jl45 Privacy Policy

1. Who We Are

jl45 ("jl45," "we," "us," or "our") operates the online gaming platform accessible at jl45.app (the "Platform"). jl45 is the personal information controller responsible for the collection, use, and protection of your personal data as described in this Privacy Policy.

This Privacy Policy applies to all personal information collected through the jl45 Platform, including through account registration, gameplay, financial transactions, customer support interactions, and any other use of our services. By registering for or using the jl45 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

jl45 is committed to complying with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC) of the Philippines.

2. Personal Data We Collect

jl45 collects only the personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

jl45 does not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance, in which case such collection will be clearly disclosed and subject to heightened protection measures.

3. How We Collect Your Data

jl45 collects personal data through the following channels:

• Direct interactions — when you register an account, complete identity verification, make a deposit or withdrawal, contact our support team, or respond to a survey.
• Automated technologies — when you use the Platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources — we may receive identity and financial verification data from regulated Philippine payment processors (e.g., GCash, Maya) and identity verification service providers, solely for KYC and AML compliance purposes.
• Regulatory sources — PAGCOR and other Philippine regulatory bodies may share information with jl45 as part of their oversight and enforcement functions.

4. How We Use Your Personal Data

jl45 uses your personal data for the following purposes:

• To create, verify, and manage your jl45 account, including age and identity verification in compliance with PAGCOR requirements.
• To process deposits and withdrawals through GCash, Maya, and Philippine bank transfers, and to maintain accurate financial records.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities in compliance with the Anti-Money Laundering Act.
• To provide customer support and resolve disputes, complaints, or account issues.
• To send you transactional communications — such as deposit confirmations, withdrawal notifications, and security alerts — that are necessary for the operation of your account.
• To send you promotional communications about jl45 bonuses, new games, and special offers, where you have provided consent or where permitted by applicable law. You may opt out at any time.
• To monitor gameplay patterns for responsible gaming purposes, including identifying players who may be at risk of problem gambling and applying appropriate interventions.
• To comply with our legal and regulatory obligations under Philippine law, including reporting obligations to PAGCOR and the AMLC.
• To improve the jl45 Platform through analysis of aggregated, anonymised usage data.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, jl45 processes your personal data on the following legal bases:

• Contractual necessity — processing is necessary to perform the contract between you and jl45 (i.e., to provide you with gaming services, process payments, and manage your account).
• Legal obligation — processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate interests — processing is necessary for jl45's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent — for marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent, which you may withdraw at any time.

6. Data Sharing & Disclosure

jl45 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances:

• Payment processors — GCash, Maya, and Philippine banking partners receive the minimum data necessary to process your deposits and withdrawals.
• Identity verification providers — regulated KYC service providers may process your identity documents solely for age and identity verification purposes.
• Game software providers — third-party game studios that power jl45's game library may receive anonymised session data necessary for game operation and fairness auditing.
• Regulatory authorities — PAGCOR, the AMLC, the National Privacy Commission, and other Philippine government bodies may receive your data as required by law or regulatory directive.
• Law enforcement — we will disclose personal data to Philippine law enforcement agencies when required by a valid court order, subpoena, or other lawful process.
• Business transfers — in the event of a merger, acquisition, or sale of all or part of jl45's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom jl45 shares personal data are required to process that data in accordance with the Philippine Data Privacy Act and are bound by appropriate data processing agreements.

7. Data Retention

jl45 retains your 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.

• Account and identity data is retained for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years as required by the Anti-Money Laundering Act of the Philippines.
• Customer support communications are retained for two (2) years from the date of the last interaction.
• Technical and usage data collected via cookies and server logs is retained for up to twelve (12) months, after which it is anonymised or deleted.

When your personal data is no longer required, jl45 will securely delete or anonymise it in accordance with our data disposal procedures.

8. Data Security

jl45 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jl45 Platform.
• Encryption of sensitive data at rest, including financial account details and identity documents.
• Role-based access controls ensuring that only authorised jl45 personnel can access personal data, and only to the extent necessary for their job function.
• Regular security assessments, penetration testing, and vulnerability scanning of the jl45 Platform and infrastructure.
• Multi-factor authentication (MFA) options available to all registered jl45 players to protect account access.
• A documented data breach response procedure, including notification to the National Privacy Commission and affected data subjects within the timeframes prescribed by the Data Privacy Act.

While jl45 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for keeping your jl45 login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.

9. Cookies & Tracking Technologies

jl45 uses cookies and similar tracking technologies to operate and improve the Platform, personalise your experience, and support our security and fraud-prevention systems. The types of cookies we use include:

• Strictly necessary cookies — essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings and responsible gaming limits.
• Analytics cookies — collect anonymised data about how players use the Platform to help us improve performance and user experience.
• Marketing cookies — used with your consent to deliver relevant jl45 promotions and measure the effectiveness of our campaigns.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the jl45 Platform. For marketing cookies, you may withdraw your consent at any time via your account settings.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl45:

• Right to be informed — you have the right to know what personal data jl45 collects about you and how it is used, as set out in this Privacy Policy.
• Right of access — you may request a copy of the personal data jl45 holds about you at any time.
• Right to rectification — you may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object — you may object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability — you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint — if you believe jl45 has violated your data privacy rights, you may file a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

To exercise any of the above rights, please contact the jl45 Data Privacy Officer at the email address provided in Section 13. jl45 will respond to all verified data subject requests within fifteen (15) business days, as required by the Data Privacy Act.

11. Children's Privacy

The jl45 Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with PAGCOR regulations governing online gaming in the Philippines. jl45 does not knowingly collect personal data from individuals under the age of 21.

If jl45 becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the personal data in question, and report the matter to PAGCOR as required. If you believe a minor has registered on the jl45 Platform, please contact us immediately at the details provided in Section 13.

12. Changes to This Privacy Policy

jl45 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Privacy Policy, jl45 will notify registered users via the email address or mobile number on file, or by posting a prominent notice on the Platform. Your continued use of the jl45 Platform after any amendment becomes effective constitutes your acceptance of the revised Privacy Policy.

13. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jl45, please contact our designated Data Privacy Officer:

Email: [email protected]

General support: [email protected]

Please include your registered username, a clear description of your request, and any relevant account details in all correspondence. jl45 aims to acknowledge all privacy-related enquiries within three (3) business days and to resolve them within fifteen (15) business days.