Privacy Policy – jlaaa

1 Introduction

This Privacy Policy applies to all personal data collected and processed by jlaaa ("we", "us", "our") in connection with the operation of the jlaaa online gaming platform accessible at jlaaa.net. It covers data collected through the website, the jlaaa mobile app, customer support interactions, and any other channel through which you engage with jlaaa.

jlaaa operates in the Philippines and processes personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its implementing rules and regulations. We are committed to ensuring that your personal information is collected lawfully, stored securely, and used only for the purposes described in this policy.

This Privacy Policy should be read alongside jlaaa's Terms and Conditions and Responsible Gaming Policy. If you have any questions about how jlaaa handles your personal data, please refer to the Contact section at the end of this document.

2 Personal Data We Collect

jlaaa collects personal data from you in several ways: directly when you register or interact with the platform, automatically through your use of the website or app, and occasionally from third-party sources such as payment processors and identity verification services.

The categories of personal data jlaaa may collect include:

jlaaa does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by law or regulatory obligation (for example, in the context of responsible gaming assessments).

3 How jlaaa Uses Your Personal Data

jlaaa uses the personal data we collect for specific, legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was originally collected. The primary purposes for which jlaaa processes your personal data are:

• Account Registration and Management: To create and maintain your jlaaa player account, verify your identity, and manage your account settings and preferences.
• Transaction Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods, and to maintain accurate financial records.
• Legal and Regulatory Compliance: To fulfil our obligations under Philippine law, including the Data Privacy Act of 2012, Anti-Money Laundering Act (AMLA), and applicable PAGCOR regulations. This includes conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit and loss limits, and administer self-exclusion requests in accordance with our Responsible Gaming Policy.
• Platform Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other security threats to the jlaaa platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide assistance with your jlaaa account.
• Platform Improvement: To analyse usage patterns and technical performance data to improve the jlaaa platform, fix bugs, and enhance the overall player experience.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012 and applicable data protection principles, jlaaa processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and jlaaa – specifically, to operate your player account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including KYC/AML obligations, age verification requirements, and PAGCOR regulatory requirements.
• Legitimate Interests: Processing is necessary for jlaaa's legitimate interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and interests.
• Consent: For certain processing activities, such as sending marketing communications or using non-essential cookies, jlaaa relies on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 Sharing Your Personal Data

jlaaa does not share your personal data with third parties except in the circumstances described below. In all cases, jlaaa ensures that appropriate data protection safeguards are in place before any data is shared.

• Payment Processors: jlaaa shares necessary financial data with payment service providers such as GCash, PayMaya, and partner banks (BPI, BDO, Metrobank) to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity Verification Services: jlaaa may share identity documents and related data with third-party KYC and AML compliance service providers to verify your identity and comply with regulatory requirements.
• Regulatory and Law Enforcement Authorities: jlaaa may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities where required by law or in response to a lawful request.
• Technology and Infrastructure Providers: jlaaa uses third-party technology providers for hosting, data storage, and platform infrastructure. These providers process data on jlaaa's behalf and are contractually bound to handle it in accordance with this Privacy Policy.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of jlaaa's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

6 Cookies and Tracking Technologies

jlaaa uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse how players use our services. A cookie is a small text file placed on your device when you visit the jlaaa website or use the jlaaa app.

The types of cookies jlaaa uses include:

• Strictly Necessary Cookies: These are essential for the jlaaa platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymised information about how players use jlaaa, such as which pages are visited most frequently and whether error messages are received. This data helps jlaaa improve the platform experience.
• Functional Cookies: These cookies allow jlaaa to remember your preferences, such as your preferred language or display settings, to provide a more personalised experience.
• Marketing Cookies: With your consent, jlaaa may use cookies to deliver relevant promotional content and measure the effectiveness of marketing campaigns. You may opt out of marketing cookies at any time through your browser settings or the jlaaa cookie preference centre.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the jlaaa platform. For more information on managing cookies, refer to your browser's help documentation.

7 Data Retention

jlaaa retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active jlaaa account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements.
• Transaction Records: Financial transaction data is retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC and Verification Documents: Identity verification documents are retained for a minimum of five (5) years following the end of the business relationship, or longer if required by law.
• Customer Support Records: Communications with jlaaa's support team are retained for up to three (3) years from the date of the interaction.
• Marketing Data: Data used for marketing purposes is retained until you withdraw your consent or opt out of marketing communications, after which it is deleted or anonymised within a reasonable timeframe.

When personal data is no longer required, jlaaa will securely delete or anonymise it in accordance with our internal data disposal procedures. Anonymised data that can no longer be linked to an individual may be retained indefinitely for statistical and analytical purposes.

8 Your Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jlaaa. To exercise any of these rights, please contact jlaaa's Data Protection Officer using the details provided in Section 12.

• Right to be Informed: You have the right to be informed about how jlaaa collects and uses 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 jlaaa holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request that jlaaa correct any inaccurate or incomplete personal data held about you. You may also update certain account details directly through your jlaaa account settings.
• Right to Erasure: You have the right to request that jlaaa delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to jlaaa's legal and regulatory retention obligations.
• Right to Object: You have the right to object to jlaaa's processing of your personal data where that processing is based on legitimate interests, including the right to object to direct marketing at any time.
• 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 it be transmitted to another data controller where technically feasible.
• Right to Lodge a Complaint: If you believe that jlaaa has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

9 Data Security

jlaaa takes the security of your personal data seriously. We implement a range of technical and organisational measures designed to protect your information against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption of data in transit using industry-standard TLS (Transport Layer Security) protocols across all jlaaa web and app connections.
• Encryption of sensitive data at rest, including financial information and identity documents stored on jlaaa's servers.
• Strict access controls ensuring that only authorised jlaaa personnel with a legitimate need can access personal data, on a need-to-know basis.
• Regular security assessments, vulnerability testing, and penetration testing of the jlaaa platform and infrastructure.
• Multi-factor authentication options for player accounts to reduce the risk of unauthorised access.
• Staff training on data protection obligations and security best practices.

While jlaaa takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jlaaa will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

You also play an important role in keeping your jlaaa account secure. Please ensure that you use a strong, unique password for your jlaaa account, do not share your login credentials with anyone, and contact jlaaa support immediately if you suspect any unauthorised access to your account.

10 Children's Privacy and Age Restrictions

The jlaaa platform is strictly intended for adults aged 21 years and above. jlaaa does not knowingly collect personal data from individuals under the age of 21. The minimum age requirement of 21 years is enforced in accordance with PAGCOR regulations governing online gaming in the Philippines.

As part of the registration process, jlaaa requires all players to confirm that they are at least 21 years of age. jlaaa also conducts age verification checks as part of the KYC process, which may include requesting a government-issued photo ID such as a Philippine passport, SSS ID, UMID, or driver's licence.

11 Changes to This Privacy Policy

jlaaa reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, jlaaa will notify registered players by email or through a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how jlaaa protects your personal data. Your continued use of the jlaaa platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms.

If you do not agree with any changes to this Privacy Policy, you should cease using the jlaaa platform and may request account closure by contacting our support team.

12 Contact and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or jlaaa's handling of your personal data, please contact our Data Protection Officer (DPO). jlaaa has appointed a dedicated DPO to oversee compliance with the Data Privacy Act of 2012 and to handle all data subject requests.

You may contact the jlaaa Data Protection Officer by email at: [email protected]

For general account support and enquiries, you may also reach the jlaaa customer support team at: [email protected]

Please note that all email addresses are displayed as plain text for security purposes and are not clickable links. jlaaa will never ask you to send passwords, full payment card details, or other sensitive credentials via email.

For matters relating to your rights under the Data Privacy Act of 2012, or if you wish to lodge a formal complaint, you may also contact the National Privacy Commission of the Philippines directly. For responsible gaming concerns, please visit our Responsible Gaming page.