jl4com Privacy Policy

1 Who We Are

jl4com ("jl4com," "we," "us," or "our") operates the online casino and sports betting platform accessible at jl4com.app. jl4com serves Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and other regions throughout Luzon, Visayas, and Mindanao.

For the purposes of this Privacy Policy, jl4com is the data controller responsible for the personal information collected through the jl4com platform. This means we determine the purposes and means by which your personal data is processed.

This Privacy Policy applies to all personal data collected through the jl4com website, mobile platform, customer support channels, and any other jl4com service. It should be read alongside our Terms & Conditions, which govern your use of the jl4com platform.

2 Personal Data We Collect

jl4com collects the following categories of personal data from players and visitors to the platform:

jl4com does not collect sensitive personal information (as defined under the Philippine Data Privacy Act) unless strictly required for identity verification or legal compliance purposes, and only with your explicit consent where required.

3 How We Collect Your Data

jl4com collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access and use the jl4com platform, including through cookies, web beacons, and similar tracking technologies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud and risk data from payment processors; publicly available information where relevant to account security or legal compliance.
• Payment Processors: Transaction confirmation and payment status data from GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard when you make deposits or request withdrawals.

4 How We Use Your Personal Data

jl4com uses your personal data for the following purposes:

• Account Management: To register, verify, and maintain your jl4com account, including processing your login credentials and account settings.
• Identity & Age Verification: To verify that you are at least 21 years of age and to confirm your identity in compliance with Philippine law and PAGCOR responsible gaming standards.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, and to maintain accurate financial records.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other security threats.
• Legal & Regulatory Compliance: To comply with applicable Philippine laws, including the Data Privacy Act of 2012, Anti-Money Laundering Act, and PAGCOR responsible gaming requirements.
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance through live chat and email support.
• Responsible Gaming: To monitor gaming patterns and identify players who may be at risk of problem gambling, and to administer self-exclusion and deposit limit tools.
• Platform Improvement: To analyze usage patterns and improve the jl4com platform, games, and services for all Filipino players.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may opt out at any time.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, jl4com processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you — i.e., to provide the jl4com gaming platform and associated services as described in our Terms & Conditions.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations, age verification requirements, and PAGCOR compliance.
• Legitimate Interests: Processing necessary for jl4com's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Sharing Your Personal Data

jl4com does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing your financial transactions.
• Identity Verification Providers: Third-party KYC service providers who assist jl4com in verifying player identity and age in compliance with Philippine law.
• Fraud Prevention Services: Third-party risk and fraud detection providers who help jl4com identify and prevent fraudulent activity on the platform.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who support the operation of the jl4com platform under strict data processing agreements.
• Regulatory Authorities: Philippine government agencies, including the National Privacy Commission, PAGCOR, and the Anti-Money Laundering Council (AMLC), where disclosure is required by law or regulatory directive.
• Legal Advisors: Legal counsel and professional advisors where necessary for the protection of jl4com's legal rights or in connection with legal proceedings.

All third-party service providers engaged by jl4com are contractually required to process your personal data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable Philippine data protection law.

7 Cookies & Tracking Technologies

jl4com uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and analyze platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the jl4com platform, including session management, login authentication, and security functions. These cookies cannot be disabled without affecting core platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings, display preferences, and responsible gaming limits you have set on your account.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the jl4com platform, helping us identify areas for improvement. No personally identifiable information is shared through analytics cookies.
• Marketing Cookies: Used to deliver relevant promotional content and bonus offers to you based on your activity on the jl4com platform. These cookies are only placed with your consent.

You can manage or disable non-essential cookies at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the jl4com platform. For detailed information on the specific cookies we use, please refer to our Cookie Notice available in your account settings.

8 Data Retention

jl4com retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account Data: Retained for the duration of your active account and for a minimum of 5 years following account closure, in compliance with Philippine anti-money laundering regulations and PAGCOR requirements.
• Transaction Records: Financial transaction records are retained for a minimum of 5 years from the date of the transaction, as required by the Anti-Money Laundering Act of the Philippines.
• KYC & Identity Documents: Retained for a minimum of 5 years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Live chat transcripts and support emails are retained for up to 3 years from the date of the interaction for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Records of your marketing consent or opt-out are retained for the duration of your account and for 3 years following account closure.
• Technical & Usage Data: Aggregated and anonymized usage data may be retained indefinitely for platform analytics purposes. Personally identifiable technical data is retained for up to 12 months.

When personal data is no longer required, jl4com will securely delete or anonymize it in accordance with our internal data retention and disposal procedures.

9 Data Security

jl4com implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and the jl4com platform is encrypted using industry-standard SSL/TLS protocols.
• Secure Data Storage: Personal and financial data is stored on secure, access-controlled servers with restricted personnel access on a strict need-to-know basis.
• Two-Factor Authentication: jl4com supports two-factor authentication (2FA) for player accounts to provide an additional layer of login security.
• Regular Security Audits: jl4com conducts periodic security assessments and penetration testing to identify and address potential vulnerabilities in our systems.
• Staff Training: All jl4com personnel who handle personal data receive regular training on data protection obligations and security best practices.
• Incident Response: jl4com maintains a data breach response procedure. In the event of a personal data breach that poses a risk to your rights, we will notify the National Privacy Commission and affected players in accordance with the requirements of the Philippine Data Privacy Act.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl4com:

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data jl4com holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• 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 jl4com's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on jl4com's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe jl4com has not handled your personal data in accordance with applicable law.

To exercise any of these rights, please contact jl4com's Data Protection Officer using the contact details provided in Section 14 of this policy. We will respond to all verified data rights requests within 30 days of receipt.

11 Children's Privacy

The jl4com platform is strictly intended for adults aged 21 years and above. jl4com does not knowingly collect personal data from any person under the age of 21. This requirement is consistent with Philippine law governing online gambling and PAGCOR responsible gaming standards.

If jl4com becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the relevant personal data, and take appropriate steps in accordance with our legal obligations. Any funds held in such an account may be forfeited.

If you are a parent or guardian and believe that a person under 21 in your care has registered an account with jl4com, please contact our support team immediately at [email protected] so that we can take prompt action.

12 International Data Transfers

jl4com's primary operations and data storage are based in the Philippines. In some cases, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international payment networks.

Where such transfers occur, jl4com ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses that require the recipient to maintain standards equivalent to those required under the Philippine Data Privacy Act of 2012.

jl4com will not transfer your personal data to any jurisdiction that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

13 Changes to This Privacy Policy

jl4com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform services. When material changes are made, we will notify registered players via the email address or mobile number associated with their jl4com account at least 7 days before the changes take effect.

The most current version of this Privacy Policy will always be available on this page. The "Last updated" date at the top of this page indicates when the policy was most recently revised. We encourage all jl4com players to review this policy periodically to stay informed about how we protect their personal data.

Your continued use of the jl4com platform following notification of changes to this Privacy Policy constitutes your acceptance of the revised policy. If you do not agree to the updated policy, you must stop using the platform and may request account closure by contacting our support team.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or jl4com's handling of your personal data, please contact our Data Protection Officer (DPO) through the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line for faster routing to our DPO team.
• Live Chat: Available 24/7 directly from your jl4com account dashboard. Our support team can escalate privacy-related inquiries to the DPO.
• Response Time: jl4com aims to acknowledge all privacy-related inquiries within 24 hours and to provide a substantive response within 30 days of receipt.

If you are not satisfied with jl4com's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory body responsible for administering and enforcing the Philippine Data Privacy Act of 2012.