, and responsible gaming tool settings (e.g., deposit limits set by the Player).

3.5 Technical and Device Data

We automatically collect IP address, device type and model, operating system, browser type and version, screen resolution, and referring URL when you access jl169.club.

3.6 Communications Data

Records of communications between you and jl169 support (including live chat transcripts, email correspondence, and SMS records) are retained for quality assurance, dispute resolution, and regulatory compliance purposes.

Category	Examples	Mandatory?
Identity	Name, DOB, address, mobile number	Yes — account creation
KYC Documents	Government ID, selfie/liveness	Yes — withdrawal access
Financial	GCash number, bank details, TX records	Yes — deposits/withdrawals
Gaming Activity	Bets, wins, session history	Automatic — generated by use
Technical	IP, device, browser	Automatic — generated by use
Communications	Support chat, emails	Where applicable

4. How We Use Your Personal Data

jl169 processes your personal data for the following purposes:

• Account creation and management — to establish, maintain, and secure your jl169 account;
• Identity and age verification — to comply with PAGCOR's 21+ age requirement and KYC obligations;
• Payment processing — to process deposits via GCash, PayMaya, BDO, BPI, Metrobank, and other methods, and to process withdrawal requests to verified payment accounts;
• Gaming services — to provide access to jl169's game library, record game outcomes, calculate payouts, and administer bonuses;
• Regulatory compliance — to meet obligations under the DPA, PAGCOR licensing requirements, and the Anti-Money Laundering Act (RA 9160, as amended);
• Fraud prevention and security — to detect, investigate, and prevent unauthorised account access, bonus abuse, payment fraud, and money laundering;
• Responsible gaming — to administer deposit limits, self-exclusion requests, and problem gambling referrals;
• Customer support — to respond to enquiries, resolve disputes, and manage complaints;
• Platform improvement — to analyse usage patterns, diagnose technical issues, and improve jl169's services;
• Marketing communications — to send promotional offers, bonus notifications, and platform updates, where you have consented or where jl169 has a legitimate interest in direct marketing to existing customers (subject to your right to opt out).

5. Legal Basis for Processing

5.1 jl169 processes your personal data on the following legal bases under the DPA and its IRR:

• Contractual necessity — processing required to perform the jl169 user agreement, including account management, payment processing, and game delivery;
• Legal obligation — processing required to comply with applicable Philippine laws, including PAGCOR regulations, the AML Act, and NPC directives;
• Legitimate interests — processing for fraud prevention, platform security, and direct marketing to existing jl169 customers, where such interests are not overridden by your rights;
• Consent — where jl169 relies on your consent for specific processing activities (e.g., marketing communications to prospective customers), you retain the right to withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 jl169 does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

6.2 jl169 may share your personal data with the following categories of recipients where necessary for the purposes described in this Policy:

• Payment processors — GCash (GXI), PayMaya (Maya Bank), and Philippine commercial banks for transaction processing and settlement;
• Gaming software providers — certified game developers and live casino studios whose games are available on jl169, limited to data required to provide the game service;
• KYC and identity verification providers — third-party services used to verify government-issued ID documents;
• IT and hosting providers — cloud infrastructure and security service providers under contractual data processing agreements;
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities where required by law or lawful court order.

6.3 All third-party service providers who process personal data on jl169's behalf are required to enter into data processing agreements that impose obligations equivalent to those applicable to jl169 under the DPA.

6.4 In the event of a merger, acquisition, or sale of jl169's assets, personal data may be transferred to a successor entity. Affected data subjects will be notified in advance.

6.5 jl169 does not share gaming session data, account balances, or win/loss histories with any party except as required by law or regulation.

7. Cookies and Tracking Technologies

7.1 jl169.club uses cookies and similar tracking technologies (e.g., local storage, session tokens) to enable core platform functionality, maintain your login session, remember your preferences, and analyse aggregate usage patterns.

7.2 The following categories of cookies are used on jl169:

• Strictly necessary cookies — required for the Platform to function (e.g., session authentication, security tokens). These cannot be disabled without impairing platform functionality.
• Functional cookies — remember your language, currency, and responsible gaming settings between sessions.
• Analytics cookies — collect anonymised data on page views, session duration, and navigation paths to help jl169 improve the Platform.

7.3 You may configure your browser to refuse or delete cookies. Disabling strictly necessary cookies will impair your ability to log in and use jl169's services.

7.4 jl169 does not use third-party advertising or retargeting cookies that track your activity across websites outside of jl169.club.

8. Data Retention

8.1 jl169 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, and in any event for no shorter period than required by applicable law.

8.2 The following retention periods apply as a general guide:

• Account data and KYC records — retained for the duration of the account relationship and for a minimum of five (5) years following account closure, as required by AML regulations;
• Transaction records — minimum five (5) years from the date of the transaction, in compliance with the AML Act;
• Gaming activity logs — minimum two (2) years for dispute resolution purposes, longer where required by PAGCOR;
• Support communications — minimum two (2) years from the date of last contact;
• Marketing consent records — retained until withdrawal of consent plus one (1) year.

8.3 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised.

9. Data Security

9.1 jl169 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and jl169's servers;
• Encryption of sensitive data (including passwords and KYC document data) at rest;
• Access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing;
• SMS OTP two-factor authentication for jl169 account login;
• Automated monitoring systems for unusual login activity and suspicious transactions.

9.2 In the event of a personal data breach that is likely to harm data subjects, jl169 will notify the NPC within 72 hours of discovery and will notify affected data subjects without undue delay, in accordance with NPC Circular No. 16-03.

10. Your Data Subject Rights

10.1 Under the Philippine Data Privacy Act of 2012 and its IRR, you have the following rights in respect of your personal data held by jl169:

• Right to be informed — to know whether jl169 holds your personal data and to receive clear information about how it is processed;
• Right of access — to request a copy of the personal data jl169 holds about you;
• Right to rectification — to request correction of inaccurate or incomplete personal data;
• Right to erasure or blocking — to request deletion or blocking of your personal data where processing is unlawful or the purpose has been fulfilled, subject to overriding legal obligations (e.g., AML retention requirements);
• Right to object — to object to processing based on legitimate interests, including direct marketing;
• Right to data portability — to receive your personal data in a structured, commonly used electronic format;
• Right to damages — to claim compensation for damages suffered as a result of a DPA violation by jl169;
• Right to lodge a complaint — to file a complaint with the National Privacy Commission (NPC) if you believe your rights have been violated.

10.2 To exercise any of the above rights, please contact jl169's Data Protection Officer at the details provided in Section 14. jl169 will respond to verified requests within fifteen (15) business days. Identity verification may be required before processing certain requests.

11. Children's Privacy and Age Restriction

11.1 jl169's services are strictly restricted to individuals who are twenty-one (21) years of age or older, in compliance with PAGCOR regulations. jl169 does not knowingly collect personal data from individuals under 21.

11.2 Where jl169 discovers or has reasonable grounds to believe that a user is under 21, the account will be immediately closed, personal data will be deleted (subject to any mandatory legal retention period), and any deposited funds will be returned through the original payment method following verification.

11.3 If you have reason to believe that an individual under 21 has created a jl169 account, please contact jl169 support immediately at [email protected].

12. Cross-Border Data Transfers

12.1 Some of jl169's service providers — including cloud infrastructure providers, gaming software suppliers, and KYC verification services — may be located outside the Philippines. Where personal data is transferred outside the Philippines, jl169 ensures that such transfers are subject to appropriate safeguards, including contractual data protection clauses consistent with NPC standards, to ensure your data receives equivalent protection regardless of where it is processed.

12.2 jl169 will not transfer personal data to jurisdictions that do not provide adequate data protection without implementing appropriate additional safeguards and, where required, obtaining prior approval from the NPC.

13. Changes to This Privacy Policy

13.1 jl169 may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or Platform features. Material changes will be communicated to registered account holders via email or via a prominent notice on jl169.club at least 15 days before the changes take effect.

13.2 Your continued use of the Platform following the effective date of any update constitutes your acknowledgment of the revised Privacy Policy. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision.

14. Contact & Data Protection Officer

14.1 For questions, concerns, or requests relating to your personal data, or to exercise any of the rights described in Section 10, please contact jl169's Data Protection Officer:

Data Protection Officer — jl169 Casino
Email: [email protected] (plain text — not a clickable link)
Available: 24 hours a day, 7 days a week

14.2 If you are dissatisfied with jl169's response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.