jl97 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal information by jl97 ("jl97", "we", "us", "our") in connection with the operation of the jl97 online casino platform at https://jl97.club ("Platform"). jl97 is committed to processing personal data lawfully, fairly, and transparently in accordance with the Data Privacy Act of 2012 (Republic Act 10173, "DPA"), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all registered Players, visitors to jl97.club, and any other individuals whose personal data is processed by jl97 in connection with the Platform. By accessing jl97.club, registering an account, or placing any wager on jl97, you acknowledge that you have read, understood, and consent to the data practices described in this Policy.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, jl97 is the personal information controller responsible for your personal data collected through the jl97 Platform. jl97 operates under PAGCOR licensing and is subject to PAGCOR's data handling requirements in addition to the DPA.

Questions, requests, or complaints relating to this Policy or jl97's data processing practices may be directed to our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3. Categories of Personal Data We Collect

jl97 collects the following categories of personal data, depending on your relationship with the Platform:

jl97 does not collect sensitive personal information as defined under Section 3(l) of the DPA, except where required for age and identity verification purposes under PAGCOR KYC mandates (e.g., government ID numbers).

4. How We Collect Personal Data

jl97 collects personal data through the following channels:

• Direct Registration: When you create a jl97 account, you provide your mobile number, date of birth, and choose a username and password.
• KYC Verification: When you submit identity documents in response to jl97's verification request, we collect the personal data contained in those documents.
• Payment Transactions: When you make a deposit or withdrawal via GCash, Maya, BPI, BDO, or other payment channels, we receive confirmation data from the payment provider including reference numbers and account identifiers.
• Platform Use: When you play games, use live chat, access account settings, or browse jl97.club, we automatically collect Technical Data and Usage Data through server logs, cookies, and similar technologies.
• Communications: When you contact jl97 via live chat or email, the content of those communications is collected and stored.

5. Purposes of Processing

jl97 processes your personal data for the following specific purposes:

• Account Registration and Management: To create, maintain, and administer your jl97 account, including authentication and account security;
• Identity Verification (KYC): To verify your identity and age (21+) as required by PAGCOR licensing conditions and Philippine anti-money laundering regulations;
• Payment Processing: To process deposits, withdrawals, and to maintain accurate PHP wallet records in compliance with financial regulations;
• Game Provision: To deliver casino games, track gameplay results, calculate winnings, and apply bonus credits accurately;
• Responsible Gaming: To monitor player behavior for indicators of problem gambling, enforce deposit limits and self-exclusion requests, and fulfill PAGCOR's responsible gaming requirements;
• Legal Compliance: To comply with PAGCOR reporting obligations, Anti-Money Laundering Act (AMLA) requirements, NPC regulations, and court orders;
• Fraud Prevention: To detect, investigate, and prevent unauthorized account access, bonus abuse, collusion, and financial fraud;
• Customer Support: To respond to support inquiries, resolve disputes, and improve the quality of jl97's service;
• Platform Improvement: To analyze aggregated usage patterns and improve jl97's features, performance, and user experience;
• Marketing Communications: To send promotional offers, game announcements, and relevant updates to Players who have not opted out — subject to your communication preferences.

6. Legal Bases for Processing

jl97 processes personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent (Section 12(a), DPA): Where you have given your free, informed, and specific consent — for example, for marketing communications;
• Contractual Necessity (Section 12(b), DPA): Where processing is necessary to fulfill our obligations under the jl97 Terms & Conditions, including account administration, game delivery, and payment processing;
• Legal Obligation (Section 12(c), DPA): Where processing is required to comply with PAGCOR regulations, AMLA reporting requirements, or other applicable Philippine law;
• Legitimate Interests (Section 12(f), DPA): Where processing is necessary for jl97's legitimate interests — including fraud prevention, platform security, and service improvement — and those interests are not outweighed by your rights and freedoms.

7. Data Sharing and Disclosure

7.1 Third-Party Service Providers

jl97 shares personal data with third parties only where necessary for the operation of the Platform. These include: licensed game software providers (for game delivery and RNG certification), payment processors (GCash, Maya, BPI, BDO, and other accepted channels), cloud infrastructure providers hosting jl97's platform, and customer support software providers. All third-party processors are bound by data processing agreements requiring them to process jl97 player data only for the specific purposes instructed by jl97 and in compliance with Philippine data protection law.

7.2 Regulatory and Legal Disclosure

jl97 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), Philippine law enforcement agencies, and courts of competent jurisdiction where required or permitted by law. jl97 will not notify you of such disclosures where doing so would undermine an official investigation or is prohibited by law.

7.3 No Sale of Personal Data

jl97 does not sell, rent, lease, or trade your personal data to any third party for their own marketing or commercial purposes. This is an absolute commitment — not a policy subject to exceptions.

8. Data Retention

jl97 retains personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following minimum retention periods required by law:

• Account and Transaction Records: Minimum five (5) years from account closure, as required by PAGCOR licensing conditions and AMLA record-keeping obligations;
• KYC Identity Documents: Five (5) years from the date of submission or from the date of account closure, whichever is later;
• Financial Transaction Logs: Five (5) years in accordance with AMLA requirements;
• Support Communications: Two (2) years from the date of resolution, or longer if the communication relates to a pending dispute or legal proceeding;
• Technical and Usage Data: Up to twelve (12) months from collection, unless retained longer for fraud investigation or legal proceedings.

Upon expiry of the applicable retention period, jl97 will securely destroy or anonymize personal data in accordance with NPC-approved disposal procedures.

9. Data Security

jl97 implements industry-standard technical and organizational security measures to protect personal data against unauthorized access, loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jl97.club;
• Encrypted storage of Account passwords using one-way hashing algorithms;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Two-factor authentication (2FA) available for all Player accounts;
• Regular security audits and penetration testing of the jl97 platform;
• Incident response procedures aligned with NPC notification requirements in the event of a personal data breach.

While jl97 applies rigorous security standards, no system is completely impenetrable. Players are also responsible for maintaining the security of their own Account credentials.

10. Cookies and Tracking Technologies

jl97 uses cookies and similar tracking technologies on jl97.club for the following purposes:

• Essential Cookies: Required for the Platform to function — including session management, authentication, and security. These cannot be disabled without preventing Platform use.
• Analytics Cookies: Used to understand how Players interact with jl97.club — which pages are visited, how long sessions last, and how navigation flows. Data is aggregated and anonymized.
• Preference Cookies: Store your Platform preferences (e.g., language settings, game view preferences) to improve your experience across sessions.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using jl97, but may affect certain preference-based features.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl97:

• Right to be Informed: The right to know how your personal data is being collected and processed — which this Policy fulfills;
• Right to Access: The right to request a copy of the personal data jl97 holds about you;
• Right to Rectification: The right to request correction of inaccurate or outdated personal data in your jl97 Account;
• Right to Erasure: The right to request deletion of personal data where retention is no longer legally required — subject to jl97's legal retention obligations under PAGCOR and AMLA rules;
• Right to Restriction: The right to request restriction of processing in certain circumstances while a dispute is under investigation;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to Object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to Complain: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jl97 has violated your data privacy rights.

To exercise any of these rights, contact jl97's Data Protection Officer using the contact details in Section 14. jl97 will respond to data subject requests within fifteen (15) working days, or within the period permitted by NPC regulations for complex requests.

12. Children and Minors

jl97 is strictly an adult platform. jl97 does not knowingly collect personal data from any person under the age of 21. Registration is not permitted for persons under 21 years of age. If jl97 discovers that personal data has been collected from a person under 21, that Account will be suspended immediately and the data will be securely deleted, subject to any legal retention obligations that apply.

If you are a parent or guardian and believe that a minor has registered on jl97, please contact jl97 support immediately via live chat at jl97.club so that the Account can be reviewed and actioned without delay.

13. Changes to This Privacy Policy

jl97 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or regulatory guidance from PAGCOR or the NPC. When material changes are made, jl97 will notify registered Players via the mobile number associated with their Account and/or by displaying a prominent notice on jl97.club. The "Effective Date" at the top of this Policy will be updated accordingly. Your continued use of jl97 after the effective date of any update constitutes acceptance of the revised Policy.

14. Contact & Data Protection Officer

For all data privacy inquiries, access requests, rectification requests, complaints, or concerns relating to this Policy, please contact jl97 through the following channels:

• Data Protection Officer (DPO): Reachable via jl97 live chat (available 24/7 at jl97.club) or by email
• Email: [email protected] (plain text — not a clickable link)
• Support Hours: 8 AM – 12 MN (GMT+8, Manila time)
• Live Chat: Available 24/7 via jl97.club — preferred for urgent data privacy concerns

Complaints that cannot be resolved through jl97's internal process may be escalated to the National Privacy Commission of the Philippines through official NPC channels.