Privacy Policy – jll96

1. Introduction

Welcome to jll96. This Privacy Policy ("Policy") describes how jll96 ("jll96," "we," "us," or "our") collects, uses, discloses, and safeguards the personal information of users ("you" or "User") who access or use the jll96 website, mobile platform, and all related services (collectively, the "Platform").

jll96 is committed to protecting the privacy and personal data of all Filipino players and users of our Platform. We process personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission ("NPC").

By registering an account or using the jll96 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, please discontinue use of the Platform immediately.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a jll96 account, complete identity verification, make transactions, or contact our support team, we may collect the following categories of personal information:

• Identity Information: Full legal name, date of birth, nationality, and government-issued identification number (e.g., PhilSys ID, passport, driver's license, SSS/GSIS ID, or PRC ID).
• Contact Information: Email address, Philippine mobile number, and residential address.
• Financial Information: GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), and transaction history on the jll96 Platform.
• Account Credentials: Username and encrypted password (we never store passwords in plain text).
• Communications: Records of your correspondence with jll96 customer support, including live chat transcripts and email exchanges.

2.2 Information Collected Automatically

When you access the jll96 Platform, we automatically collect certain technical and usage data, including:

• IP address and approximate geographic location (city/region level).
• Device type, operating system, browser type and version.
• Pages visited, features used, games played, and session duration on the Platform.
• Referring URLs and search terms used to find the jll96 Platform.
• Cookie identifiers and similar tracking technology data (see Section 6).

2.3 Information from Third Parties

We may receive personal information about you from third-party sources, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification service providers, fraud prevention agencies, and PAGCOR or other regulatory authorities where required by law.

3. How We Use Your Information

jll96 uses the personal information we collect for the following purposes:

• Account Management: To create, maintain, and manage your jll96 account, including verifying your identity and age (21+ requirement) in compliance with PAGCOR guidelines.
• Service Delivery: To provide you with access to games, sports betting, live dealer services, and all other features of the jll96 Platform.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted payment methods.
• Regulatory Compliance: To comply with our obligations under the Data Privacy Act of 2012, PAGCOR regulations, Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, cheating, money laundering, and other prohibited activities on the Platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming activity and enforce responsible gaming tools such as deposit limits and self-exclusion where applicable.
• Marketing & Promotions: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the jll96 Platform.

4. Legal Basis for Processing

jll96 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide the jll96 Platform services you have registered for).
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA obligations, and NPC directives.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent (e.g., for direct marketing communications), you have the right to withdraw that consent at any time by contacting us at [email protected].

5. Sharing Your Information

jll96 does not sell, rent, or trade your personal information 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:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions.
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged to verify your identity and prevent fraud.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where required by law or regulatory directive.
• Technology Service Providers: Cloud hosting, data analytics, customer support software, and cybersecurity vendors who process data on our behalf under strict data processing agreements.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors where necessary to protect jll96's legal rights or comply with legal proceedings.

All third parties with whom jll96 shares personal data are required to maintain appropriate technical and organizational security measures and to process personal data only in accordance with jll96's instructions and applicable Philippine data protection law.

6. Cookies & Tracking Technologies

jll96 uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the Platform, remember your preferences, and analyze Platform usage. The types of cookies we use include:

• Essential Cookies: Necessary for the Platform to function correctly, including maintaining your login session and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and display options to personalize your experience.
• Analytics Cookies: Help us understand how users interact with the jll96 Platform so we can improve performance and user experience.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may affect the functionality of the jll96 Platform.

7. Data Retention

jll96 retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law. Specifically:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with PAGCOR regulations and AMLA requirements.
• KYC and identity verification documents are retained for the period required by applicable Philippine law.
• Customer support communications are retained for up to three (3) years from the date of the interaction.
• Marketing consent records are retained until you withdraw your consent and for a reasonable period thereafter as evidence of compliance.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, jll96 will securely delete or anonymize the data.

8. Data Security

jll96 implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the jll96 Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform.
• Two-factor authentication (2FA) available for all jll96 user accounts.

While jll96 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that poses a risk to your rights and freedoms, jll96 will notify the National Privacy Commission and affected users in accordance with the Data Privacy Act of 2012.

9. Your Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jll96:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed — which this Privacy Policy fulfills.
• Right of Access: The right to request a copy of the personal data jll96 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, subject to our legal retention obligations.
• Right to Object: 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: The right to receive your personal data in a structured, commonly used format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days in accordance with the Data Privacy Act of 2012.

10. Children's Privacy

The jll96 Platform is strictly intended for users who are 21 years of age or older, in accordance with PAGCOR guidelines governing online gaming in the Philippines. jll96 does not knowingly collect personal data from individuals under the age of 21.

If jll96 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the jll96 Platform, please contact us immediately at [email protected].

11. Changes to This Policy

jll96 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, we will notify registered users via email or a prominent notice on the Platform, and update the "Last Updated" date at the top of this page.

Your continued use of the jll96 Platform following the posting of any revised Privacy Policy constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed about how jll96 protects your personal data.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by jll96, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 inside your jll96 account dashboard.
• Response Time: We aim to respond to all data privacy requests within thirty (30) days Philippine Standard Time.