jl199 Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") is published by jl199 ("jl199", "we", "us", "our") and applies to all personal information collected, processed, stored, or otherwise handled in connection with the jl199 online casino platform accessible at jl199.vip and all associated services, features, and communications (collectively, the "Platform").

jl199 is committed to protecting the privacy and personal data of every player, visitor, and user who interacts with our Platform. We recognise that Filipino players trust us with sensitive personal and financial information when they register and play at jl199, and we take that trust seriously. This Policy is designed to be transparent about our data practices so you can make informed decisions about your personal information.

This Policy is to be read together with jl199's Terms and Conditions and Responsible Gaming Policy, both of which are available on the Platform. By accessing or using the jl199 Platform, you acknowledge that you have read, understood, and agreed to this Policy. If you do not agree to the processing of your personal data as described in this Policy, you must not use the jl199 Platform.

2 Definitions

For the purposes of this Policy, the following terms have the meanings set out below:

• "Personal Data" — any information from which an individual can be directly or indirectly identified, including name, mobile number, email address, date of birth, government ID number, payment details, IP address, and device identifiers.
• "Sensitive Personal Information" — personal data as defined under Section 3(l) of RA 10173, including government-issued ID numbers, financial account information, and information that may expose the data subject to discrimination.
• "Data Subject" — the individual to whom personal data relates; in the context of this Policy, primarily jl199 players and registered users.
• "Processing" — any operation performed on personal data, including collection, recording, organisation, storage, alteration, use, disclosure, combination, deletion, or destruction.
• "Personal Information Controller" (PIC) — jl199, which determines the purposes and means of processing personal data collected through the Platform.
• "Personal Information Processor" (PIP) — any third-party service provider that processes personal data on behalf of jl199 under contractual arrangement and instruction.
• "KYC" — Know Your Customer; the identity verification process conducted by jl199 pursuant to its anti-money laundering and regulatory compliance obligations.
• "NPC" — National Privacy Commission of the Philippines; the regulatory authority responsible for administering and enforcing RA 10173.

3 Personal Data We Collect

jl199 collects personal data that is necessary for the operation of the Platform and the provision of the Services. The following table describes the categories of personal data we collect and the primary reason for collection:

4 How We Collect Your Data

jl199 collects personal data through the following methods:

4.1 Direct Collection

Personal data you provide directly to jl199 when you: register an account on the Platform; complete KYC identity verification; make a deposit or withdrawal request; contact jl199 customer support; participate in promotions or surveys; update your account profile; or set responsible gaming preferences.

4.2 Automated Collection

When you visit and use the jl199 Platform, certain technical and usage data is automatically collected by our systems. This includes your IP address, device information, browser data, and behavioural usage data recorded through server logs and analytics systems. This data collection is necessary for platform security, fraud prevention, and service optimisation.

4.3 Third-Party Sources

jl199 may receive personal data about you from the following third-party sources where you have consented to such sharing or where jl199 has a legitimate legal basis for receiving the data: payment processors (GCash, PayMaya, BPI, BDO, Metrobank) for transaction verification; identity verification service providers used to conduct KYC checks; and fraud prevention services used to protect the integrity of the Platform.

5 Purpose & Legal Basis for Processing

jl199 processes personal data only where there is a lawful basis for doing so under the Philippine Data Privacy Act. The following table sets out the purposes for which jl199 processes personal data and the corresponding legal basis under RA 10173:

• Performance of a Contract: Processing necessary to create and manage your jl199 account, process your deposits and withdrawals, and provide you with access to the casino Services you have contracted to use.
• Legal Obligation: Processing required to comply with applicable legal obligations, including KYC identity verification, anti-money laundering record-keeping, age verification, and regulatory reporting requirements.
• Legitimate Interest: Processing for jl199's legitimate business interests, including platform security, fraud detection and prevention, responsible gaming monitoring, system maintenance, and internal analytics — where such interests are not overridden by your data protection rights.
• Consent: Where jl199 processes your personal data for direct marketing communications or optional platform features, we will obtain your explicit consent before doing so. You may withdraw consent at any time by contacting jl199 support or updating your communication preferences in Account Settings.

6 Cookies & Tracking Technologies

The jl199 Platform uses cookies and similar tracking technologies to provide a functional, secure, and personalised experience. A cookie is a small text file placed on your device when you visit the Platform. jl199 uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the jl199 Platform to function. They maintain your login session, remember your wallet state during gameplay, and support Platform security functions. These cookies cannot be disabled without severely impairing your ability to use the Platform.
• Functional Cookies: These cookies remember your preferences, such as your selected language and notification settings, to provide a more personalised experience on the Platform.
• Analytics Cookies: jl199 uses analytics to understand how players use the Platform in aggregate — which game categories are most popular, where players encounter technical issues, and how navigation patterns can be improved. Analytics data is processed at an aggregate, non-identifiable level where possible.
• Security Cookies: These cookies support jl199's fraud detection systems by flagging unusual device or session patterns that may indicate unauthorised access attempts.

You can configure your browser to refuse or delete cookies; however, disabling strictly necessary cookies will impair your ability to log in to and use the jl199 Platform. jl199 does not use third-party advertising or behavioural retargeting cookies.

7 Sharing Your Personal Data

jl199 does not sell your personal data. We do not share your personal data with third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly for the purposes described, and under binding data processing agreements:

• Payment Processors: GCash, PayMaya, BPI, BDO, and Metrobank receive the transaction data necessary to process your deposits and withdrawals. These providers process your data under their own privacy policies and in compliance with Bangko Sentral ng Pilipinas (BSP) regulations.
• Identity Verification Providers: Third-party KYC service providers receive your identity documents and identity data to perform verification checks required for regulatory compliance. These providers are bound by strict data processing agreements with jl199.
• Game Content Providers: Your session and transaction data may be shared with jl199's game providers (such as JILI and live casino studios) to the extent necessary to deliver game services and resolve game-related disputes.
• Fraud and Security Providers: Third-party fraud detection services may receive technical data (IP addresses, device fingerprints) to assist in identifying and preventing fraudulent activity on the Platform.
• Legal and Regulatory Authorities: jl199 will disclose personal data to PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), law enforcement agencies, or courts of competent jurisdiction when required to do so by law, court order, or regulatory directive. jl199 may also disclose data where it has a good-faith belief that disclosure is necessary to protect the rights, safety, or property of jl199, its players, or the public.
• Professional Advisors: jl199's lawyers, auditors, and insurers may access personal data to the extent necessary to provide their professional services to jl199, subject to professional confidentiality obligations.

8 Data Security

jl199 employs comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jl199 servers;
• AES-256 encryption for sensitive personal and financial data at rest in jl199 databases;
• One-way cryptographic hashing of all player passwords — jl199 cannot retrieve your password;
• Multi-factor authentication requirements for privileged system access by jl199 staff;
• Regular third-party penetration testing and security audits of the jl199 platform and infrastructure;
• Role-based access controls ensuring that jl199 staff can only access personal data to the extent required by their specific job function;
• Comprehensive audit logs of all access to personal data by jl199 staff and systems;
• Incident response procedures for detecting, responding to, and notifying affected parties in the event of a personal data breach.

Notwithstanding these measures, no method of electronic transmission or storage is completely secure. jl199 cannot guarantee absolute security of your personal data. In the event of a personal data breach that poses a real risk of serious harm to you, jl199 will notify you and the NPC within the timeframes required under RA 10173 and the NPC's breach notification guidelines.

9 Data Retention

jl199 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and Identity Data: Retained for the lifetime of your jl199 account plus five (5) years after account closure, to comply with anti-money laundering record-keeping requirements under Philippine law and PAGCOR regulations.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification, as required by the Anti-Money Laundering Act (AMLA) of the Philippines, as amended.
• Financial Transaction Records: Retained for five (5) years from the date of each transaction, consistent with AMLA requirements and standard financial record-keeping obligations.
• Game Session Logs: Retained for two (2) years from the date of each session, for dispute resolution and responsible gaming monitoring purposes.
• Technical and Usage Data (Log Files): Retained for ninety (90) days for operational purposes and up to twelve (12) months for security investigation purposes.
• Support Records: Retained for three (3) years from the date of the support interaction, for quality assurance and dispute resolution purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised using methods that prevent recovery. Anonymised aggregate data that cannot be linked to any individual is not subject to these retention limits and may be retained for statistical and product development purposes.

10 Your Data Protection Rights

As a data subject under the Philippine Data Privacy Act, you have the following rights in respect of your personal data held by jl199. To exercise any of these rights, please contact the jl199 Data Protection Officer using the contact details in Section 15.

jl199 will respond to all data subject requests within thirty (30) calendar days of receipt, as required under RA 10173. In complex cases, this period may be extended by a further thirty (30) days with notice to you. jl199 will not charge a fee for processing data subject requests unless they are manifestly unfounded or excessive.

11 Children & Minors

If you are a parent or guardian and believe that your child or ward may have registered on the jl199 Platform, please contact jl199 support immediately via live chat or at [email protected]. jl199 will investigate the matter and take appropriate action, including account suspension and data deletion where confirmed.

12 Cross-Border Data Transfers

The jl199 Platform serves Filipino players, and the primary data processing infrastructure for jl199 is located in the Asia-Pacific region. Some of jl199's third-party service providers — including game content providers and security technology vendors — may be located outside the Philippines.

Where personal data is transferred outside the Philippines, jl199 ensures that appropriate safeguards are in place in compliance with Section 21 of RA 10173 and the NPC's rules on cross-border data flows. These safeguards include contractual clauses that require the recipient to apply data protection standards equivalent to those under Philippine law, and jl199's ongoing due diligence of the security practices of its international service providers.

jl199 does not transfer your personal data to any jurisdiction that lacks adequate data protection standards without first ensuring that appropriate contractual and technical safeguards are in place to protect your information.

13 Third-Party Links

The jl199 Platform does not contain links to third-party websites for advertising or affiliate purposes. To the extent that jl199 integrates with third-party payment processors (GCash, PayMaya, BPI, BDO, Metrobank), those integrations are governed by the respective privacy policies of those providers. jl199 is not responsible for the data practices of third-party payment providers once you are redirected to their payment interfaces to complete a transaction.

jl199 recommends that you review the privacy policies of any third-party service you interact with in connection with using the jl199 Platform.

14 Changes to This Privacy Policy

jl199 may update this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or improvements to our Services. Where changes are material — meaning they substantially alter the way jl199 processes your personal data or the rights available to you — jl199 will provide at least fourteen (14) days' advance notice via the Platform or by direct communication to your registered contact details.

The effective date of the current version of this Policy is displayed at the top of this page. You are encouraged to review this Policy periodically. Your continued use of the jl199 Platform following the publication of an updated Policy constitutes your acceptance of the changes, to the extent permitted by applicable Philippine law.

15 Data Protection Officer

In compliance with Section 21(e) of RA 10173 and NPC Circular No. 16-03, jl199 has designated a Data Protection Officer (DPO) who is responsible for overseeing jl199's compliance with RA 10173 and this Privacy Policy. The DPO serves as the primary point of contact for data subjects wishing to exercise their rights or raise data protection concerns.

To reach jl199's Data Protection Officer, please submit your request in writing to:

• Email: [email protected] — subject line "Data Protection Request" or "DPO Query"
• Live Chat: Available 24/7 on the jl199 Platform — request to be connected to the Data Protection team

jl199's DPO will acknowledge receipt of your request within five (5) business days and provide a substantive response within the statutory timeframe of thirty (30) calendar days, extendable by a further thirty (30) days in complex cases.

16 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or jl199's handling of your personal data, please contact jl199 through the following channels. All communications regarding data privacy matters are treated with priority and strict confidentiality:

• Live Chat: Available 24/7 directly on the jl199 Platform — the fastest channel for privacy-related queries.
• Email: [email protected] — for formal written data privacy requests, complaints, or DPO queries.
• Languages: Privacy requests can be submitted in English or Filipino.

If you are not satisfied with jl199's response to a data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), which is the competent supervisory authority for data protection matters in the Philippines.