Privacy Policy — jl879.club

1. Scope & Data Controller

1.1 This Privacy Policy applies to all personal data collected, processed, and stored by jl879 in connection with the operation of jl879.club, including data collected through account registration, identity verification (KYC), payment transactions, game play activity, customer support interactions, and any other use of the Platform.

1.2 jl879 is the data controller for the personal data described in this Policy. As data controller, jl879 determines the purposes and means of processing your personal data and bears primary responsibility for its lawful and fair processing in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

1.3 This Policy should be read alongside jl879's Terms & Conditions and Responsible Gaming Policy, all of which form part of the overall framework governing your relationship with jl879.

1.4 jl879 operates within the PAGCOR regulatory framework. Certain data processing activities — particularly those related to anti-money laundering (AML), know-your-customer (KYC), and responsible gaming compliance — are conducted pursuant to regulatory obligations that take precedence over individual data subject preferences.

2. Personal Data We Collect

jl879 collects personal data across the following categories. Not all categories apply to every user — the data collected depends on the nature of your interaction with the Platform.

2.1 Special Categories of Data: jl879 does not intentionally collect special categories of personal data (such as health data, political opinions, religious beliefs, or biometric data beyond what is required for identity verification). Where ID photographs are collected for KYC purposes, they are processed solely for identity verification and are not used for biometric analysis beyond what is necessary for that verification.

3. How We Collect Your Data

jl879 collects personal data through the following channels and mechanisms:

• Direct submission — data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or updating your account profile;
• Automated collection — technical data collected automatically when you access jl879.club, including through cookies, server logs, and session tracking technologies (see Section 9 for full details on cookies);
• Third-party sources — identity verification data confirmed by KYC service providers; payment confirmation data from GCash, Maya, BPI, BDO, and UnionBank; fraud and AML screening results from compliance service providers; and regulatory data from PAGCOR where applicable;
• Publicly available sources — where required for regulatory compliance purposes, jl879 may cross-reference information against publicly available records such as government sanction lists, court records, and regulatory blacklists.

4. Purposes & Legal Basis for Processing

jl879 processes your personal data only where a lawful basis for processing exists under the Philippine Data Privacy Act. The following table sets out the primary purposes of processing and the applicable legal basis for each.

5. Disclosure to Third Parties

5.1 jl879 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data with third parties only in the following circumstances:

5.2 Service Providers and Processors

jl879 engages the following categories of third-party processors who handle personal data on our behalf and under our instruction, subject to contractual data processing agreements:

• KYC and Identity Verification Providers — to verify your identity and age as required by PAGCOR regulations;
• Payment Processors — GCash (Mynt/Globe Fintech), Maya (Voyager/PLDT), BPI, BDO, UnionBank, and USDT TRC20 facilitators, solely for the processing of deposits and withdrawals;
• Game Providers — JILI, Pragmatic Play, PG Soft, Evolution Gaming, Asia Gaming, and other licensed providers, who receive gameplay data necessary to operate their games on jl879's platform. Game providers operate under their own data processing agreements and are bound by confidentiality obligations;
• AML and Fraud Screening Providers — to screen transactions and player profiles against sanctions lists and fraud databases as required by the Anti-Money Laundering Act (RA 9160 as amended);
• Cloud Infrastructure and Hosting Providers — for secure data storage and platform operation;
• Customer Support Platform Providers — for the operation of live chat and email support systems.

5.3 Regulatory and Legal Disclosures

jl879 may disclose personal data to PAGCOR, the AMLC (Anti-Money Laundering Council), the National Privacy Commission, law enforcement authorities, or courts of competent jurisdiction where required by law, regulation, court order, or regulatory directive. Such disclosures are made to the minimum extent necessary to comply with the applicable legal obligation.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of jl879's assets, personal data held by jl879 may be transferred to the acquiring or successor entity. Affected players will be notified of any such transfer prior to their data becoming subject to a different privacy policy.

6. International Data Transfers

6.1 Some of jl879's third-party service providers — particularly game providers and cloud infrastructure operators — may be located outside the Philippines. Where personal data is transferred to countries that the National Privacy Commission has not recognised as providing an adequate level of data protection, jl879 takes steps to ensure that appropriate safeguards are in place, including standard contractual clauses or equivalent mechanisms.

6.2 By using jl879 and submitting personal data, you acknowledge that your data may be processed in jurisdictions outside the Philippines where data protection laws may differ from Philippine law. jl879 ensures that any such cross-border processing is conducted subject to appropriate contractual and technical safeguards.

7. Data Retention

7.1 jl879 retains personal data for the period necessary to fulfil the purpose for which it was collected, or for the minimum period required by applicable Philippine law and regulation, whichever is longer.

7.2 The following retention periods apply as a general guide:

• Account and KYC data — retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR and AMLC requirements;
• Transaction and financial records — retained for a minimum of ten (10) years from the date of the transaction, in compliance with the Anti-Money Laundering Act;
• Gaming activity records — retained for a minimum of three (3) years from the date of the activity;
• Customer support records — retained for two (2) years from the date of the interaction;
• Technical and usage logs — typically retained for twelve (12) months unless required longer for security or legal purposes.

7.3 Following the expiry of the applicable retention period, personal data will be securely deleted, destroyed, or anonymised so that it can no longer be attributed to any individual. Where anonymisation is used, the anonymised data may be retained indefinitely for analytical purposes.

8. Security Measures

8.1 jl879 implements technical and organisational security measures designed to protect personal data against unauthorised access, disclosure, alteration, destruction, or accidental loss. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jl879's servers;
• Encryption of sensitive data at rest in our database infrastructure;
• Role-based access controls limiting personal data access to authorised personnel with a documented operational need;
• Multi-factor authentication requirements for jl879 staff accessing systems containing personal data;
• Regular security vulnerability assessments and penetration testing;
• Documented incident response and data breach notification procedures;
• Physical security controls at data processing facilities.

8.2 Notwithstanding these measures, no security system is impenetrable. jl879 cannot guarantee absolute security of personal data and accepts no liability for breaches that occur despite reasonable security measures, except to the extent such liability cannot be excluded under Philippine law.

8.3 You are responsible for maintaining the security of your own account credentials. jl879 strongly recommends enabling two-factor authentication (2FA) and using a strong, unique password for your jl879 account.

9. Cookies & Tracking Technologies

9.1 jl879 uses cookies and similar tracking technologies to operate the Platform, maintain your session, personalise your experience, and analyse usage patterns. The following types of cookies are used on jl879.club:

• Strictly Necessary Cookies — essential for the Platform to function. These include session authentication cookies that keep you logged in during your visit. These cannot be disabled without preventing the Platform from working.
• Functional Cookies — store your preferences such as language settings, preferred game categories, and UI settings. Disabling these will reduce personalisation.
• Analytics Cookies — collect aggregated, anonymised data about how users interact with jl879.club — pages visited, session duration, referral sources. This data helps jl879 improve the Platform experience. These are not linked to identifiable individuals.
• Security Cookies — used to detect fraud, unusual login activity, and bot behaviour. These are part of jl879's security infrastructure.

9.2 jl879 does not use advertising cookies or serve targeted advertising on the Platform. We do not share cookie data with advertising networks.

9.3 You can control cookie preferences through your browser settings. Blocking strictly necessary cookies will prevent you from logging in to jl879. Instructions for managing cookies are available in the help documentation of your browser (Chrome, Safari, Firefox, Edge).

10. Your Data Subject Rights

10.1 Under Republic Act No. 10173 (Philippine Data Privacy Act of 2012), you have the following rights with respect to your personal data held by jl879. These rights are subject to applicable legal exceptions, including regulatory obligations that require jl879 to retain certain data regardless of your request.

10.2 To exercise any of the above rights, contact jl879's Data Protection Officer at the address in Section 15. Requests will be acknowledged within five (5) business days and resolved within thirty (30) calendar days, or within the extended period permitted under Philippine law for complex requests.

10.3 jl879 will not charge a fee for data subject rights requests unless the request is manifestly unfounded or excessive. Where a fee applies, we will notify you before processing the request.

10.4 If you are dissatisfied with jl879's response to a data subject rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

11. Minors' Privacy

11.1 jl879 takes the protection of minors seriously. If you believe that a person under the age of 21 has registered an account on jl879 or submitted personal data to jl879, please contact our Data Protection Officer immediately at the contact details in Section 15.

12. Marketing Communications

12.1 jl879 may send you promotional communications about new games, bonuses, platform updates, and special offers where you have provided explicit consent to receive such communications at registration or through your Account Settings.

12.2 You may withdraw consent to marketing communications at any time by updating your notification preferences in Account Settings, or by contacting jl879 support. Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to withdrawal.

12.3 Withdrawal of marketing consent does not affect jl879's ability to send you transactional communications — such as account activity notifications, deposit confirmations, withdrawal processing updates, and security alerts — which are sent on the basis of contract performance and legitimate interests rather than consent.

12.4 jl879 does not share your personal data with third parties for their own direct marketing purposes.

13. Data Breach Notification

13.1 In the event of a personal data breach that is reasonably likely to result in serious harm to affected data subjects, jl879 will:

1. Notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach;
2. Notify affected data subjects as soon as reasonably practicable following the NPC notification, providing sufficient information for affected individuals to take protective measures;
3. Maintain a record of the breach, its nature, the data affected, the likely consequences, and the remedial measures taken, in accordance with NPC guidelines.

13.2 Breach notifications to affected players will be sent to the email address or mobile number on file for the affected account. jl879 strongly recommends that players keep their contact details current in Account Settings to ensure timely receipt of such notifications.

13.3 Not all security incidents constitute a reportable data breach. Where a security incident is contained without exposure of personal data, jl879 will document the incident internally but is not required to notify the NPC or affected players.

14. Changes to This Privacy Policy

14.1 jl879 reserves the right to update this Privacy Policy at any time. The effective date and last updated date displayed at the top of this page reflect the current version.

14.2 Material changes to this Privacy Policy — particularly changes that affect how your personal data is collected, used, or shared — will be communicated to registered players via email notification to the address on file or through a prominent notice on the Platform, not less than fourteen (14) calendar days prior to the change taking effect, where practicable.

14.3 Your continued use of jl879 following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you may request account closure in accordance with the Terms & Conditions.

15. Contact & Data Protection Officer

15.1 jl879 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. The DPO is the primary point of contact for all personal data matters, including data subject rights requests, privacy complaints, and breach notifications.

15.2 If you are dissatisfied with jl879's handling of your personal data or our response to a data subject rights request, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC) at its official website and contact channels.

15.3 All official communications from jl879 regarding this Privacy Policy will come from addresses on the jl879.club domain. Emails from other domains purporting to be from jl879 should be treated as fraudulent and reported to jl879 support immediately.