jl111 Privacy Policy — How We Handle Your Personal Information

1. Scope & Application

This Privacy Policy ("Policy") applies to all personal information collected, processed, stored, and used by jl111 ("jl111," "we," "us," "our") in connection with the operation of the jl111 online casino and sports betting platform, accessible at jl111.cam ("the Platform"). It applies to all registered account holders, visitors to jl111.cam, and any individual whose personal data is processed by jl111 in the course of providing its services to Filipino players.

This Policy governs personal data processed through all channels associated with jl111, including but not limited to: the jl111.cam website, the account registration and verification process, the cashier and transaction systems, customer support interactions, promotional communications, and loyalty program administration.

This Policy is to be read in conjunction with jl111's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference.

2. Data Controller Information

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, the data controller responsible for your personal information is jl111, operating the platform at jl111.cam.

All data subject requests, privacy concerns, and inquiries regarding the processing of your personal information should be directed to jl111 through the contact channels described in Section 15 of this Policy. jl111 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection obligations.

3. Personal Data We Collect

jl111 collects different categories of personal data depending on the nature of your interaction with the Platform. The following table summarizes the categories of personal data we process:

jl111 does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly necessary for identity verification and regulatory compliance purposes. Where sensitive personal information is collected, it is processed in accordance with the heightened protection requirements prescribed by applicable law.

4. How We Collect Your Data

jl111 collects personal data through the following channels and mechanisms:

4.1 Directly from You

• Account registration: When you create a jl111 account, you provide identity and contact information directly through the registration form;
• KYC verification: When you submit identity documents in response to verification requests;
• Cashier transactions: When you initiate deposits or withdrawals, payment method details are processed;
• Customer support: When you contact jl111 via live chat or email, communications and identifying information are recorded;
• Promotions and surveys: When you participate in jl111 promotional activities or respond to player surveys.

4.2 Automatically During Platform Use

• Cookies and similar technologies: Session identifiers, preference cookies, and analytics cookies are placed on your device when you visit jl111.cam (see Section 8);
• Log data: Web server logs automatically record IP addresses, browser types, referring URLs, and page visit timestamps;
• Game system records: All wagers, game outcomes, session durations, and account activity are logged automatically by platform systems.

4.3 From Third Parties

• Identity verification providers: jl111 may use third-party KYC services to cross-reference identity information provided during registration;
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors share transaction reference data necessary to reconcile deposits and withdrawals;
• Fraud and AML screening services: jl111 may receive risk flags or screening results from third-party compliance service providers.

5. Purposes & Legal Bases for Processing

jl111 processes personal data only where a lawful basis for processing exists under applicable Philippine data protection law. The following table summarizes our primary processing purposes and their corresponding legal bases:

Where processing is based on consent — primarily for marketing communications — you may withdraw that consent at any time by updating your account communication preferences or by contacting jl111 support. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

6. Disclosure to Third Parties

jl111 does not sell your personal data. We may disclose your personal information to the following categories of third parties only where necessary and in accordance with this Privacy Policy:

6.1 Service Providers & Processors

jl111 engages third-party service providers who process personal data on our behalf under binding data processing agreements. These include payment processors (GCash/PayMaya/banks), cloud hosting providers, identity verification services, KYC platform vendors, fraud screening services, and customer support infrastructure providers. These parties are contractually prohibited from using your data for any purpose beyond providing services to jl111.

6.2 Game Providers

Third-party game studios integrated into the jl111 platform may receive certain technical and account identifiers necessary to deliver game content and record wager outcomes. The transmission of data to game providers is limited to what is strictly necessary for game operation and is governed by data processing agreements with each provider.

6.3 Regulatory & Law Enforcement Authorities

jl111 may disclose personal data to regulatory bodies, law enforcement agencies, or other government authorities where required by applicable Philippine law, court order, or binding regulatory direction. jl111 will notify affected account holders of such disclosures where legally permitted to do so.

6.4 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets involving jl111, personal data held by jl111 may be transferred to the acquiring or successor entity. Affected players will be notified of such transfers and of any changes to the applicable privacy policy that result.

7. International Data Transfers

Some of jl111's service providers and infrastructure components may be located outside the Philippines. Where your personal data is transferred to recipients in other jurisdictions, jl111 ensures that appropriate safeguards are in place to maintain an adequate level of data protection. Such safeguards may include standard contractual clauses, binding corporate rules, or transfers to jurisdictions recognized as providing an adequate level of data protection under applicable Philippine law.

By using the jl111 platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines where data protection laws may differ from those applicable in the Philippines. jl111 takes reasonable steps to ensure that such transfers are conducted in compliance with applicable legal requirements.

8. Cookies & Tracking Technologies

jl111 uses cookies and similar tracking technologies when you access jl111.cam. A cookie is a small text file placed on your device by a web server. The following categories of cookies are used by jl111:

jl111 does not use advertising cookies, cross-site tracking cookies, or social media pixel technologies. You may configure your browser to refuse cookies; however, doing so may impair your ability to log in to and use the jl111 platform. Most browsers provide controls for managing cookie settings in their privacy or security preferences section.

9. Data Security

jl111 implements a layered security architecture to protect your personal and financial data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• 256-bit SSL/TLS encryption on all data in transit between your browser and jl111 servers;
• Encryption at rest for sensitive personal data and KYC documents stored on jl111 infrastructure;
• Access controls limiting internal access to personal data on a strict need-to-know basis, with all internal access logged;
• Two-factor authentication available for all player accounts and mandatory for jl111 internal systems;
• Regular security assessments and penetration testing of jl111 platform infrastructure;
• Intrusion detection systems monitoring for suspicious activity in real time;
• Staff data protection training and confidentiality obligations binding all personnel with access to personal data.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl111 will notify the National Privacy Commission (NPC) and affected data subjects in accordance with the breach notification requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

10. Data Retention

jl111 retains personal data for the minimum period necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention principles apply:

• Account data and transaction records are retained for a minimum of five (5) years from the date of account closure, in compliance with anti-money laundering recordkeeping requirements;
• KYC documents are retained for a minimum of five years from the completion of the relevant transaction or the closure of the account, whichever is later;
• Customer support communications are retained for up to three years to assist with dispute resolution and quality assurance;
• Technical and usage data (including log files) is retained for up to 24 months before being deleted or anonymized;
• Marketing preferences and consent records are retained for the duration of your account and for up to three years after account closure to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be associated with an identifiable individual. Where complete deletion is not immediately feasible due to backup retention schedules, data is isolated and protected until it can be permanently deleted.

11. Your Rights as a Data Subject

As a data subject under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by jl111:

11.1 Right to be Informed

You have the right to be informed of the manner in which your personal data is processed by jl111. This Privacy Policy constitutes jl111's primary disclosure of processing practices to data subjects.

11.2 Right of Access

You have the right to request a copy of the personal data jl111 holds about you, together with information about how that data is being processed. Access requests can be submitted through jl111 support as described in Section 15.

11.3 Right to Rectification

You have the right to request that inaccurate or incomplete personal data held by jl111 be corrected. Some account details can be updated directly within your account settings. For changes to core identity information, a formal rectification request and supporting documentation may be required.

11.4 Right to Erasure

You have the right to request the deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected, or where processing was based on consent that has since been withdrawn. This right is subject to jl111's legal obligations to retain certain data as described in Section 10. Erasure requests will be assessed individually and jl111 will communicate the outcome within 30 calendar days.

11.5 Right to Object

You have the right to object to the processing of your personal data where that processing is based on jl111's legitimate interests. jl111 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, or where processing is necessary for the establishment, exercise, or defense of legal claims.

11.6 Right to Data Portability

Where technically feasible and applicable, you have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.

11.7 Right to Lodge a Complaint

If you believe jl111 has processed your personal data in a manner that violates the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Contact details for the NPC are publicly available on the NPC's official website.

12. Children & Minors

jl111 does not knowingly collect personal data from individuals under the age of 21 years, consistent with the minimum age requirements for casino-style gambling in the Philippines. The jl111 platform is strictly intended for adults aged 21 and above residing in the Philippines.

If jl111 becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. Any balances held in accounts found to belong to underage individuals will be returned through the original deposit method where practicable, net of any amounts jl111 is legally entitled to retain.

If you believe that a minor has registered or is using a jl111 account, please contact jl111 support immediately so the matter can be investigated and addressed promptly.

13. Responsible Gaming & Data

jl111 processes certain usage and behavioral data specifically for the purpose of monitoring player wellbeing and fulfilling its responsible gaming obligations. This processing includes:

• Monitoring deposit frequency and volume against self-imposed limits set by the player;
• Tracking session duration against session time reminder settings;
• Identifying patterns that may indicate at-risk gaming behavior for the purpose of responsible gaming interventions;
• Recording self-exclusion requests and maintaining exclusion lists to prevent re-registration during an active exclusion period;
• Storing player-selected responsible gaming preferences (deposit limits, loss limits, session reminders) as part of the account record.

Responsible gaming data is processed under the legal basis of legitimate interest and legal obligation. This processing is not used for marketing purposes and is not disclosed to third parties except where required by regulatory obligations. For full details of the responsible gaming tools available on jl111, please visit our Responsible Gaming page.

14. Changes to This Privacy Policy

jl111 reserves the right to amend this Privacy Policy at any time to reflect changes in our processing practices, applicable law, or platform functionality. Material changes — meaning changes that significantly affect how jl111 processes your personal data or that reduce your rights as a data subject — will be communicated to registered players via email to the address on file or via a prominent notice on jl111.cam before the changes take effect.

Minor or clarificatory changes may be made without separate notification, and will be reflected in the "Last updated" date at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how jl111 handles your personal information. Your continued use of the jl111 platform after an amended Privacy Policy takes effect constitutes your acceptance of the revised Policy.

15. How to Contact Us

For all data protection enquiries — including data subject rights requests, privacy complaints, questions about this Policy, or notifications of suspected security incidents — you may contact jl111 through the following channels:

jl111 aims to acknowledge all data subject requests and privacy complaints within five (5) business days and to provide a full substantive response within 30 calendar days of receipt. Where a request is particularly complex or involves a large volume of data, jl111 may extend this period by a further 30 days, in which case we will notify you of the extension and the reasons for it within the initial 30-day response window.

For complaints that cannot be resolved satisfactorily through jl111's internal process, you retain the right to escalate your complaint to the National Privacy Commission of the Philippines, the supervisory authority responsible for data protection enforcement in the Philippines.