jl92 Privacy Policy

The data controller responsible for the processing of your personal information in connection with jl92.club is jl92 ("jl92," "we," "us," or "the Platform"). As data controller, jl92 determines the purposes and means of processing your personal data and is accountable to you and to the National Privacy Commission of the Philippines (NPC) for compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

If you have questions about how jl92 processes your personal data, you may contact our Data Protection Officer at the contact details provided in Section 14 of this Policy.

jl92 collects personal data that is necessary and proportionate to the purposes described in this Policy. The categories of personal data jl92 processes include:

jl92 does not intentionally collect special categories of sensitive personal data (such as health data or political opinions) unless specifically required for compliance purposes, such as responsible gaming assessments requested by you or mandated by applicable regulation.

jl92 collects personal data through the following channels:

• Direct submission: Information you provide during account registration, identity verification, payment setup, support interactions, and responsible gaming self-assessments.
• Automated collection: Technical and usage data collected automatically as you interact with jl92.club — via cookies, session tokens, server logs, and analytics tools.
• Payment processors: Financial reference data relayed by GCash, Maya, BPI, BDO, and other payment partners necessary to confirm and reconcile transactions.
• Identity verification services: Document verification data provided by third-party KYC service providers engaged by jl92 to verify player identity and age as required by PAGCOR and Philippine anti-money laundering regulations.
• Third-party fraud and security tools: Risk signals and device fingerprint data from security service providers used to detect fraudulent account activity.

jl92 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Performance of a contract: Processing necessary to create and manage your jl92 account, process deposits and withdrawals, and deliver the gaming services you have contracted for.
• Legal obligation: Processing required for jl92 to comply with Philippine laws and PAGCOR regulations — including Anti-Money Laundering Act (AMLA) compliance, mandatory age verification, tax reporting obligations, and responses to lawful orders from regulatory or law enforcement authorities.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving jl92's services — where these interests are not overridden by your data protection rights.
• Consent: Where jl92 relies on consent — for example, for optional marketing communications — you may withdraw consent at any time without affecting the lawfulness of prior processing.

jl92 uses your personal data for the following purposes:

• Creating, verifying, and managing your jl92 player account.
• Processing deposits and withdrawals via GCash, Maya, and other Philippine payment methods.
• Verifying your identity and age (21+) as required by PAGCOR and Philippine law.
• Conducting AML screening and monitoring transaction patterns in compliance with the Anti-Money Laundering Act.
• Detecting and preventing fraud, account takeover, and other security threats to your jl92 account.
• Administering bonuses, promotions, and loyalty program rewards.
• Providing 24/7 customer support — including live chat, email, and complaint resolution.
• Monitoring gaming behaviour to identify potential problem gambling patterns and delivering responsible gaming interventions.
• Sending transactional communications — account verification codes (OTPs), withdrawal confirmations, security alerts.
• Sending marketing communications about jl92 promotions and new features — only where you have provided consent or where permitted by applicable law.
• Improving the jl92 platform based on aggregated usage analytics.
• Complying with legal obligations and responding to lawful requests from Philippine regulatory and law enforcement authorities.

jl92 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. jl92 shares personal data only in the following limited circumstances:

• Payment processors: GCash, Maya, BPI, BDO, and other payment partners receive necessary financial reference data to process your transactions.
• Identity verification providers: KYC service providers engaged by jl92 to verify identity documents and confirm age compliance receive the specific document data necessary for verification only.
• Game providers: Technical game session data (but not full identity or financial data) is shared with JILI, PG Soft, Pragmatic Play, and other game providers to facilitate game delivery and dispute resolution.
• Security and fraud prevention services: Device and behavioural data is shared with third-party security services to detect fraudulent activity.
• PAGCOR and Philippine regulatory authorities: jl92 is obligated to provide transaction records, player data, and other information to PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine authorities when required by law or regulation.
• Professional advisers: Legal, accounting, and audit professionals retained by jl92 may access limited personal data strictly as necessary for their professional services, subject to confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of jl92's business, your personal data may be transferred as part of that transaction, subject to appropriate confidentiality protections.

Some third-party service providers engaged by jl92 — including game providers and technical infrastructure partners — may process personal data outside the Philippines. Where such transfers occur, jl92 ensures that adequate safeguards are in place in accordance with the requirements of the Philippine Data Privacy Act and the National Privacy Commission's guidelines on cross-border data transfers.

Safeguards may include contractual data processing agreements incorporating standard data protection clauses, or transfers to jurisdictions recognized by the NPC as providing adequate levels of data protection. You may request further information about cross-border transfers by contacting jl92's Data Protection Officer.

jl92 retains your personal data for as long as necessary to fulfil the purposes described in this Policy, including for the duration of your active account relationship with jl92 and for the minimum periods required by Philippine law thereafter.

• Account and identity data: Retained for the duration of your jl92 account plus a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of each transaction in compliance with AMLA record-keeping obligations.
• Gaming data: Retained for the duration of your account plus two (2) years following account closure, or longer where required for dispute resolution or regulatory reporting.
• Communications data: Live chat and support transcripts retained for two (2) years from the date of the interaction.
• Technical and usage data: Retained for up to twelve (12) months, after which it is aggregated or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with you as an individual.

jl92.club uses cookies and similar tracking technologies — including session tokens, local storage, and analytics pixels — to operate the platform, maintain your logged-in session, prevent fraud, and analyze platform usage patterns. Cookies set by jl92 fall into the following categories:

• Strictly necessary cookies: Required for core platform functionality — session authentication, security tokens, and load balancing. These cannot be disabled without affecting your ability to use jl92.
• Functional cookies: Remember your preferences such as language setting, game filters, and display preferences to improve your experience.
• Analytics cookies: Collect anonymized usage data to help jl92 understand how Filipino players interact with the platform and identify areas for improvement. Data collected is aggregated and not associated with your personal identity.
• Security cookies: Support fraud detection and bot prevention systems that protect your jl92 account.

You may control cookie settings through your browser preferences. Disabling non-essential cookies will not prevent you from using jl92's core gaming features, though some personalization functionality may be limited.

jl92 implements technical and organizational security measures appropriate to the nature and sensitivity of personal data processed on the platform. These measures include:

• TLS 1.3 encryption for all data in transit between your device and jl92 servers — the same encryption standard used by Philippine banks.
• Encryption at rest for sensitive stored personal data, including identity documents and financial reference data.
• Multi-factor authentication (OTP via Philippine mobile number) for new device logins and high-value transaction authorizations.
• Role-based access controls ensuring that jl92 staff can only access the personal data necessary for their specific job function.
• Regular security audits and penetration testing of jl92's platform infrastructure.
• Automatic account lock after multiple consecutive failed login attempts to prevent brute-force attacks.
• Segregation of player funds from operational accounts, preventing co-mingling of player balances with company funds.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl92:

• Right to be informed: The right to be notified of how jl92 collects and uses your personal data — which this Privacy Policy fulfils.
• Right to access: The right to request a copy of the personal data jl92 holds about you, together with information about how that data is being processed.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected. You may update basic account information directly through your jl92 account settings.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and where no legal obligation requires jl92 to retain it.
• Right to object: The right to object to processing of your personal data based on legitimate interests — including profiling for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe jl92 has processed your personal data in violation of the DPA.

To exercise any of these rights, please contact jl92's Data Protection Officer at the contact details in Section 14. jl92 will respond to data rights requests within fifteen (15) days of receipt, in accordance with NPC guidelines. Some rights may be limited where jl92 is required by law to retain or process specific data.

jl92 strictly prohibits use of its platform by individuals under 21 years of age, in compliance with PAGCOR age restriction requirements for online gambling in the Philippines. jl92 does not knowingly collect personal data from individuals under 21. Where jl92 discovers that personal data of an underage individual has been collected, it will immediately close the associated account and delete the relevant personal data.

If you are a parent or guardian and believe that an underage individual has registered an account on jl92, please contact our support team immediately via live chat or at the email address in Section 14 so that we can investigate and take appropriate action.

jl92 may update this Privacy Policy from time to time to reflect changes in applicable law, NPC guidance, or jl92's data processing practices. When material changes are made, jl92 will notify registered users via email or an in-platform notification prior to the changes taking effect. The most current version of this Privacy Policy will always be accessible at jl92.club/privacy-policy.

Your continued use of jl92 after the effective date of any Privacy Policy update constitutes acceptance of the revised Policy. If you do not accept the revised Policy, you must cease using jl92 and may request closure of your account by contacting customer support.

For all data privacy inquiries, data rights requests, or to report a potential privacy concern, please contact jl92's Data Protection Officer: