jll33 Privacy Policy

This Policy applies to all personal data collected from individuals who register a jll33 account, visit the Platform, use jll33 games, engage with jll33 customer support, or interact with jll33 in any other capacity. It covers data collected through the Platform website, any associated mobile-optimized interface, and communications between you and jll33.

This Policy should be read alongside jll33's Terms & Conditions and Responsible Gaming page, which together form the complete framework governing your relationship with jll33.

jll33's privacy practices are designed to comply with Republic Act No. 10173 (Data Privacy Act of 2012 of the Philippines), its Implementing Rules and Regulations, and PAGCOR regulatory data handling requirements applicable to licensed online gaming operators.

jll33 acts as the Data Controller with respect to personal data collected through the Platform. As Data Controller, jll33 determines the purposes and means by which your personal data is processed. jll33 has appointed a Data Protection Officer (DPO) in accordance with the requirements of the National Privacy Commission (NPC). The DPO's contact details are provided in Section 15 of this Policy.

In cases where jll33 engages third-party service providers to process data on its behalf (for example, payment processors, KYC verification services, and game content providers), those parties act as Data Processors under jll33's instructions and are bound by data processing agreements that require them to maintain appropriate security measures and process data only as directed by jll33.

jll33 collects and processes the following categories of personal data:

jll33 collects personal data through the following channels:

• Direct Collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in surveys and promotions;
• Automated Collection: Technical and usage data collected automatically through the Platform via server logs, cookies, and session tracking technology as described in Section 7;
• Third-Party Collection: Data received from payment processors (GCash, Maya, BPI, BDO), KYC verification service providers, and fraud detection systems when you transact through the Platform;
• Identity Verification Providers: Data returned from third-party identity verification services when you submit KYC documentation, including document authenticity checks and facial recognition results where applicable.

jll33 processes your personal data on the following legal grounds as provided under the Data Privacy Act of 2012 and its Implementing Rules:

• Contractual Necessity: Processing required to fulfill the agreement between you and jll33 — including account operation, deposit processing, game access, and withdrawal services;
• Legal Obligation: Processing required to comply with PAGCOR regulations, Anti-Money Laundering (AMLA) obligations, tax reporting requirements, and NPC data governance requirements;
• Legitimate Interests: Processing conducted to detect and prevent fraud, ensure platform security, manage operational risk, and improve the Platform experience — where those interests are not overridden by your privacy rights;
• Consent: Processing for optional activities such as marketing communications, where you have given explicit consent. You may withdraw consent for marketing at any time by contacting support or updating your account communication preferences.

jll33 uses the personal data it collects for the following specific purposes:

6.1 Account Management & Platform Operation

To create and manage your jll33 account, authenticate your identity at login, process deposits and withdrawals, calculate and credit bonuses, and maintain your gaming activity history accessible from your account dashboard.

6.2 Identity Verification & KYC Compliance

To verify that you are at least 21 years of age and to confirm your identity in compliance with PAGCOR's KYC requirements. KYC verification is mandatory before withdrawals are enabled and may be requested at any point during the account lifecycle for compliance purposes.

6.3 Fraud Prevention & Security

To detect and prevent fraudulent activity, unauthorized account access, money laundering, bonus abuse, and other activities prohibited under jll33's Terms & Conditions. This includes automated monitoring of transaction patterns and login behavior, and IP-based anomaly detection.

6.4 Regulatory Compliance

To fulfill jll33's obligations under PAGCOR regulations, the Anti-Money Laundering Act (Republic Act No. 9160 as amended), and applicable tax reporting requirements. Regulatory compliance may require the retention and disclosure of certain data to government authorities.

6.5 Customer Support

To respond to your queries, resolve disputes, process account restriction requests (including self-exclusion), and maintain records of communications for quality assurance and dispute documentation purposes.

6.6 Responsible Gaming Monitoring

To support jll33's responsible gaming obligations, including monitoring player activity for signs of problem gambling behavior, applying deposit limits and session restrictions you have requested, and communicating responsible gaming resources where appropriate.

6.7 Marketing Communications (Consent-Based)

To send you promotional communications about jll33 bonuses, game launches, and platform updates, where you have provided consent to receive such communications. Each marketing communication includes an unsubscribe mechanism. Withdrawal of consent does not affect the lawfulness of marketing communications sent before withdrawal.

6.8 Platform Improvement

To analyze aggregated and anonymized usage data to improve the Platform's performance, design, and game library. This analysis does not identify individual players and does not involve the sale of data to third parties.

jll33 uses cookies and similar tracking technologies to operate the Platform effectively and to provide you with a personalized experience. A cookie is a small text file placed on your device by the Platform when you visit it. jll33 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function — including session authentication tokens, CSRF protection cookies, and load-balancing identifiers. These cannot be disabled without breaking Platform functionality;
• Functional Cookies: Remember your preferences such as language settings, game display preferences, and deposit method defaults to enhance your experience on return visits;
• Analytics Cookies: Collect aggregated, anonymized data about how visitors navigate the Platform to help us identify usability improvements. Individual users are not identifiable from this data;
• Security Cookies: Support fraud detection systems by identifying unusual patterns across sessions, such as rapid account switching or payment anomalies.

You may manage cookie preferences through your browser settings. Note that disabling Strictly Necessary Cookies will impair your ability to log in to and use the Platform.

jll33 does not sell, rent, or trade your personal data to third parties. Data is shared only in the following limited circumstances:

• Payment Processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), BPI, BDO, and cryptocurrency processing partners receive the minimum data necessary to process your deposit and withdrawal transactions;
• KYC and Identity Verification Providers: Third-party verification services receive your identity document data to perform government ID authentication and facial verification as part of the KYC process;
• Game Content Providers: When you launch a game, your account identifier and session token are passed to the relevant game provider to initiate the game session. Game providers do not receive your financial or identity data;
• Fraud Detection and Security Services: Anonymized or pseudonymized technical data is shared with security service providers to detect fraudulent activity. These providers are contractually prohibited from using data for any purpose other than fraud detection;
• Legal and Regulatory Authorities: jll33 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement, and courts when required to do so by applicable Philippine law, a valid court order, or a regulatory directive;
• Corporate Transactions: In the event of a merger, acquisition, or sale of jll33's business or assets, personal data held by jll33 may be transferred to the acquiring entity, provided that the acquiring entity is bound to protect the data under terms no less protective than this Policy.

All third-party service providers engaged by jll33 are required to maintain appropriate technical and organizational security measures and to process data only in accordance with jll33's documented instructions.

jll33 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention obligations:

• Active Account Data: Retained for the duration of your jll33 account and for a minimum period following account closure as required by PAGCOR regulations and AMLA record-keeping obligations;
• KYC Documentation: Identity documents and verification records are retained for a minimum of five (5) years following account closure in compliance with PAGCOR KYC requirements and AMLA record-keeping obligations under Republic Act No. 9160;
• Transaction Records: Deposit, withdrawal, and gaming transaction records are retained for a minimum of five (5) years for regulatory compliance and dispute resolution purposes;
• Support Communications: Customer support interactions are retained for three (3) years to support dispute resolution and quality assurance;
• Marketing Consent Records: Records of marketing consent and withdrawal of consent are retained for the duration of the account and for one (1) year following account closure;
• Cookie and Technical Data: Session-level technical data is retained for up to ninety (90) days. Aggregated, anonymized analytics data may be retained indefinitely as it cannot identify individuals.

jll33 implements a layered approach to data security, combining technical controls, organizational measures, and access management policies to protect your personal data against unauthorized access, disclosure, alteration, or destruction.

Key security measures include:

• TLS/SSL Encryption: All data transmitted between your device and jll33 servers is encrypted in transit using industry-standard TLS encryption;
• Encryption at Rest: Sensitive data, including KYC documents and financial account details, is encrypted in jll33's databases using AES-256 encryption or equivalent;
• Access Controls: Access to personal data is restricted to jll33 personnel on a need-to-know basis. Access privileges are reviewed regularly and revoked promptly upon role changes;
• Two-Factor Authentication (2FA): Administrative access to systems containing personal data requires multi-factor authentication;
• Security Monitoring: jll33 maintains continuous monitoring of its infrastructure for unauthorized access attempts, anomalous data flows, and known vulnerability signatures;
• Data Breach Response: In the event of a personal data breach that is likely to result in harm to affected individuals, jll33 will notify the National Privacy Commission within seventy-two (72) hours of discovery and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.

While jll33 applies robust security measures, no online platform can guarantee absolute security against all possible threats. You are responsible for maintaining the security of your own account credentials, as described in jll33's Terms & Conditions.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by jll33. To exercise any of these rights, please contact jll33's Data Protection Officer using the details in Section 15.

jll33 will respond to all data rights requests within thirty (30) days of receipt. Requests may be extended by a further thirty (30) days where the complexity or volume of requests justifies it, with notice provided to you. Where jll33 is unable to fulfil a request due to a conflicting legal obligation (for example, mandatory KYC retention periods), jll33 will explain the basis for that limitation in its response.

If you are unsatisfied with jll33's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The jll33 Platform is strictly intended for individuals who are at least twenty-one (21) years of age. jll33 does not knowingly collect personal data from persons under 21. The minimum age requirement is enforced through the mandatory KYC identity verification process, which requires submission of a valid government-issued Philippine ID confirming the account holder's date of birth.

If jll33 discovers that an Account has been registered by or is being used by a person under 21 years of age, jll33 will immediately suspend the Account, void any associated gaming activity, and process a return of any real-money deposits to the payment method used — subject to applicable PAGCOR guidance and jll33's Terms & Conditions regarding underage account closure.

If you believe that a person under 21 has registered a jll33 account, please contact jll33 Customer Support immediately using the contact information in Section 15.

The jll33 Platform may contain references or links to third-party services (such as payment provider help pages or game provider studios). This Privacy Policy applies exclusively to data processed by jll33 and does not extend to the privacy practices of any third-party websites or services you may access through the Platform.

jll33 has no control over and takes no responsibility for the privacy policies or data handling practices of third-party services. You are encouraged to review the applicable privacy policy of any third-party service you use in connection with your jll33 account, including your GCash or Maya provider.

jll33 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, NPC guidance, or jll33's data processing practices. When material changes are made, jll33 will publish the updated Policy on this page with a revised "Last Updated" date and will notify registered players via the contact details held on their Account.

Your continued use of the jll33 Platform following publication of an updated Policy constitutes acceptance of the revised terms. If you do not agree to a material change, you may request account closure by contacting jll33 Customer Support, at which point jll33 will delete or anonymize your personal data in accordance with the retention obligations described in Section 9.

If you have questions or concerns about this Privacy Policy, wish to exercise your data rights, or need to report a potential data security incident involving your jll33 account, please contact jll33's Data Protection Officer:

• Role: Data Protection Officer, jll33
• Live Chat: Available through the jll33 Platform, 8:00 AM – 12:00 AM PHT (UTC+8), daily;
• Email (plain text — not a clickable link): [email protected]

jll33 will acknowledge all Privacy Policy-related inquiries and data rights requests within five (5) business days and provide a substantive response within thirty (30) days. For data breach notifications or urgent security concerns, please use Live Chat for the fastest response.

If you are not satisfied with jll33's handling of your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) through their official complaint channels.