Privacy Policy

1. Introduction

jl003 ("jl003," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the jl003 online gaming platform at jl003.net (the "Platform"). This Privacy Policy ("Policy") describes how jl003 collects, uses, stores, shares, and protects personal information in connection with the operation of the Platform and the provision of our services to players in the Philippines and other permitted jurisdictions.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). It applies to all personal data collected through the jl003 Platform, including data collected via the website, mobile-optimized interfaces, customer support channels, and any other touchpoints through which jl003 interacts with players.

This Policy should be read in conjunction with jl003's Terms & Conditions, which govern the overall use of the Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, jl003 acts as the personal information controller ("PIC") in respect of the personal data collected through the Platform. As PIC, jl003 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable data protection laws.

jl003 has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection legislation. You may contact the DPO through the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

jl003 collects the following categories of personal data in connection with the operation of the Platform:

3.1 Registration and Identity Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (for age verification purposes — players must be 21 or older);
• Residential address, including barangay, city/municipality, province, and postal code;
• Email address and mobile phone number;
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys National ID);
• Proof of address documents (e.g., utility bills, bank statements);
• Proof of payment method ownership where required.

3.3 Financial and Transaction Data

• GCash account details, Maya account details, or bank account information used for deposits and withdrawals;
• Transaction history, including deposit amounts, withdrawal requests, and processing dates;
• Account balance information denominated in Philippine Peso (PHP).

3.4 Gaming Activity Data

• Game session logs, including games played, wager amounts, outcomes, and session durations;
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status).

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser information;
• Cookie identifiers and session tokens (see Section 8);
• Platform access logs and timestamps.

3.6 Communications Data

• Records of communications with jl003 customer support, including live chat transcripts and email correspondence;
• Feedback, complaints, and dispute records.

4. How We Collect Your Data

jl003 collects personal data through the following means:

• Directly from you — when you register for a jl003 Account, complete identity verification, make deposits or withdrawals, contact customer support, or interact with any promotional features on the Platform;
• Automatically — through cookies, log files, and similar tracking technologies when you access and navigate the jl003 Platform;
• From third parties — including identity verification service providers, payment processors (GCash, Maya, banks), fraud detection services, and PAGCOR where required by regulation.

5. How We Use Your Personal Data

jl003 uses the personal data we collect for the following purposes:

jl003 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.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, jl003 processes your personal data on the following legal bases:

• Contractual necessity — processing required to perform our obligations under the Terms & Conditions, including account management, payment processing, and game provision;
• Legal obligation — processing required to comply with applicable laws and regulations, including PAGCOR licensing requirements, AML obligations, and tax reporting;
• Legitimate interests — processing necessary for jl003's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights;
• Consent — processing based on your freely given, specific, informed, and unambiguous consent, including for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing and Disclosure

jl003 does not sell, rent, or trade your personal data to third-party marketers. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors — GCash, Maya, and partner banks for the processing of deposits and withdrawals;
• Identity verification providers — third-party KYC and AML service providers engaged to assist with regulatory compliance;
• IT and platform service providers — cloud hosting, cybersecurity, and software vendors who process data on jl003's behalf under data processing agreements;
• Regulatory authorities — PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other government bodies where disclosure is required by law or regulation;
• Law enforcement — where jl003 is legally compelled to disclose data in connection with a criminal investigation or court order;
• Professional advisers — lawyers, auditors, and accountants bound by professional confidentiality obligations.

All third-party service providers who process personal data on jl003's behalf are required to do so under written data processing agreements that impose data protection obligations consistent with the DPA and this Policy.

8. Cookies and Tracking Technologies

jl003 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you visit the jl003 website. The following categories of cookies are used:

• Strictly necessary cookies — essential for the Platform to function, including session authentication and security tokens. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings and game lobby layout to improve your experience.
• Analytics cookies — collect aggregated, anonymized data about how players use the Platform to help jl003 identify areas for improvement.
• Marketing cookies — used with your consent to deliver relevant promotional content about jl003 games and offers.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jl003 Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate securely.

9. Data Retention

jl003 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account and identity data — retained for the duration of your active jl003 Account and for a minimum of five (5) years following account closure, in compliance with AML and PAGCOR record-keeping requirements;
• Transaction and financial data — retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act;
• Gaming activity logs — retained for three (3) years from the date of the session;
• Customer support communications — retained for two (2) years from the date of the last communication;
• Marketing consent records — retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with jl003's data disposal procedures.

10. Data Security

jl003 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jl003 Platform;
• Encryption of sensitive data at rest, including KYC documents and financial account details;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Regular security vulnerability assessments and penetration testing;
• Multi-factor authentication for administrative access to systems containing personal data;
• Staff training on data protection obligations and secure data handling practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl003 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay where required by the DPA.

11. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jl003:

• Right to be informed — the right to be notified of how your personal data is collected and processed, as set out in this Policy;
• Right of access — the right to request a copy of the personal data jl003 holds about you;
• Right to rectification — the right to request correction of inaccurate or incomplete personal data;
• 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, subject to jl003's legal retention obligations;
• Right to object — the right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability — the right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint — the right to lodge a complaint with the National Privacy Commission if you believe jl003 has processed your personal data in violation of the DPA.

To exercise any of the above rights, please contact jl003's Data Protection Officer using the contact details in Section 15. jl003 will respond to all data subject requests within thirty (30) days of receipt. We may require you to verify your identity before processing your request.

12. Children's Privacy

jl003 employs age verification measures during the registration process to prevent underage individuals from accessing the Platform. If jl003 becomes aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete such data and close the associated account.

If you believe that jl003 may have inadvertently collected personal data from a minor, please contact us immediately using the details in Section 15.

13. International Data Transfers

jl003 primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines — for example, cloud infrastructure providers or international KYC service providers — jl003 ensures that such transfers are carried out in accordance with the requirements of the DPA, including by implementing appropriate safeguards such as contractual data protection clauses.

jl003 will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

14. Changes to This Privacy Policy

jl003 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is indicated at the top of this document.

Where changes are material, jl003 will provide reasonable advance notice to registered players via email or a prominent notice on the Platform. Your continued use of the jl003 Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request closure of your Account.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or jl003's handling of your personal data, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are unsatisfied with jl003's response to your privacy concern.