jl3win Privacy Policy

1Who We Are and How This Policy Applies

jl3win ("we," "us," "our") is the operator of the online gaming platform accessible at jl3win.cam, operating under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR). For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, jl3win acts as the Personal Information Controller with respect to the personal data of players and visitors to the Platform.

This Privacy Policy applies to all personal data collected from individuals who register an account on the jl3win Platform, visit the Platform as a guest, interact with jl3win's customer support team, receive communications from jl3win, or otherwise provide personal information to jl3win through any channel. By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2Personal Data We Collect

jl3win collects personal data through multiple touchpoints in the course of providing its gaming services. The categories of data collected, their sources, and purposes are set out below.

2.1 Data You Provide Directly

When you register an account, complete KYC verification, contact support, or interact with jl3win's platform features, you may provide:

• Full legal name, date of birth, and gender;
• Philippine mobile number and email address;
• Residential address (including barangay, city or municipality, province, and ZIP code);
• Government-issued identification documents (e.g., Philippine National ID, passport, driver's licence, SSS or UMID card);
• Payment method details necessary for deposit and withdrawal processing (e.g., GCash mobile number, Maya account details, bank account number);
• Communications you send to jl3win's support team via live chat or email.

2.2 Data Collected Automatically

When you access or use the jl3win Platform, certain technical data is collected automatically by our systems:

• IP address and approximate geolocation derived from IP data;
• Device type, operating system, browser type and version;
• Session timestamps, pages visited, and navigation patterns within the Platform;
• Game activity logs, including games played, wager amounts, outcomes, and session durations;
• Cookies and similar tracking technologies as described in Section 6.

2.3 Data from Third Parties

In certain circumstances, jl3win may receive personal data about you from third parties, including:

• Identity verification service providers used to authenticate KYC documents;
• Payment processors (such as GCash and Maya) confirming transaction details;
• PAGCOR or other regulatory bodies transmitting information relevant to player protection or compliance;
• Fraud detection and anti-money laundering screening services.

3How jl3win Uses Your Personal Data

jl3win uses the personal data it collects for the following specific purposes:

• Account creation and management: To register, verify, and maintain your jl3win account, including applying the one-account-per-person policy;
• Identity and age verification: To confirm that you are at least 21 years of age as required by PAGCOR regulations, and to authenticate your identity before processing withdrawals;
• Payment processing: To process deposits and withdrawals via your chosen payment method, and to maintain accurate transaction records;
• Service delivery: To provide access to games, promotions, live dealer services, sports betting, and all other features of the jl3win Platform;
• Regulatory compliance: To comply with PAGCOR's reporting requirements, Anti-Money Laundering Act obligations, and other applicable Philippine laws;
• Fraud prevention and security: To detect and investigate suspicious activity, prevent unauthorised account access, and protect the integrity of the Platform;
• Responsible gaming: To monitor gaming patterns for indicators of problem gambling and to administer player-requested responsible gaming tools;
• Customer support: To respond to your enquiries, resolve disputes, and provide assistance through jl3win's live chat and email support channels;
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have not opted out of receiving such communications;
• Platform improvement: To analyse aggregated and anonymised usage data to improve game performance, user experience, and platform features.

4Legal Basis for Processing

Under the Data Privacy Act of 2012, jl3win's processing of your personal data is carried out on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and jl3win — including account operation, payment processing, game delivery, and customer support;
• Legal obligation: Processing required to comply with PAGCOR's regulatory requirements, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act, and other applicable Philippine laws;
• Legitimate interests: Processing necessary for jl3win's legitimate business interests, including fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your rights and freedoms;
• Consent: Processing of personal data for direct marketing purposes, where your consent has been obtained and may be withdrawn at any time.

5Sharing Your Personal Data

jl3win does not sell your personal data. We may share your personal data with third parties only in the following circumstances and only to the extent necessary:

5.1 Service Providers

jl3win engages third-party service providers to assist in operating the Platform. These include payment processors (GCash, Maya, BPI, BDO), KYC and identity verification providers, fraud detection vendors, game software developers, and cloud infrastructure providers. All service providers are contractually bound to process your data only as instructed by jl3win and to maintain appropriate security standards.

5.2 Regulatory and Law Enforcement Authorities

jl3win will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or any court of competent jurisdiction where required to do so by applicable Philippine law, court order, or binding regulatory instruction.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of jl3win's business assets, personal data held by jl3win may be transferred to the acquiring entity, provided that such entity assumes jl3win's obligations under this Privacy Policy and applicable data protection law. Affected players will be notified of any such transfer.

6Cookies and Tracking Technologies

jl3win uses cookies and similar technologies (including web beacons and local storage) to operate and improve the Platform. Cookies are small data files stored on your browser or device when you visit the Platform.

6.1 Types of Cookies We Use

• Strictly necessary cookies: Required for the Platform to function, including maintaining your login session, remembering your account preferences, and enabling secure access. These cannot be disabled without impairing Platform functionality.
• Analytical cookies: Used to collect aggregated, anonymised data about how players navigate the Platform, which pages they visit most, and where technical errors occur. This data is used solely to improve Platform performance.
• Functional cookies: Used to remember your preferences such as language settings, game history shortcuts, and responsible gaming tool configurations.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the jl3win Platform, including the ability to remain logged in to your account.

7Data Security Measures

jl3win implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and the jl3win Platform;
• AES-256 encryption for personal data and financial information stored in jl3win's systems;
• Multi-factor authentication requirements for internal system access by jl3win personnel;
• Role-based access controls ensuring that personal data is accessible only to authorised personnel with a legitimate operational need;
• Real-time intrusion detection and security monitoring systems operating 24 hours a day;
• Regular security audits and penetration testing conducted by independent third-party cybersecurity professionals;
• Documented incident response procedures for data breaches, including mandatory notification to the National Privacy Commission and affected players within the timeframes required by law.

While jl3win maintains robust security measures, no system is completely immune to risk. You are responsible for maintaining the security of your own account credentials and for notifying jl3win's support team immediately if you suspect any unauthorised access to your account.

8Data Retention

jl3win retains personal data for the periods set out below, after which data is securely deleted or anonymised in accordance with our internal data lifecycle management procedures:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AML legislation;
• Transaction and financial records: Retained for a minimum of five (5) years following the date of the transaction, as required by the Anti-Money Laundering Act;
• Gaming activity logs: Retained for three (3) years following account closure or the last recorded activity;
• Customer support communications: Retained for two (2) years from the date of the communication, or until the matter is finally resolved, whichever is later;
• Marketing consent records: Retained until withdrawn plus one (1) year to maintain an accurate record of consent history.

Where legal proceedings, regulatory investigations, or unresolved disputes are ongoing at the end of a standard retention period, jl3win will retain the relevant data until the matter is concluded.

9Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following legally enforceable rights with respect to your personal data held by jl3win. To exercise any of these rights, please contact our Data Protection Officer at the address set out in Section 13.

jl3win will respond to all verified data subject rights requests within thirty (30) calendar days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by a further fifteen (15) days, of which you will be notified. If you are not satisfied with jl3win's response, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines.

10Children's Data

The jl3win Platform is strictly intended for individuals aged 21 years and above, as mandated by PAGCOR regulations. jl3win does not knowingly collect personal data from any person under the age of 21. Age verification is enforced during account registration as a mandatory step before any access to gaming features is granted.

If jl3win becomes aware that personal data has been collected from an individual who was under 21 years of age at the time of collection, that data will be promptly and permanently deleted, the associated account will be closed, and any funds deposited will be handled in accordance with PAGCOR's guidelines on underage account management.

11Cross-Border Data Transfers

jl3win's primary operations and data storage are based in the Philippines. However, certain third-party service providers engaged by jl3win — including game software developers, cloud infrastructure providers, and cybersecurity vendors — may be located outside the Philippines and may process personal data in their respective jurisdictions.

Where personal data is transferred outside the Philippines, jl3win ensures that appropriate safeguards are in place in accordance with NPC requirements, including the execution of data sharing agreements and, where applicable, standard contractual clauses consistent with those recognised by the National Privacy Commission.

12Changes to This Privacy Policy

jl3win reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable laws, or the services we provide. Material changes to this Policy will be communicated to registered players via the email address on file and/or through a prominent notice displayed on the Platform, at least fourteen (14) days before the changes take effect where practicable.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically. Your continued use of the jl3win Platform following the effective date of any revision constitutes your acceptance of the updated Policy.

13Contact — Data Protection Officer

For all enquiries, complaints, or requests relating to your personal data or this Privacy Policy, please contact jl3win's designated Data Protection Officer:

Email: [email protected]

Please mark your correspondence clearly with the subject line "Data Privacy Request" to ensure it is routed directly to the Data Protection Officer. jl3win will acknowledge your request within five (5) business days and will provide a substantive response within the timeframes prescribed by the Data Privacy Act and NPC regulations.

If you believe that jl3win has not adequately addressed your data privacy concern, you have the right to escalate the matter to the National Privacy Commission, the supervisory authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines.