jl365a Privacy Policy

1 Introduction

jl365a is committed to protecting the privacy and personal data of every player who uses our Platform. We understand that when you create a jl365a account, you trust us with information about yourself — your name, your contact details, your payment information — and we take that responsibility seriously.

This Policy applies to all personal data collected through the jl365a website at https://jl365a.cam, including through account registration, gameplay activity, financial transactions, customer support interactions, and any other engagement with the Platform. It should be read together with our Terms and Conditions and Responsible Gaming Policy, both of which are available on the jl365a Platform.

jl365a operates in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Republic of the Philippines and its Implementing Rules and Regulations, as overseen by the National Privacy Commission (NPC). Where applicable, we also adhere to the relevant provisions of the Anti-Money Laundering Act (AMLA) as amended, and other applicable Philippine laws governing the processing of personal data in a gaming and financial services context.

2 Data Controller

For the purposes of this Policy and applicable Philippine data protection legislation, jl365a acts as the personal information controller (PIC) in respect of personal data collected through the Platform. As the PIC, jl365a determines the purposes and means by which your personal data is processed.

Questions, requests, or complaints regarding the processing of your personal data under this Policy should be directed to our designated Data Protection Officer (DPO), whose contact details are provided in Section 16 of this Policy.

3 Personal Data We Collect

jl365a collects the following categories of personal data in connection with the operation of the Platform:

3.1 Identity and Registration Data

• Full legal name as it appears on a government-issued identification document
• Date of birth (used to verify compliance with the 21+ age requirement)
• Nationality and country of residence
• Government-issued identification document number (e.g., Philippine National ID, Passport, Driver's License)
• Username and encrypted password credentials

3.2 Contact Data

• Registered mobile number (including Philippine mobile network carrier)
• Email address
• Residential address (province, city/municipality, barangay, zip code)

3.3 Financial and Transaction Data

• Deposit and withdrawal amounts and transaction timestamps
• Payment method details (GCash account reference, PayMaya account reference, bank account name, and masked account numbers where applicable)
• Account balance history and bonus fund activity
• Source of funds documentation provided during KYC verification

3.4 Gaming Activity Data

• Game sessions, wagering history, and game outcomes
• Promotional participation records and bonus redemption history
• Responsible gaming tool usage (deposit limits set, session reminders, self-exclusion requests)

3.5 Technical and Device Data

• IP address and geolocation data at the time of login and transactions
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Access logs and Platform navigation behaviour

3.6 Communications Data

• Records of customer support interactions, including live chat transcripts
• Email correspondence with jl365a
• Feedback, complaints, and dispute records

4 How We Collect Your Data

jl365a collects personal data through the following means:

• Direct submission: Information you voluntarily provide during account registration, KYC verification, payment processing, customer support interactions, or when updating your account profile.
• Automated collection: Technical data collected automatically when you access and use the Platform, including IP addresses, device identifiers, cookie data, and navigation logs generated through your interaction with the jl365a website.
• Third-party sources: Identity verification data received from KYC and anti-fraud service providers engaged by jl365a; payment confirmation data received from GCash, PayMaya, BDO, BPI, and other payment processors; and geolocation data received from network service providers for fraud prevention and compliance purposes.

5 Purposes of Data Processing

jl365a processes your personal data for the following purposes:

6 Legal Basis for Processing

jl365a processes your personal data on the following legal grounds under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing that is required to fulfil the contract between you and jl365a — including account registration, KYC verification, transaction processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML obligations, age verification requirements, regulatory reporting, and obligations under PAGCOR-related regulatory frameworks.
• Legitimate interests: Processing for fraud prevention, Platform security, responsible gaming monitoring, and business analytics, where these interests do not override your fundamental rights and freedoms as a data subject.
• Consent: Processing for direct marketing communications and certain cookie-based tracking, where your explicit consent has been obtained and may be withdrawn at any time.

7 Sharing Your Personal Data

jl365a does not sell, rent, or trade your personal data to any third party. We share your personal data only in the following circumstances and only to the extent necessary for the stated purpose:

7.1 Service Providers (Personal Information Processors)

jl365a engages third-party service providers who process personal data on our behalf and under our instruction. These include: identity verification and KYC providers, payment processors (including GCash, PayMaya, BDO, BPI, and other banking partners), cloud hosting and data storage providers, customer support platform providers, and fraud detection and cybersecurity vendors. All third-party processors are bound by data processing agreements requiring them to handle your data in accordance with applicable Philippine data protection law.

7.2 Regulatory and Law Enforcement Authorities

jl365a may disclose your personal data to Philippine government authorities, regulatory bodies, or law enforcement agencies where required by applicable law, court order, or regulatory directive. This includes mandatory disclosures under the Anti-Money Laundering Act (AMLA) as amended, and disclosures to the AMLC (Anti-Money Laundering Council), NPC (National Privacy Commission), and other relevant bodies.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a portion of jl365a's business assets, personal data held by jl365a may be transferred to the successor entity. You will be notified of any such transfer and of any material change to this Policy that may result from the transaction.

8 International Data Transfers

Some of the third-party service providers engaged by jl365a may be located outside the Republic of the Philippines, in which case your personal data may be transferred to and processed in another jurisdiction. Where such transfers occur, jl365a ensures that appropriate safeguards are in place to protect your data to a standard consistent with the Data Privacy Act of 2012, including the use of data transfer agreements incorporating the standard contractual clauses recognised by the National Privacy Commission.

By using the jl365a Platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside the Philippines where such transfers are necessary for the operation of the Platform, subject to the safeguards described above.

9 Data Retention

jl365a retains your personal data for as long as necessary to fulfil the purposes for which it was collected, or for such longer period as is required or permitted by applicable law. In practice, this means:

• Account and identity data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in accordance with AML retention requirements under Philippine law.
• Transaction and financial data: Retained for a minimum of five (5) years following each transaction, or for such longer period as required by applicable tax, AML, or regulatory obligations.
• Gaming activity data: Retained for a minimum of two (2) years following each gaming session for dispute resolution, fraud detection, and responsible gaming monitoring purposes.
• Customer support records: Retained for a minimum of two (2) years following resolution of the relevant support interaction.
• Technical and access logs: Retained for a maximum of twelve (12) months unless required for ongoing fraud investigation or legal proceedings.
• Marketing communications data: Retained until you withdraw consent, after which it will be deleted within thirty (30) days.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with jl365a's data disposal procedures.

10 Security Measures

jl365a implements a comprehensive range of technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jl365a Platform
• Encryption of sensitive data fields at rest, including payment method references and government ID numbers
• Password hashing using industry-standard cryptographic algorithms — your plaintext password is never stored
• Multi-factor authentication options available for all Player accounts
• Role-based access controls limiting internal access to personal data to authorised personnel only, on a need-to-know basis
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure
• Automated systems for detecting and alerting on suspicious login attempts, unusual transaction patterns, and potential data breach indicators

Notwithstanding the above measures, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to adversely affect your rights and freedoms, jl365a will notify you and the National Privacy Commission within the timeframes required under applicable Philippine law.

11 Cookies & Tracking Technologies

jl365a uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain your session state, analyse Platform usage, and support fraud prevention. The categories of cookies used include:

• Strictly necessary cookies: Required for the Platform to function. These cannot be disabled without preventing you from using core features such as logging in and accessing your account.
• Functional cookies: Used to remember your preferences and settings, such as language selection and display preferences, to personalise your experience.
• Analytics cookies: Used to collect anonymised or aggregated information about how Players use the Platform, helping us identify and improve underperforming features.
• Security cookies: Used to detect and prevent fraudulent login attempts, bot activity, and other security threats.

You may control the use of non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality and performance of the jl365a Platform. Strictly necessary and security cookies cannot be disabled.

12 Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by jl365a:

1. Right to be informed: The right to receive clear and accessible information about how jl365a processes your personal data, as set out in this Policy.
2. Right of access: The right to request a copy of the personal data jl365a holds about you and information about how it is being processed.
3. Right to rectification: The right to request correction of inaccurate or incomplete personal data held by jl365a.
4. 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 jl365a's legal retention obligations.
5. Right to object: The right to object to the processing of your personal data on the ground of legitimate interests or for direct marketing purposes.
6. Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller, where technically feasible.
7. Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact jl365a's Data Protection Officer using the contact details in Section 16. jl365a will acknowledge your request within three (3) business days and respond substantively within fifteen (15) business days. In complex cases, this period may be extended by a further fifteen (15) business days with notification to you.

13 Children and Minors

The jl365a Platform is strictly intended for use by individuals who are twenty-one (21) years of age or older. jl365a does not knowingly collect personal data from any person under the age of 21. Age verification is a mandatory component of the jl365a KYC process, and accounts found to be operated by individuals under the minimum age requirement will be immediately closed.

If jl365a becomes aware that personal data of a minor has been collected, that data will be deleted as soon as reasonably practicable, and the relevant account will be suspended pending investigation. If you have reason to believe that a minor has accessed the jl365a Platform or provided personal data, please contact our support team immediately at the address provided in Section 16.

14 Third-Party Websites

The jl365a Platform may contain references to third-party services such as payment providers (GCash, PayMaya, BDO, BPI). When you interact with third-party services, including when you initiate a payment through a third-party e-wallet or banking platform, your use of that service is governed by the privacy policy of the relevant third party. jl365a has no control over, and accepts no responsibility for, the privacy practices or content of any third-party services.

15 Changes to This Policy

jl365a reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. The date of the most recent revision is displayed at the top of this document. Where changes are material — meaning they significantly affect your rights or how your data is used — jl365a will notify you by posting a prominent notice on the Platform or by sending a notification to the email address associated with your jl365a account, prior to the changes taking effect.

Your continued use of the jl365a Platform following notification of any amendments constitutes your acknowledgement of and agreement to the updated Privacy Policy. If you do not accept the revised Policy, you should cease using the Platform and may request account closure in accordance with the Terms and Conditions.

16 Contact & Data Protection Officer

For any questions, concerns, or requests regarding this Privacy Policy, the processing of your personal data, or the exercise of your data subject rights, please contact jl365a's designated Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your rights under the Data Privacy Act of 2012 have been violated. Information on how to contact the NPC and submit a complaint can be found through the NPC's official channels.