Privacy Policy – JL39

1. Introduction

JL39 ("we," "us," "our," "the Platform") is committed to protecting the privacy and personal data of every player who uses the JL39 online gaming platform. This Privacy Policy describes how JL39 collects, uses, stores, shares, and protects personal information in connection with the operation of the JL39 website and mobile application, which are accessible to players in the Philippines and other permitted jurisdictions.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). JL39 is committed to upholding the data privacy rights of all individuals whose personal information it processes.

This Privacy Policy should be read together with the JL39 Terms and Conditions, which govern the overall relationship between JL39 and its registered players. Capitalised terms used but not defined in this Privacy Policy have the meanings given to them in the JL39 Terms and Conditions.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and applicable data protection legislation, JL39 is the personal information controller in respect of the personal data collected through the JL39 platform. JL39 determines the purposes and means of processing personal data collected from registered players and platform visitors.

JL39 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection law. Players who wish to exercise their data privacy rights or raise concerns about JL39's data processing practices may contact the JL39 DPO through the contact details provided in Section 14 of this Privacy Policy.

3. Personal Data We Collect

JL39 collects personal data from players through several channels, including account registration, identity verification, payment processing, gameplay activity, and customer support interactions. The categories of personal data collected by JL39 include:

JL39 collects only the personal data that is necessary for the purposes described in this Privacy Policy. Where JL39 is required by law or regulation to collect specific categories of personal data and you decline to provide it, JL39 may be unable to open or maintain your account or provide certain services.

JL39 does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. JL39 does not collect biometric data except where required by applicable KYC regulations and only through certified verification partners.

4. How JL39 Uses Your Personal Data

JL39 uses the personal data it collects for the following purposes:

• Account management: To create, verify, maintain, and administer your JL39 player account, including processing deposits, withdrawals, and bonus credits.
• Identity and age verification: To verify that you meet the eligibility requirements for using the JL39 platform, including the mandatory 21+ age requirement under Philippine gaming regulations.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment methods, and to maintain accurate financial records.
• Regulatory compliance: To comply with anti-money laundering (AML) obligations, PAGCOR reporting requirements, tax obligations, and other legal duties applicable to JL39 as an online gaming operator in the Philippines.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other security threats to the JL39 platform and its players.
• Customer support: To respond to your enquiries, resolve complaints, and provide technical assistance in connection with your use of the JL39 platform.
• Responsible gaming: To monitor gameplay patterns for indicators of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion requests.
• Platform improvement: To analyse usage data and player feedback in order to improve the functionality, performance, and content of the JL39 platform.
• Communications: To send you transactional notifications, account alerts, and — where you have provided consent — promotional communications about JL39 offers and new games.

JL39 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5. Legal Basis for Processing

JL39 processes personal data on the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary for the performance of the contract between JL39 and the player, including account registration, payment processing, and the provision of gaming services.
• Legal obligation: Processing is required for JL39 to comply with applicable laws and regulations, including AML obligations, PAGCOR licensing requirements, and tax reporting duties.
• Legitimate interests: Processing is necessary for the legitimate interests of JL39, including fraud prevention, platform security, and responsible gaming monitoring, provided that such interests are not overridden by the player's data privacy rights.
• Consent: Where JL39 relies on consent as the legal basis for processing — for example, in connection with marketing communications — you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Personal Data

JL39 does not sell, rent, or otherwise transfer your personal data to third parties for commercial or marketing purposes. JL39 may share your personal data with the following categories of recipients where necessary and lawful:

• Payment processors: JL39 shares the minimum necessary financial data with certified payment processors — including GCash, PayMaya, BPI, BDO, and Metrobank — to facilitate deposits and withdrawals. These processors are contractually bound to handle your data securely and in accordance with applicable law.
• Identity verification providers: JL39 uses third-party KYC and AML compliance providers to verify player identity and age. These providers process identity documents and verification data on behalf of JL39 under strict data processing agreements.
• Regulatory authorities: JL39 is required to share player data with PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities where required by law or regulatory instruction.
• Technology and hosting providers: JL39 uses third-party cloud hosting and technology infrastructure providers to operate the JL39 platform. These providers process data on behalf of JL39 and are bound by data processing agreements that require them to maintain appropriate security standards.
• Professional advisers: JL39 may share data with its legal, financial, and compliance advisers where necessary for the conduct of JL39's business, subject to professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of JL39's business, player data may be transferred to the acquiring entity, subject to the same privacy protections described in this Privacy Policy.

7. Data Retention

JL39 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account data: Retained for the duration of your JL39 account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AML regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations and tax law.
• KYC and verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant verification process, whichever is later.
• Customer support records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required in connection with an ongoing dispute or regulatory matter.
• Technical and usage data: Retained for up to two (2) years from the date of collection, after which it is anonymised or deleted.

Where JL39 is required by law to retain data for a longer period, the statutory retention period will apply. Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with JL39's data disposal procedures.

8. Cookies and Tracking Technologies

JL39 uses cookies and similar tracking technologies on the JL39 website and mobile application. Cookies are small text files placed on your device that help JL39 recognise you, maintain your session, and improve your experience on the platform. JL39 uses the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the operation of the JL39 platform. They enable core functions such as user authentication, session management, and security. These cookies cannot be disabled without affecting the functionality of the platform.
• Functional cookies: These cookies allow JL39 to remember your preferences — such as your preferred language and display settings — and provide a more personalised experience.
• Analytics cookies: JL39 uses analytics tools to collect aggregated, anonymised data about how players use the platform. This data helps JL39 understand which features are most popular and where improvements can be made. Analytics data is not linked to individual player identities.
• Security cookies: These cookies help JL39 detect and prevent fraudulent activity, unauthorised access attempts, and other security threats to the platform.

JL39 does not use advertising cookies or share cookie data with third-party advertising networks. You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the JL39 platform.

9. Data Security

JL39 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the JL39 platform.
• Encryption of sensitive data at rest, including account credentials and financial information.
• Role-based access controls that restrict access to personal data to authorised JL39 personnel on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the JL39 platform infrastructure.
• Multi-factor authentication requirements for access to JL39 administrative systems.
• Incident response procedures for the detection, containment, and reporting of personal data breaches in accordance with NPC notification requirements.

While JL39 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. JL39 cannot guarantee the absolute security of data transmitted over the internet. You are responsible for maintaining the security of your JL39 account credentials and for notifying JL39 immediately if you suspect any unauthorised access to your account.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, JL39 will notify the National Privacy Commission and affected players in accordance with the requirements of the Philippine Data Privacy Act and NPC Circular No. 16-03.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by JL39:

• Right to be informed: You have the right to be informed about how JL39 collects and processes your personal data, as set out in this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data that JL39 holds about you, together with information about how it is being processed.
• Right to rectification: You have the right to request that JL39 correct any inaccurate or incomplete personal data it holds about you. You can update certain account information directly through your JL39 account settings.
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to JL39's legal and regulatory retention obligations.
• Right to object: You have the right to object to the processing of your personal data where JL39 relies on legitimate interests as the legal basis for processing, and where your interests override those of JL39.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that JL39 transmit this data to another controller where technically feasible.
• Right to withdraw consent: Where JL39 processes your personal data on the basis of your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that JL39 has processed your personal data in a manner that violates the Philippine Data Privacy Act.

To exercise any of the above rights, please contact JL39 support using the contact details provided in Section 14 of this Privacy Policy. JL39 will respond to all data privacy requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. JL39 may request proof of identity before processing a data privacy request to ensure that personal data is not disclosed to unauthorised parties.

11. Children's Privacy and Age Restriction

The JL39 platform is strictly intended for adults aged 21 years and above. JL39 does not knowingly collect personal data from individuals under the age of 21. The 21+ age restriction is a mandatory requirement under Philippine gaming regulations and is enforced by JL39 through its account registration and KYC verification processes.

If JL39 becomes aware that it has inadvertently collected personal data from an individual under the age of 21, JL39 will take immediate steps to close the relevant account, delete the associated personal data, and — where required — report the matter to the relevant regulatory authority.

Parents and guardians who believe that a minor may have registered a JL39 account are encouraged to contact JL39 support immediately. JL39 will investigate all such reports promptly and take appropriate action.

12. International Data Transfers

JL39 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or technology partners located outside the Philippines — for example, in connection with cloud hosting or identity verification services — JL39 will ensure that such transfers are carried out in compliance with the Philippine Data Privacy Act and applicable NPC guidelines on cross-border data transfers.

JL39 will only transfer personal data to recipients in countries that provide an adequate level of data protection, or where appropriate safeguards — such as data processing agreements incorporating standard contractual clauses — are in place to protect the transferred data. JL39 will not transfer personal data to jurisdictions that do not provide adequate protection without first obtaining your explicit consent or establishing another lawful basis for the transfer.

13. Changes to This Privacy Policy

JL39 reserves the right to update or amend this Privacy Policy at any time to reflect changes in its data processing practices, applicable law, or regulatory requirements. The revised Privacy Policy will be published on the JL39 website with an updated effective date. Where changes are material, JL39 will notify registered players via the email address associated with their account prior to the changes taking effect.

Your continued use of the JL39 platform following the publication of a revised Privacy Policy constitutes your acknowledgement of the updated terms. JL39 recommends that all players review this Privacy Policy periodically to remain informed of how their personal data is being handled.

If you do not agree with any changes to this Privacy Policy, you should cease using the JL39 platform and may request account closure in accordance with the JL39 Terms and Conditions.

14. Contact and Data Privacy Requests

If you have any questions about this Privacy Policy, wish to exercise your data privacy rights, or want to raise a concern about JL39's data processing practices, please contact the JL39 Data Protection Officer using the details below.

JL39 Data Protection Officer email: [email protected]

General support email: [email protected]

Please include your registered JL39 username, a clear description of your request or concern, and any relevant reference numbers in all privacy-related communications. JL39 aims to acknowledge all privacy requests within three (3) business days and to provide a substantive response within fifteen (15) business days.

If you are not satisfied with JL39's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.

This Privacy Policy was last reviewed and updated in January 2026. JL39 recommends that all registered players review this policy periodically to stay informed of their data privacy rights and JL39's data handling practices.