Privacy Policy

1. About This Policy

This Privacy Policy applies to all personal data collected by jll33 through the jll33 website (jll33.com), the jll33 mobile application, and any related services, communications, or interactions between you and jll33. It applies to all registered account holders and to visitors who access the jll33 platform without registering.

jll33 operates as an online gaming platform serving players in the Philippines. As an operator subject to Philippine law, jll33 is required to comply with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations. This Privacy Policy is drafted in accordance with those requirements.

By registering an account on jll33 or by continuing to use the jll33 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 to this Privacy Policy, you must not register an account or use the jll33 platform.

This Privacy Policy should be read together with jll33's Terms and Conditions, which are available at jll33.com/terms-conditions and are incorporated herein by reference.

2. Data We Collect

jll33 collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we collect include the following:

2.1 Identity Data

• Full legal name as it appears on your government-issued identification document.
• Date of birth (used to verify that you meet the 21+ age requirement).
• Nationality and country of residence.
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence, SSS, GSIS, or PhilHealth number).
• Photographs or scanned copies of identity documents submitted during the KYC verification process.

2.2 Contact Data

• Email address registered to your jll33 account.
• Mobile phone number registered to your jll33 account.
• Residential address, including barangay, city or municipality, province, and postal code.

2.3 Financial Data

• GCash or PayMaya mobile wallet number linked to your account.
• Bank account details (account name, account number, bank name) for BPI, BDO, Metrobank, or other supported banks where bank transfer is used.
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references.

2.4 Gaming Data

• Game session history, including games played, wagers placed, outcomes, and session duration.
• Account balance history and bonus transaction records.
• Responsible gaming settings, including any deposit limits, session limits, or self-exclusion periods you have set.

2.5 Technical Data

• IP address and approximate geolocation at the time of login and during active sessions.
• Device type, operating system, browser type and version.
• Unique device identifiers.
• Log data, including access times, pages visited, and error reports.

2.6 Communications Data

• Records of communications between you and jll33 customer support, including chat transcripts and email correspondence.
• Survey responses and feedback submitted through the jll33 platform.

3. How We Collect Data

jll33 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or responding to a survey.
• Automated collection: Technical data collected automatically when you access the jll33 website or mobile application, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data received from third-party KYC service providers engaged by jll33 to verify the accuracy of the information you have provided. Payment data received from payment processors (GCash, PayMaya, BPI, BDO, Metrobank, and others) in connection with your transactions on jll33.
• Regulatory sources: Data received from PAGCOR or other regulatory authorities in connection with jll33's compliance obligations, including self-exclusion register data.

4. How We Use Your Data

jll33 uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your jll33 account, including processing your registration, verifying your identity, and managing your account settings.
• Service delivery: To provide you with access to jll33's games, process your deposits and withdrawals, credit bonuses, and deliver customer support.
• Legal compliance: To comply with jll33's obligations under Philippine law, including anti-money laundering (AML) regulations, PAGCOR licensing requirements, and the Data Privacy Act of 2012. This includes conducting KYC verification, monitoring transactions for suspicious activity, and reporting to regulatory authorities as required.
• Responsible gaming: To enforce the 21+ age requirement, apply responsible gaming limits and self-exclusion orders, and monitor gaming behaviour for indicators of problem gambling.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other security threats to the jll33 platform.
• Platform improvement: To analyse usage patterns, diagnose technical issues, and improve the performance and features of the jll33 platform.
• Communications: To send you transactional communications related to your account (e.g., deposit confirmations, withdrawal notifications, security alerts). jll33 will only send promotional communications where you have provided explicit consent, and you may withdraw that consent at any time through your account settings.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, jll33 processes your personal data on the following legal bases:

• Contractual necessity: Processing that is necessary to perform the contract between you and jll33 — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Processing that is required to comply with jll33's obligations under Philippine law, including AML regulations, PAGCOR requirements, and tax reporting obligations.
• Legitimate interests: Processing that is necessary for jll33's legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided that those interests are not overridden by your rights and interests. This includes fraud prevention, security monitoring, and platform analytics.
• Consent: Processing based on your explicit consent, such as the sending of promotional communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Data

jll33 does not share your personal data with third parties except in the following circumstances:

6.1 Service Providers

jll33 engages third-party service providers to assist in operating the platform, including KYC verification providers, payment processors, cloud hosting providers, and customer support technology providers. These service providers are permitted to process your personal data only as necessary to perform their services for jll33, and are contractually required to maintain appropriate data security standards and to process your data only in accordance with jll33's instructions.

6.2 Regulatory Authorities

jll33 is required by law to disclose certain player data to PAGCOR and other Philippine regulatory or law enforcement authorities upon lawful request. Such disclosures are made strictly in accordance with jll33's legal obligations and do not require your prior consent.

6.3 Financial Institutions

jll33 shares transaction data with payment processors and financial institutions (including GCash, PayMaya, BPI, BDO, and Metrobank) to the extent necessary to process your deposits and withdrawals. These institutions are subject to their own privacy and data security obligations under Philippine law.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of jll33's assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material changes to this Privacy Policy that result from it.

6.5 Legal Proceedings

jll33 may disclose your personal data where required to do so by a court order, subpoena, or other legal process, or where jll33 believes in good faith that disclosure is necessary to protect the rights, property, or safety of jll33, its players, or the public.

7. Data Retention

jll33 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for a minimum of five years from the date of account closure, in accordance with PAGCOR requirements and Philippine AML regulations.
• Transaction and financial data: Retained for a minimum of five years from the date of each transaction, in accordance with applicable financial record-keeping requirements.
• Gaming session data: Retained for a minimum of three years from the date of each session.
• Customer support communications: Retained for a minimum of two years from the date of the communication.
• Technical and log data: Retained for a maximum of 12 months from the date of collection, unless retention for a longer period is required for security investigation or legal proceedings.

Upon expiry of the applicable retention period, jll33 will securely delete or anonymise your personal data in accordance with its data disposal procedures, unless retention for a longer period is required by law or is necessary for the establishment, exercise, or defence of legal claims.

8. Data Security

jll33 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption of data in transit using industry-standard TLS protocols.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Access controls limiting access to personal data to authorised jll33 personnel and service providers on a need-to-know basis.
• Regular security assessments and penetration testing of jll33's platform infrastructure.
• Multi-factor authentication requirements for access to jll33's internal systems.
• Incident response procedures for the detection, investigation, and notification of personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jll33 will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

9. Cookies & Tracking

jll33 uses cookies and similar tracking technologies on its website and mobile application. Cookies are small text files stored on your device that help jll33 recognise you, remember your preferences, and understand how you use the platform.

9.1 Types of Cookies Used

• Strictly necessary cookies: Required for the jll33 platform to function. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting your ability to use the platform.
• Functional cookies: Used to remember your preferences, such as your preferred language and display settings. These improve your experience but are not essential to platform operation.
• Analytics cookies: Used to collect anonymised data about how players use the jll33 platform, including which pages are visited most frequently and where errors occur. This data is used to improve platform performance and user experience.

9.2 Managing Cookies

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies will affect your ability to log in and use the jll33 platform. Disabling analytics cookies will not affect your ability to use the platform but will limit jll33's ability to improve its services based on usage data.

10. Your Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jll33:

• Right to be informed: The right to be informed of how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data jll33 holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data jll33 holds about you.
• 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 jll33's legal retention obligations.
• Right to object: The right to object to the processing of your personal data where that processing is based on jll33's legitimate interests, including the right to object to the use of your data for direct marketing purposes.
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that jll33 transmit that data to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jll33 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, please contact jll33's Data Protection Officer using the contact details provided in Section 14 of this Privacy Policy. jll33 will respond to all data rights requests within 15 business days of receipt. jll33 may request proof of identity before processing a data rights request to ensure that personal data is not disclosed to an unauthorised person.

11. Children's Privacy

The jll33 platform is strictly intended for adults aged 21 years and above. jll33 does not knowingly collect personal data from any person under the age of 21. The 21+ age requirement is enforced through identity verification during the account registration process.

If jll33 becomes aware that personal data has been collected from a person under the age of 21, jll33 will immediately close the associated account, delete the personal data collected, and return any funds deposited to the payment source used, subject to verification. If you believe that a person under 21 has registered an account on jll33, please contact jll33 support immediately.

12. Cross-Border Data Transfers

jll33 primarily processes and stores personal data within the Philippines. Where jll33 engages service providers that process data outside the Philippines — for example, cloud infrastructure providers with data centres in other countries — jll33 ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012.

Such safeguards may include contractual data processing agreements that require the recipient to maintain data protection standards equivalent to those required under Philippine law. jll33 will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

13. Changes to This Policy

jll33 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes to this Privacy Policy will be communicated to registered players via the email address on file or through a prominent notice on the jll33 platform at least seven days before the changes take effect.

The effective date at the top of this Privacy Policy will be updated each time a new version is published. Your continued use of the jll33 platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree to the updated Privacy Policy, you must cease using the platform and may request account closure in accordance with jll33's Terms and Conditions.

14. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or wish to contact jll33's Data Protection Officer, please use the following contact details:

Data Protection Officer — jll33

Email: [email protected]

General Support Email: [email protected]

jll33's Data Protection Officer will acknowledge all privacy-related enquiries within three business days and will provide a substantive response within 15 business days. Where a request is complex or involves a large volume of data, jll33 may extend this period by a further 15 business days, in which case you will be notified of the extension and the reason for it.

If you are not satisfied with jll33's response to your privacy enquiry, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.