Privacy Policy — jl679

1. Introduction

This Privacy Policy ("Policy") describes how jl679 ("jl679", "we", "us", "our"), the operator of the online gaming platform at jl679.club (the "Platform"), collects, uses, stores, discloses, and protects the personal information of users ("Player", "User", "you") who register and interact with the Platform.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines. It is also consistent with the data governance requirements set by the Philippine Amusement and Gaming Corporation (PAGCOR) applicable to jl679's licensed operations.

By registering an account on jl679, you consent to the collection and processing of your personal data as described in this Policy. If you do not consent, please do not register or continue using the Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, jl679 is the Personal Information Controller ("PIC") in respect of all personal data collected through the jl679.club platform. All data protection inquiries, access requests, and correction requests should be directed to jl679's designated Data Protection Officer ("DPO") via the contact details provided in Section 13 of this Policy.

3. Personal Data We Collect

jl679 collects the following categories of personal data, depending on how you interact with the Platform:

jl679 does not collect sensitive personal information (as defined under Section 3(l) of the DPA) except where strictly required by law or regulatory obligation, such as the collection of a government ID for age and identity verification purposes.

4. How We Collect Personal Data

jl679 collects personal data through the following means:

• Direct submissions: Information you provide when registering, completing KYC, submitting withdrawal requests, or contacting support;
• Automated collection: Technical data collected automatically through cookies, server logs, and analytics tools when you visit jl679.club;
• Payment providers: Transaction confirmation data received from GCash, PayMaya, and banking partners when you make deposits or withdrawals;
• Third-party verification services: Identity verification data obtained from government database checks where permitted by law and required by PAGCOR compliance obligations.

5. Purpose & Legal Basis for Processing

jl679 processes your personal data for the following purposes and on the following legal bases under the Data Privacy Act of 2012:

• Account creation and management — Necessary for the performance of the contract between jl679 and the Player;
• Age and identity verification (KYC) — Legal obligation under PAGCOR regulations and the Anti-Money Laundering Act (AMLA, RA 9160 as amended);
• Payment processing — Necessary for the performance of the contract;
• Fraud prevention and anti-money laundering compliance — Legal obligation and legitimate interest of jl679;
• Responsible gaming tools administration — Legal obligation under PAGCOR guidelines and legitimate interest in player protection;
• Customer support — Legitimate interest in providing effective user assistance;
• Platform security and technical maintenance — Legitimate interest in maintaining a secure, stable platform;
• Marketing communications — Only with your explicit prior consent, which you may withdraw at any time.

6. Data Sharing & Disclosure

jl679 does not sell personal data to third parties. jl679 may share personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• PAGCOR and Philippine regulatory authorities: As required by law, licence conditions, or formal regulatory request;
• Anti-Money Laundering Council (AMLC): Reporting of covered and suspicious transactions in accordance with RA 9160, as amended by RA 10365;
• Payment service providers: GCash, PayMaya, BDO, BPI, Metrobank — to facilitate deposits and withdrawals;
• Game content providers: Game session data shared with licensed game studios (e.g., Pragmatic Play, Jili, PG Soft) solely to provide and audit game results;
• IT and security service providers: Third-party vendors engaged by jl679 to maintain platform infrastructure, fraud detection, and cybersecurity systems — subject to data processing agreements;
• Law enforcement and courts: Where disclosure is required by a valid court order, subpoena, or applicable Philippine law.

All third-party service providers engaged by jl679 are bound by contractual obligations to handle personal data only for the specified purpose and in compliance with the DPA.

7. Data Retention

jl679 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and identity records: Five (5) years from account closure, in compliance with AMLA record-keeping requirements;
• Transaction records: Five (5) years from the date of the transaction;
• Gaming logs: Three (3) years from the date of the gaming session;
• Support communications: Two (2) years from the date of the last interaction;
• Marketing consent records: For the duration of the consent plus two (2) years thereafter.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised unless retention is required by a specific legal obligation or ongoing regulatory investigation.

8. Cookies & Tracking Technologies

jl679 uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies: Necessary for the operation of the Platform (e.g., maintaining your login session). These cannot be disabled without impacting core functionality;
• Performance cookies: Collect aggregated, anonymised data about how players navigate the Platform to help jl679 improve user experience;
• Security cookies: Used to detect fraudulent login attempts and unauthorised account access;
• Preference cookies: Remember your language and display preferences between visits.

jl679 does not use third-party advertising or behavioural tracking cookies. You may manage cookie preferences through your browser settings. Disabling essential cookies may affect Platform functionality including the jl679 login process.

9. Data Security

jl679 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, and destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and jl679 servers;
• Encryption of sensitive data fields (including financial account details) at rest using industry-standard algorithms;
• Role-based access controls limiting internal staff access to personal data to those with a legitimate need;
• Regular security assessments and penetration testing of the Platform's infrastructure;
• Two-factor authentication (2FA) availability for all registered accounts.

In the event of a personal data breach that is likely to result in harm to affected individuals, jl679 will notify the National Privacy Commission and affected players within the timeframes prescribed by the Data Privacy Act and NPC Circular 16-03.

10. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights in respect of your personal data held by jl679:

• Right to be Informed: The right to know that your personal data is being collected and processed, and for what purpose — this Policy fulfils that obligation;
• Right to Access: The right to request a copy of the personal data jl679 holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure / Blocking: The right to request deletion or blocking of personal data that is no longer necessary, collected without consent, or processed unlawfully — subject to jl679's legal retention obligations;
• Right to Object: The right to object to processing based on legitimate interest, in particular direct marketing;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe jl679 has violated your data privacy rights.

To exercise any of these rights, please contact jl679's Data Protection Officer at [email protected] with your request. jl679 will respond within fifteen (15) business days of receiving a verifiable request.

11. Children's Privacy

jl679 does not knowingly collect personal data from individuals under the age of 21. The Platform is strictly intended for adults who meet the minimum age requirement imposed by PAGCOR regulations. If jl679 becomes aware that personal data of a minor has been collected, such data will be deleted immediately and the account will be permanently closed. Parents or guardians who believe a minor has registered on jl679 should contact support immediately.

12. Amendments to This Policy

jl679 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or regulatory guidance. Material changes will be communicated to registered users via the email address on file or through a prominent notice on the Platform. The "Last Updated" date at the top of this page indicates the date of the most recent revision. Continued use of the jl679 Platform following the effective date of any update constitutes acceptance of the revised Policy.

13. Contact & DPO Details

For all privacy-related enquiries, data access requests, or complaints regarding jl679's handling of your personal data, please contact our Data Protection Officer:

Email: [email protected]

Please include "Privacy Request" in the subject line and provide your registered account email address and a description of your request. jl679 will acknowledge receipt within three (3) business days and provide a substantive response within fifteen (15) business days.

If you are not satisfied with jl679's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.