Privacy Policy – jl23 Casino

1. Introduction and Scope

1.1 This Privacy Policy ("Policy") is issued by jl23 Casino ("jl23," "we," "us," "our"), the operator of the online gaming platform at jl23.asia ("Platform"). This Policy applies to all personal data collected from players, prospective players, and visitors ("you," "Data Subject") in connection with the jl23 Platform and any related customer communications.

1.2 jl23 operates as a data controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations. jl23 is committed to processing personal data in a manner that is consistent with the principles of transparency, legitimate purpose, and proportionality as mandated by Philippine law.

1.3 This Policy should be read alongside jl23's Terms & Conditions and Responsible Gaming Policy, all of which form part of the jl23 player agreement.

2. Personal Data We Collect

2.1 Registration and Identity Data

When you create a jl23 account, we collect the following categories of personal data:

• Full legal name as it appears on a government-issued Philippine ID;
• Date of birth (to verify the 21+ age requirement);
• Philippine mobile number (used as primary account identifier);
• Email address;
• Residential address in the Philippines.

2.2 Identity Verification (KYC) Documents

To comply with PAGCOR's Know Your Customer (KYC) requirements and Philippine anti-money laundering law, jl23 may collect copies of:

• Government-issued photo ID (e.g., Philippine passport, driver's license, SSS card, PhilHealth ID, UMID, or Voter's ID);
• Proof of residential address (e.g., utility bill or bank statement issued within the past 90 days);
• Source-of-funds documentation where required by applicable regulations.

2.3 Financial and Transaction Data

jl23 records all financial transactions associated with your account, including deposit amounts, withdrawal requests, payment methods used (GCash, PayMaya, BPI, BDO, Metrobank), transaction timestamps, and account balance history.

2.4 Gaming Activity Data

We maintain records of your gaming activity on the jl23 Platform, including games played, wager amounts, game outcomes, session durations, and bonus usage. This data is necessary for game integrity, dispute resolution, and responsible gaming monitoring.

2.5 Technical and Device Data

When you access jl23, our systems automatically collect technical data including your IP address, browser type and version, operating system, device type, referring URLs, and pages visited. This data is used for security monitoring, fraud prevention, and platform performance optimisation.

3. How We Use Your Personal Data

jl23 uses your personal data only for the following specified, explicit, and legitimate purposes:

• Account Management: Creating and maintaining your jl23 player account, processing your jl23 login, and managing your account settings and preferences.
• Identity Verification: Conducting KYC checks as required by PAGCOR and Philippine anti-money laundering law, including verifying the 21+ age requirement.
• Payment Processing: Processing deposits to your jl23 wallet and withdrawals to your verified payment method (GCash, PayMaya, or bank account).
• Game Delivery and Integrity: Providing access to games, recording game outcomes for audit purposes, and investigating suspected fraud or collusion.
• Regulatory Compliance: Meeting our obligations to PAGCOR, including submitting required reports and cooperating with regulatory investigations.
• Responsible Gaming: Monitoring gaming behaviour to identify potential problem gambling patterns and administering player-requested self-exclusion or limit settings.
• Customer Support: Responding to your support queries, resolving account disputes, and maintaining records of support interactions.
• Security and Fraud Prevention: Detecting, investigating, and preventing fraudulent transactions, account takeovers, and other security threats to the jl23 Platform.
• Communications: Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts) and, where you have consented, promotional communications about jl23 offers.

4. Legal Basis for Processing

jl23 processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing required to perform our obligations under the jl23 Terms & Conditions, including account management and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR regulations, Anti-Money Laundering Act obligations, and other applicable Philippine law.
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such processing is proportionate and does not override your privacy rights.
• Consent: Processing for optional marketing communications, where you have provided explicit consent that may be withdrawn at any time.

5. Data Sharing and Disclosure

5.1 jl23 does not sell, rent, or trade your personal data to third parties for commercial purposes.

5.2 jl23 may share your personal data with the following categories of recipients, strictly limited to what is necessary for the stated purpose:

• PAGCOR and Philippine Regulatory Authorities: As required by our gaming licence, jl23 submits required player data and activity reports to PAGCOR and, where legally compelled, to other Philippine government bodies including law enforcement agencies.
• Payment Service Providers: GCash (Mynt), PayMaya (Voyager), BPI, BDO, Metrobank, and other payment processors receive the minimum data necessary to process your transactions.
• Identity Verification Providers: Third-party KYC and AML screening services process identity documents on behalf of jl23 under strict data processing agreements.
• IT and Hosting Service Providers: Cloud hosting and technical infrastructure providers who process data on jl23's behalf under binding confidentiality and data processing agreements.
• Game Software Providers: JILI Games, Pragmatic Play, PG Soft, and other certified game suppliers may receive anonymised session data required for game delivery and technical support.

5.3 All third-party processors engaged by jl23 are contractually required to maintain data security standards consistent with or exceeding those required by the Philippine DPA.

6. Cookies and Tracking Technologies

6.1 jl23 uses cookies and similar technologies to operate and improve the Platform. These include:

• Strictly Necessary Cookies: Required for the Platform to function, including maintaining your jl23 login session and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences (language, display settings) between sessions.
• Analytics Cookies: Aggregate, anonymised data about how players navigate the Platform, used to improve the user experience.

6.2 You may control non-essential cookies through your browser settings. Disabling strictly necessary cookies will impair Platform functionality.

7. Data Retention

7.1 jl23 retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods include:

• Account registration and KYC data: minimum five (5) years from account closure, as required by Philippine AML regulations;
• Transaction records: minimum five (5) years from the date of each transaction;
• Gaming activity logs: minimum three (3) years from the date of each session;
• Support interaction records: three (3) years from the date of each interaction.

7.2 Following the expiry of applicable retention periods, jl23 will securely delete or anonymise your personal data.

8. Data Security

8.1 jl23 implements technical and organisational security measures appropriate to the nature of the personal data processed and the risks involved. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jl23 servers;
• Encryption of sensitive data at rest, including KYC documents and payment details;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Multi-factor authentication for administrative access to systems containing personal data;
• Regular security assessments and penetration testing;
• Incident response procedures for data breach detection and notification.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl23 will notify the National Privacy Commission (NPC) and affected Data Subjects in accordance with the DPA's breach notification requirements.

9. Your Rights as a Data Subject

Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by jl23:

• Right to be Informed: You have the right to be told what personal data jl23 collects and how it is used — this Policy fulfils that right.
• Right of Access: You may request a copy of the personal data jl23 holds about you.
• Right to Rectification: If your personal data is inaccurate or incomplete, you may request correction. You can update basic account details directly in your jl23 account settings.
• Right to Erasure: You may request deletion of your personal data in certain circumstances, subject to jl23's legal retention obligations.
• Right to Object: You may object to processing based on legitimate interests, including profiling for marketing purposes.
• Right to Data Portability: You may request your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe jl23 has violated your privacy rights, you may file a complaint with the Philippine National Privacy Commission (NPC).

To exercise any of the above rights, please contact jl23's Data Protection Officer at [email protected]. jl23 will respond to verified requests within thirty (30) days as required by the DPA.

10. Children and Minors

10.1 The jl23 Platform is strictly restricted to persons aged twenty-one (21) years and older. jl23 does not knowingly collect personal data from persons under 21 years of age.

10.2 If jl23 becomes aware that personal data has been collected from a person under the age of 21 without appropriate verification, such data will be deleted promptly and the associated account will be closed.

11. Cross-Border Data Transfers

11.1 Some of jl23's service providers and game software partners are located outside the Philippines. Where personal data is transferred outside the Philippines, jl23 ensures that such transfers are made only to countries or recipients that provide an adequate level of data protection, or that appropriate safeguards are in place (such as data processing agreements incorporating standard contractual clauses), as required by the Philippine DPA.

12. Changes to This Privacy Policy

12.1 jl23 may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or business operations. Material changes will be communicated to registered players via your registered mobile number or email address, and a notice will be displayed on the Platform.

12.2 Your continued use of the jl23 Platform following notification of material changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

13. Contact and Data Protection Officer

jl23 has designated a Data Protection Officer (DPO) as required by the Philippine Data Privacy Act. For privacy-related inquiries, to exercise your data subject rights, or to report a potential data protection concern, please contact:

Data Protection Officer, jl23 Casino
Email: [email protected]
Response time: Within 30 days of receiving a verified request.

You also have the right to lodge a complaint directly with the Philippine National Privacy Commission if you believe your data privacy rights have been violated.