Privacy Policy
of jll96

This Privacy Policy describes how jll96 ("jll96", "we", "us", "our") collects, uses, stores, discloses, and protects the personal information of players and visitors who access the jll96 Platform at jll96.net. It applies to all interactions with jll96, including account registration, deposits, gameplay, withdrawals, customer support communications, and marketing preferences.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC) of the Philippines. It also reflects the data handling obligations imposed on jll96 under PAGCOR's licensing and anti-money laundering framework.

If you have any questions about this Policy or wish to exercise any of your data subject rights, please contact jll96's Data Protection Officer as detailed in Section 14 of this document.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, jll96 is the personal information controller in respect of all personal data collected through the jll96 Platform. As the personal information controller, jll96 determines the purposes for which personal data is collected and the means by which it is processed.

Where jll96 engages third-party service providers to process personal data on its behalf (for example, payment processors, game providers, fraud detection services), those entities act as personal information processors. jll96 ensures that all personal information processors are engaged under written agreements that impose equivalent data protection standards to those applied by jll96 directly.

jll96 has designated a Data Protection Officer (DPO) as required under the Data Privacy Act of 2012. Contact details for the DPO are set out in Section 14 of this Policy.

jll96 collects the minimum personal data necessary to operate the Platform, comply with applicable law, and provide a safe and personalised experience for players. The categories of personal data collected are as follows:

3.1 Registration and Identity Data

• Full legal name as appearing on government-issued identification
• Date of birth (to verify the 21+ age requirement mandated by PAGCOR)
• Gender
• Nationality and citizenship
• Registered email address
• Philippine mobile number
• Residential address (barangay, city/municipality, province)
• Username (chosen by you at registration)

3.2 KYC and Verification Data

• Government-issued photo identification (e.g., Philippine passport, UMID, PhilSys ID, SSS ID, driver's licence, PRC ID)
• Proof of address documentation (utility bill, bank statement, or government correspondence)
• Selfie or live photograph taken during verification
• Source of funds declaration (for high-value accounts as required by PAGCOR AML rules)

3.3 Financial and Transaction Data

• GCash account details (mobile number associated with your GCash wallet)
• PayMaya account details
• Bank account details (BPI, BDO, Metrobank, or other Philippine bank) where used for transactions
• Card number (last four digits only; full card numbers are handled by PCI-DSS-compliant payment processors and are not stored by jll96)
• Full deposit and withdrawal transaction history in PHP
• Wallet balance history

3.4 Gaming and Activity Data

• Complete bet history across all game types (slots, live casino, sports, instant win)
• Game session durations, bet amounts, and results
• Sports betting selections and odds accepted
• Bonus activations, wagering progress, and bonus redemption history
• Responsible gaming tool settings (deposit limits, session alerts, self-exclusion status)

3.5 Technical and Device Data

• IP address at time of registration and each subsequent login
• Device type, operating system, and browser version
• Device identifier (fingerprint) for fraud prevention
• Session timestamps and duration
• Approximate geographic location derived from IP address

3.6 Communications Data

• All support chat and email correspondence with the jll96 team
• Survey responses and feedback submitted through the Platform
• Marketing preference settings (opted-in communication channels)

jll96 collects personal data through the following channels:

jll96 does not collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act (such as health data, racial or ethnic origin, or religious beliefs) unless exceptionally required for responsible gaming assessments and only with your explicit consent.

jll96 processes your personal data only where a lawful basis under the Data Privacy Act of 2012 applies. The following table sets out the primary purposes for processing and the applicable legal basis:

5.1 Processing Purposes

• Account creation and management — To register and maintain your jll96 Account, authenticate your identity at login, and maintain your wallet. Legal basis: performance of contract.
• Payment processing — To process PHP deposits via GCash, PayMaya, BPI, BDO, Metrobank, and cards, and to execute withdrawal requests to your verified payment method. Legal basis: performance of contract; legal obligation (PAGCOR financial records requirements).
• Identity verification (KYC) — To verify your identity and age (21+) as required by PAGCOR regulations and Philippine AML law. Legal basis: legal obligation.
• Anti-money laundering compliance — To monitor transactions for suspicious activity and report as required by the Anti-Money Laundering Act (AMLA) and PAGCOR directives. Legal basis: legal obligation.
• Game provision and integrity — To provide gameplay, record results and bet history, and maintain the integrity of all gaming outcomes. Legal basis: performance of contract.
• Responsible gaming management — To implement and enforce deposit limits, self-exclusion, and other responsible gaming tools selected by or for you. Legal basis: legitimate interests; legal obligation (PAGCOR responsible gaming framework).
• Fraud prevention and security — To detect, investigate, and prevent fraud, account compromise, and prohibited conduct as defined in the jll96 Terms & Conditions. Legal basis: legitimate interests; legal obligation.
• Customer support — To respond to your enquiries, resolve disputes, and communicate relevant account information. Legal basis: performance of contract; legitimate interests.
• Marketing communications — To send you promotional offers, bonus notifications, and event communications via your preferred channels (email, SMS), where you have opted in. Legal basis: consent. You may withdraw consent at any time via your Account settings.
• Platform analytics and improvement — To analyse aggregated usage patterns for the purposes of improving the jll96 Platform. Legal basis: legitimate interests. Analytics use anonymised or pseudonymised data wherever possible.

jll96 uses cookies and similar tracking technologies on the Platform to enable core functionality, improve performance, and — where you have consented — to deliver relevant content. A cookie is a small text file stored by your browser when you visit a website.

6.1 Types of Cookies Used

• Strictly Necessary Cookies — Required for the Platform to function. These include session authentication tokens, CSRF protection cookies, and load-balancing identifiers. These cannot be disabled without breaking Platform functionality.
• Functional Cookies — Remember your preferences, such as your language setting, game lobby layout, and responsible gaming alerts. These improve your experience but are not essential.
• Analytics Cookies — Collect anonymised data about how the Platform is used (pages visited, session duration, navigation paths) to help jll96 improve performance and user experience. jll96 uses first-party analytics and does not share raw analytics data with advertising platforms.
• Security Cookies — Used for fraud detection, device fingerprinting for account security, and anomalous login detection.

6.2 Managing Cookies

You may manage non-essential cookies through your browser settings. Note that disabling functional or analytics cookies will not prevent you from using the Platform, but may affect your experience. Disabling strictly necessary cookies will prevent Platform login and core functions from operating correctly.

jll96 does not sell your personal data. We share personal data only in the circumstances described below, and only to the extent necessary for each purpose:

• Payment processors — GCash (Globe Fintech Innovations), PayMaya (PayMongo / Maya Bank), and banking partners (BPI, BDO, Metrobank) receive the transaction data necessary to process your deposits and withdrawals. These entities are independently regulated under Bangko Sentral ng Pilipinas (BSP) rules.
• Game providers — Third-party game studios whose titles are offered on jll96 receive the game session identifiers and bet data necessary to operate their games and settle results. Game providers do not receive your full identity data.
• KYC and fraud detection services — Identity verification partners receive document images and identity data for the purpose of verifying your identity and age. These partners operate under data processing agreements and are prohibited from using your data for their own purposes.
• PAGCOR and regulatory authorities — jll96 is required by law to provide personal data and transaction records to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities upon lawful request or as part of regular regulatory reporting obligations.
• Law enforcement — Where required by valid legal process (court order, lawful subpoena, or other compulsory legal authority), jll96 will disclose personal data to law enforcement agencies.
• Technology and infrastructure providers — Cloud infrastructure, cybersecurity, and IT support providers may have incidental access to personal data in the course of providing their services. All such providers are engaged under data processing agreements with appropriate security obligations.
• Professional advisers — Legal, accounting, and audit professionals engaged by jll96 may access personal data on a strictly confidential basis where necessary to provide their services.

jll96 retains personal data for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce the jll96 Terms & Conditions. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where legal obligations require data to be retained for specified minimum periods (such as AMLA's five-year record retention requirement), jll96 cannot delete data earlier even upon request, but will restrict processing to compliance purposes only during that period.

jll96 implements organisational and technical security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS 1.3) — All data transmitted between your device and jll96 servers is encrypted using industry-standard TLS 1.3 with certificate pinning on the Platform domain.
• Data at Rest Encryption — Databases storing personal and financial data are encrypted using AES-256 encryption. KYC documents are stored in encrypted, access-controlled vaults separate from general Platform databases.
• Access Controls — Access to personal data within jll96 is restricted to staff with a legitimate need-to-know. All access is authenticated, logged, and subject to regular access review.
• Two-Factor Authentication — All internal jll96 staff systems require multi-factor authentication. Players are strongly encouraged to enable 2FA on their Accounts.
• Vulnerability Management — jll96 conducts regular vulnerability assessments and penetration testing of Platform infrastructure. Critical vulnerabilities are remediated within defined service level timelines.
• Incident Response — jll96 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to affected individuals, jll96 will notify the National Privacy Commission within 72 hours and will notify affected players without undue delay as required by NPC Circular 16-03.
• Staff Training — All jll96 staff who handle personal data receive regular data privacy training covering their obligations under the Data Privacy Act and jll96's internal data handling policies.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by jll96. To exercise any of these rights, contact jll96's Data Protection Officer using the details in Section 14.

jll96 will respond to all data subject rights requests within 30 calendar days of receipt. Where the complexity or volume of requests requires additional time, jll96 will notify you within the initial 30-day period and provide an estimated resolution timeline not exceeding 60 days in total.

Note that some rights are subject to exceptions under the Data Privacy Act — for example, the right to erasure cannot override jll96's obligations under AMLA to retain transaction records for five years.

The jll96 Platform is strictly intended for persons aged 21 years and above, as mandated by PAGCOR regulations governing online gambling in the Philippines. jll96 does not knowingly collect personal data from persons under the age of 21.

Where jll96 becomes aware that personal data has been collected from a person under 21 — whether through underage registration or misrepresentation during account opening — the relevant Account will be immediately closed, all associated gaming activity will be voided, and the personal data of the minor will be deleted from jll96's systems within 30 days, subject only to any mandatory retention obligations imposed by law.

Parents or guardians who believe that a person under 21 has registered an Account on jll96 should contact jll96 support immediately at [email protected] for urgent assistance.

jll96 is a Philippine-operated platform. The majority of personal data processing occurs within the Philippines using infrastructure located in Philippine or regional data centres. However, some third-party service providers engaged by jll96 — such as cloud infrastructure providers, cybersecurity services, and certain game studio technical systems — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, jll96 ensures that such transfers are conducted only to jurisdictions or entities that provide an adequate level of data protection through one or more of the following safeguards:

• A National Privacy Commission-recognised adequacy determination for the destination country
• Standard contractual clauses or binding corporate rules approved by the NPC
• Contractual obligations requiring the recipient to apply data protection standards equivalent to those required under RA 10173

You may request details of the specific safeguards applied to any cross-border data transfers involving your personal data by contacting the jll96 Data Protection Officer.

jll96 reviews this Privacy Policy periodically and reserves the right to update it to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. The current version of this Policy is always available at jll96.net/privacy-policy, with the effective date stated at the top.

For material changes — particularly changes that affect what data we collect, how we use it, or your rights as a data subject — jll96 will notify registered players by email to the address registered on their Account at least 14 days before the changes take effect. Continued use of the jll96 Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms.

If you do not agree to a material change in this Privacy Policy, you may request closure of your jll96 Account by contacting support at [email protected]. Residual data retained solely to comply with legal obligations (such as AMLA transaction records) will continue to be held in accordance with Section 8 of this Policy.

jll96 has appointed a Data Protection Officer (DPO) as required under Section 21 of the Data Privacy Act of 2012. The DPO is responsible for ensuring that jll96 processes personal data in compliance with applicable privacy law, handling data subject rights requests, and acting as the primary point of contact with the National Privacy Commission.

For all privacy-related enquiries, data subject rights requests, and data breach notifications, please contact:

• Role: Data Protection Officer, jll96
• Email: [email protected] (subject line: "Data Privacy – DPO Request")
• Live Chat: Available 24/7 from within your logged-in jll96 Account
• Response Time: Acknowledgement within 3 business days; full response within 30 calendar days

If you are not satisfied with jll96's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines through their official channels.