jllll Privacy Policy

01 Introduction

This Privacy Policy ("Policy") is issued by jllll ("jllll," "we," "us," or "our") and applies to all personal data collected through the jllll website at jllll.app and any associated services, features, games, and communications (collectively, the "Platform").

jllll is committed to protecting the privacy and security of its players. We understand that Filipino players entrust us with sensitive personal and financial information, and we take that responsibility seriously. This Policy explains in plain terms what data we collect, why we collect it, how it is used, who it may be shared with, and what rights you have as a data subject.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together govern your use of the jllll Platform.

02 Data We Collect

jllll collects the following categories of personal data from players and Platform visitors:

2.1 Identity & Contact Data

• Full legal name;
• Date of birth (for age verification — players must be 21 or older);
• Email address;
• Mobile phone number;
• Residential address (city, province, country);
• Government-issued identification documents (for KYC verification).

2.2 Account Data

• Username and encrypted password;
• Account registration date and history;
• Account preferences and settings;
• Responsible gaming limits and self-exclusion status.

2.3 Financial Data

• Deposit and withdrawal transaction records;
• Payment method identifiers (e.g., GCash mobile number, bank account name — not full account numbers);
• Transaction amounts in Philippine Peso (₱);
• Bonus and promotional credit history;
• Loyalty points balance and redemption history.

2.4 Technical & Usage Data

• IP address and approximate geographic location;
• Device type, operating system, and browser information;
• Session duration and login timestamps;
• Pages visited and features used on the Platform;
• Game history, wager amounts, and outcomes;
• Referral source and marketing attribution data.

2.5 Communications Data

• Records of your correspondence with jllll support;
• Live chat transcripts;
• Feedback and survey responses;
• Email and SMS communication history.

03 How We Collect Data

jllll collects personal data through the following means:

3.1 Directly From You

The majority of personal data we hold is provided directly by you when you register an account, complete identity verification, make a deposit or withdrawal, contact our support team, participate in promotions, or update your account settings.

3.2 Automatically

When you access the jllll Platform, certain technical data is collected automatically through cookies, web beacons, and similar tracking technologies. This includes your IP address, device identifiers, browser type, and behavioral data such as pages visited and time spent on the Platform. See Section 7 for more detail on our use of cookies.

3.3 From Third Parties

jllll may receive personal data about you from third parties in limited circumstances, including:

• Payment processors (e.g., GCash, PayMaya, BPI, BDO, Metrobank) for transaction verification;
• Identity verification and KYC service providers;
• Fraud detection and anti-money laundering (AML) screening services;
• Marketing and analytics partners, where you have consented to data sharing with those parties.

04 How We Use Your Data

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

05 Legal Basis for Processing

jllll processes your personal data on the following legal grounds, consistent with applicable Philippine data protection legislation:

5.1 Contractual Necessity

Processing is necessary to perform our contract with you — that is, to operate your jllll account, process your transactions, and deliver the gaming services you have signed up for. Without this processing, we cannot provide the Platform to you.

5.2 Legal Obligation

Certain processing activities are required by law. These include identity verification (KYC), age verification (21+ requirement), anti-money laundering (AML) checks, and regulatory reporting obligations. jllll must carry out this processing regardless of your preferences.

5.3 Legitimate Interests

jllll processes some data on the basis of its legitimate business interests, including fraud prevention, Platform security, responsible gaming monitoring, and improving the quality of our services. We ensure that our legitimate interests do not override your fundamental privacy rights.

5.4 Consent

Where processing is not required by contract or law, jllll will ask for your explicit consent. This applies primarily to marketing communications. You may withdraw your consent at any time by updating your account preferences or contacting our support team.

06 Data Sharing & Disclosure

jllll does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

6.1 Service Providers

jllll works with trusted third-party service providers who process data on our behalf, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC and identity verification providers, cloud hosting and infrastructure providers, customer support platform providers, and analytics and fraud detection services. All service providers are contractually bound to process data only on jllll's instructions and to maintain appropriate security standards.

6.2 Regulatory and Law Enforcement Authorities

jllll may disclose personal data to Philippine regulatory bodies, law enforcement agencies, or other government authorities where required by law, court order, or regulatory directive. This includes disclosures required under anti-money laundering regulations and gaming compliance obligations.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of jllll's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Policy that result from it.

6.4 With Your Consent

jllll may share your data with other third parties where you have given your explicit consent to such sharing. You may withdraw this consent at any time.

07 Cookies & Tracking Technologies

jllll uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and deliver relevant content. A cookie is a small text file stored on your device when you visit a website.

7.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming limits you have set.
• Analytics Cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and activity. These are only placed with your consent.

7.2 Managing Cookies

You can control non-essential cookies through your browser settings or through the cookie preference center available on the jllll Platform. Please note that disabling certain cookies may affect the functionality of the Platform and your gaming experience.

08 Data Retention

jllll retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations.

As a general guide, jllll applies the following retention periods:

• Active account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AML and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC and identity documents: Retained for the period required by applicable Philippine regulations, typically five (5) years from account closure.
• Support communications: Retained for up to three (3) years from the date of the interaction.
• Marketing data: Retained until you withdraw consent or for up to two (2) years of inactivity, whichever comes first.

When data is no longer required, jllll will securely delete or anonymize it in accordance with our internal data disposal procedures.

09 Data Security

jllll implements a comprehensive set of 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 jllll Platform;
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and financial identifiers;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication options for player accounts;
• Continuous monitoring for suspicious activity and unauthorized access attempts;
• Incident response procedures to address data breaches promptly and in compliance with applicable notification requirements.

10 Your Privacy Rights

As a jllll player and data subject, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our support team. We will respond to verified requests within the timeframes required by applicable law.

• Right of Access: You have the right to request a copy of the personal data jllll holds about you, along with information about how it is being used.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected.
• Right to Erasure: In certain circumstances, you have the right to request that jllll delete your personal data. Note that this right may be limited where retention is required by law or regulatory obligation.
• Right to Restrict Processing: You may request that jllll restrict the processing of your data in certain circumstances, such as while a dispute about accuracy is being resolved.
• Right to Data Portability: Where processing is based on your consent or a contract, you may request that your data be provided to you in a structured, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests, including profiling for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

11 Children's Privacy

The jllll Platform is strictly intended for individuals aged 21 years and above. jllll does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on the jllll Platform or provided us with personal data, please contact our support team immediately so that we can investigate and take appropriate action.

12 Third-Party Links

The jllll Platform may contain links to third-party websites or services for informational or operational purposes. jllll is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

The inclusion of a link to a third-party website does not constitute an endorsement by jllll of that website or its operators.

13 Changes to This Policy

jllll reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered players via email or an in-platform notification.

Your continued use of the jllll Platform following the posting of any changes to this Policy constitutes your acceptance of those changes. We encourage you to review this Policy periodically to stay informed about how jllll protects your personal data.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way jllll handles your personal data, please reach out to our support team. We are available 24 hours a day, 7 days a week.