Privacy Policy – jl90 Casino

1. Introduction

jl90 Casino (hereinafter "jl90", "we", "us", "our") operates the online gaming platform accessible at jl90.win. We are committed to protecting the privacy and personal data of every player and visitor who interacts with the Platform in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission (NPC) and the Philippine Amusement and Gaming Corporation (PAGCOR).

This Privacy Policy (hereinafter "Policy") describes in detail how jl90 processes personal data — what data we collect, for what purposes, on what legal bases, how long we retain it, who we share it with, and what rights you hold as a data subject. By registering an account or otherwise using the jl90 platform, you acknowledge that you have read, understood, and accepted this Policy.

2. Data Controller Identity

The data controller responsible for the personal data processed on the jl90 platform is jl90 Casino, the operator of jl90.win, operating under the Philippine Amusement and Gaming Corporation's regulatory framework.

For all data privacy inquiries, requests to exercise data subject rights, and complaints, players may contact jl90's Data Protection Officer (DPO) using the contact details set out in Section 15 of this Policy.

3. Personal Data We Collect

jl90 collects personal data that is necessary and proportionate to the purposes described in this Policy. The categories of personal data we process include the following:

3.1 Identity and Registration Data

• Full legal name as it appears on your Philippine government-issued identification;
• Date of birth (for mandatory 21+ age verification);
• Residential address in the Philippines;
• Philippine mobile number;
• Email address;
• Username and encrypted account password;
• Nationality and citizenship information where required for compliance.

3.2 Identity Verification (KYC) Data

• Scanned or photographed copies of valid Philippine government-issued photo identification (e.g., PhilSys ID, passport, driver's license, SSS ID, GSIS ID, PRC ID, Voter's ID, or UMID card);
• Proof of residential address documents (e.g., utility bills, bank statements, barangay certificates);
• Proof of payment method ownership (e.g., GCash account screenshot confirming registered mobile number);
• Selfie photographs or video verification captures where required by our compliance team;
• Source of funds declarations where required by AML protocols.

3.3 Financial and Transaction Data

• Deposit transaction records — amounts, timestamps, payment method used (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard);
• Withdrawal requests and processing records;
• Account balance history;
• Bonus and promotional credit records;
• GCash registered mobile number and PayMaya account details used for transactions;
• Bank account details (bank name, account number) where bank transfers are used.

3.4 Gaming Activity Data

• Game session records — games played, wager amounts, outcomes, session durations;
• Sports betting history — events wagered on, bet types, stakes, results;
• VIP tier status, loyalty points accumulation, and tier progression history;
• Responsible gaming tool usage — deposit limits set, self-exclusion activations, cool-down periods.

3.5 Technical and Usage Data

• IP address at time of login and gameplay sessions;
• Device type, operating system, and browser version;
• Geolocation data (country/region level) where technically available;
• Login timestamps, session durations, and logout events;
• Pages visited and navigation patterns within the Platform;
• Cookies and similar tracking technology data (see Section 8).

3.6 Communications Data

• Live chat transcripts with jl90 support agents;
• Email correspondence with the jl90 support and compliance teams;
• Records of responsible gaming tool requests and account management instructions.

4. How We Collect Personal Data

jl90 collects personal data through the following channels:

5. Purpose & Legal Basis for Processing

jl90 processes personal data only for specific, legitimate purposes, each supported by an appropriate legal basis under RA 10173:

5.1 Account Management and Service Delivery — Processing necessary for the performance of the contract between jl90 and the registered player. This covers account creation, login authentication, game access, deposit and withdrawal processing, support services, and VIP program management.

5.2 Identity Verification and Age Confirmation — Processing necessary for compliance with PAGCOR's KYC requirements and jl90's legal obligation to verify that all players are 21 years of age or older. This is a non-negotiable legal obligation under Philippine gaming regulations.

5.3 Anti-Money Laundering (AML) Compliance — Processing required by applicable Philippine AML law (Republic Act No. 9160 as amended, and PAGCOR AML directives). jl90 is required to monitor transactions for suspicious activity, conduct enhanced due diligence on high-risk accounts, and report qualifying transactions to the Anti-Money Laundering Council (AMLC).

5.4 Responsible Gaming Monitoring — Processing conducted in jl90's legitimate interests and in compliance with PAGCOR responsible gaming obligations to identify players who may be at risk of problem gambling and to implement appropriate protective measures.

5.5 Fraud Prevention and Platform Security — Processing in jl90's legitimate interests to detect, investigate, and prevent fraud, account compromises, duplicate account creation, unauthorized access, and other harmful activities on the Platform.

5.6 Marketing and Promotions — Where you have provided your consent to receive marketing communications, jl90 will use your contact details to send information about jl90 promotions, bonuses, and VIP program updates. You may withdraw this consent at any time (see Section 13).

5.7 Legal Claims and Dispute Resolution — Processing necessary for the establishment, exercise, or defense of legal claims, including account disputes, regulatory investigations, and court proceedings.

6. Data Retention

6.1 jl90 retains personal data for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal, regulatory, and PAGCOR obligations.

6.2 Active Account Data: Retained for the duration of your account's existence on the jl90 Platform.

6.3 Post-Closure Retention: Following voluntary or involuntary account closure, jl90 is required under PAGCOR and Philippine AML law to retain KYC records, transaction records, and gaming history for a minimum period of five (5) years from the date of closure or the date of the last transaction, whichever is later.

6.4 Marketing Data: Retained until you withdraw your consent to marketing communications, after which your contact details are removed from active marketing lists within thirty (30) days.

6.5 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be attributed to any identifiable individual.

7. Sharing & Disclosure of Personal Data

jl90 does not sell, rent, or commercially trade your personal data to third parties. Disclosure of personal data is limited to the following categories of recipients and circumstances:

• PAGCOR and Regulatory Authorities: jl90 is obligated to disclose player data to PAGCOR upon request as part of its licensed operating obligations, including during regulatory audits and investigations.
• Anti-Money Laundering Council (AMLC): Qualifying transactions and suspicious activity reports are submitted to the AMLC as required by Philippine AML law.
• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, Visa/Mastercard, and InstaPay/PESONet network operators receive the minimum personal data necessary to process deposits and withdrawals on your behalf.
• KYC and Identity Verification Partners: Third-party identity verification service providers receive document scans and identity data solely for the purpose of conducting verification checks on jl90's behalf. All such partners are contractually bound to process data only as directed by jl90 and to maintain equivalent data protection standards.
• Game Technology Providers: Software providers whose games are hosted on the jl90 platform (including RNG certification auditors) may receive anonymized or aggregate gaming data required for technical purposes. No personally identifiable data is shared with game providers beyond what is technically necessary for game delivery.
• Law Enforcement and Courts: jl90 will disclose personal data to Philippine law enforcement authorities, courts, or other government bodies when required to do so by law, court order, or binding regulatory directive.
• Professional Advisors: Legal counsel, auditors, and accountants engaged by jl90 may access personal data as necessary for the provision of their professional services, subject to legal professional privilege and confidentiality obligations.

8. Cookies & Tracking Technologies

8.1 jl90 uses cookies and similar tracking technologies on the jl90.win website to support essential platform functionality, analyze usage patterns, and improve the player experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies: Used to collect aggregate, anonymized data about how players navigate jl90.win — which pages are visited most frequently, average session durations, and error occurrences. This data helps jl90 improve the Platform.
• Functionality Cookies: Remember your preferences — such as language settings and preferred login method — to personalize your experience on return visits.
• Security Cookies: Support jl90's fraud detection and account security systems by recording login device fingerprints and identifying anomalous access patterns.

8.2 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform. Instructions for managing cookies in major browsers (Chrome, Safari, Firefox) are available in each browser's help documentation.

9. Data Security Measures

jl90 implements technical and organizational security measures proportionate to the sensitivity of the personal data it processes. These measures include, but are not limited to:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and jl90.win is encrypted using industry-standard 256-bit SSL/TLS. This applies to login, gameplay, cashier transactions, and support sessions.
• Password Hashing: Account passwords are stored using strong one-way cryptographic hashing algorithms. jl90 personnel cannot read your password in plain text.
• Two-Factor Authentication (2FA): Available to all players and strongly recommended. 2FA significantly reduces the risk of unauthorized account access.
• Access Controls: Access to personal data within jl90's internal systems is limited on a strict need-to-know basis. Staff with data access receive data privacy training and are bound by confidentiality obligations.
• Intrusion Detection and Monitoring: jl90's platform is monitored continuously for unauthorized access attempts, anomalous login patterns, and security incidents.
• Incident Response: In the event of a personal data breach affecting Philippine residents, jl90 will comply with the NPC's mandatory breach notification requirements within the prescribed timeframe.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl90:

• Right to be Informed: The right to know what personal data jl90 processes about you, for what purposes, and on what legal basis — as set out in this Policy.
• Right of Access: The right to request a copy of the personal data jl90 holds about you, together with information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held in your jl90 account.
• Right to Erasure (Right to Be Forgotten): The right to request deletion of your personal data, subject to jl90's legal and regulatory retention obligations. Where jl90 is required to retain data by PAGCOR or AML law, erasure requests cannot be fully honored during the mandatory retention period.
• Right to Object: The right to object to processing based on legitimate interests, including direct marketing processing. Objection to marketing communications will be acted upon immediately.
• Right to Data Portability: The right to receive a structured, machine-readable copy of personal data you have provided to jl90, where technically feasible.
• Right to Damages: The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, or unlawfully obtained personal data, in accordance with RA 10173.
• Right to Complain: The right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe jl90 has violated your data privacy rights.

To exercise any of these rights, submit your request in writing to the jl90 Data Protection Officer using the contact details in Section 15. jl90 will respond to data subject rights requests within fifteen (15) business days of receipt.

11. Minors and Age Restriction

The jl90 platform is strictly prohibited to persons under the age of 21 years in accordance with PAGCOR regulations. jl90 does not knowingly collect personal data from individuals under 21. If jl90 discovers that personal data has been collected from a person under 21 years of age, the account will be immediately closed, all associated data will be reviewed by the compliance team, and any funds held will be dealt with in accordance with PAGCOR's underage gambling protocols.

If you are a parent or guardian and believe that a person under 21 in your household has created a jl90 account, please contact jl90 immediately at [email protected] so that the account can be investigated and closed.

12. International Data Transfers

jl90 is a Philippine-market platform and its primary data processing operations are conducted within the Philippines. Where personal data is transferred to third-party service providers whose operations involve processing outside the Philippines — for example, cloud infrastructure providers or international KYC verification partners — jl90 ensures that such transfers comply with the cross-border data transfer provisions of RA 10173. This includes ensuring that the recipient jurisdiction provides an adequate level of data protection or that appropriate contractual safeguards are in place.

13. Marketing Communications

13.1 Where you have provided consent during registration or through your account settings, jl90 may send you marketing communications about promotions, bonuses, new game releases, VIP tier updates, and other jl90 offers via email and/or SMS to your registered Philippine mobile number.

13.2 You may withdraw your consent to marketing communications at any time by adjusting your notification preferences in your jl90 account settings or by contacting support. Withdrawal of marketing consent does not affect the lawfulness of processing conducted prior to the withdrawal.

13.3 Withdrawal of marketing consent does not affect your ability to use the jl90 Platform or access your account. Service communications — such as transaction confirmations, KYC notifications, responsible gaming alerts, and account security notices — are not marketing communications and will continue to be sent regardless of marketing preferences.

14. Changes to This Privacy Policy

jl90 reserves the right to update or modify this Privacy Policy at any time. Material changes will be communicated to registered players via email notification to the address on file and/or a prominent notice on jl90.win, at least seven (7) calendar days before the changes take effect — unless changes are required by applicable law or NPC/PAGCOR directive, in which case they may take effect immediately. The effective date at the top of this Policy will be updated to reflect all revisions. Continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

15. Contact & Data Protection Officer

For all data privacy inquiries, requests to exercise data subject rights, or concerns about jl90's data processing practices, you may contact the jl90 Data Protection Officer through the following channels:

• DPO Email: [email protected] — please include "Data Privacy Request" in the subject line for prioritized handling.
• Live Chat: Available 24/7 via the in-platform chat button. For formal data subject rights requests, email is preferred to ensure a documented record.
• FAQ: Common data privacy questions are addressed at the jl90 FAQ page.

If you are not satisfied with jl90's response to a data privacy request or complaint, you have the right to escalate your complaint to the Philippine National Privacy Commission (NPC). Information on the NPC's complaint process is available on the NPC's official website.