Privacy Policy

1. Introduction

Welcome to jl12. This Privacy Policy ("Policy") describes how jl12 ("jl12," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you," "your," or "Player") who access or use the jl12 platform at https://jl12.app (the "Platform").

jl12 is committed to protecting your privacy and handling your personal data responsibly, transparently, and in full compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC") of the Philippines.

By registering an account on jl12 or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

This Policy should be read together with our Terms & Conditions, which govern your use of the Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, jl12 acts as the personal information controller ("PIC") with respect to the personal data collected through the Platform. As PIC, jl12 determines the purposes and means of processing your personal data.

jl12 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing the implementation of this Policy and ensuring compliance with applicable data privacy laws. Contact details for the DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

jl12 collects the following categories of personal data from players and visitors to the Platform:

3.1 Identity and Contact Information

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Gender
• Nationality and country of residence
• Email address
• Mobile phone number
• Residential address (including city, province, and postal code)

3.2 Identity Verification Documents

• Government-issued identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID)
• Proof of address documents
• Selfie or facial image for liveness verification (where required)

3.3 Financial Information

• GCash or PayMaya (Maya) account details (mobile number only; we do not store PINs or passwords)
• Bank account details for bank transfer transactions (account name and number)
• Transaction history, including deposits, withdrawals, and wager records

3.4 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, and features used
• Login timestamps and access logs
• Cookie identifiers and similar tracking data

3.5 Communications Data

• Records of communications with jl12 customer support, including live chat transcripts and email correspondence
• Feedback, survey responses, and promotional opt-in preferences

4. How We Collect Your Data

jl12 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, through cookies, log files, and similar technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from security partners; payment confirmation data from GCash, PayMaya, and banking partners.

5. Purpose of Processing

jl12 processes your personal data for the following specific, legitimate purposes:

6. Legal Basis for Processing

jl12 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary for the performance of the contract between you and jl12, including account management and payment processing.
• Legal obligation: Where processing is required to comply with applicable laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act.
• Legitimate interests: Where processing is necessary for the legitimate interests of jl12, such as fraud prevention, platform security, and responsible gaming monitoring, provided such interests are not overridden by your rights and freedoms.

7. Sharing and Disclosure of Your Data

jl12 does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

7.1 Service Providers and Processors

jl12 engages trusted third-party service providers who process personal data on our behalf, including KYC and identity verification providers, payment processors (GCash, PayMaya, and banking partners), cloud hosting and infrastructure providers, fraud detection and cybersecurity partners, and customer support platform providers. All such providers are bound by data processing agreements that require them to handle your data securely and only for the purposes specified by jl12.

7.2 Regulatory and Law Enforcement Authorities

jl12 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other government authorities where required by law, court order, or regulatory directive. Such disclosures will be limited to the minimum data necessary to satisfy the legal obligation.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of jl12's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Policy that may result from it.

7.4 No Cross-Border Transfers Without Safeguards

jl12 does not transfer your personal data outside the Philippines unless adequate safeguards are in place in accordance with the Data Privacy Act and NPC regulations. Where cross-border transfers are necessary, jl12 ensures that the recipient country provides an adequate level of data protection or that appropriate contractual safeguards are in place.

8. Data Retention

jl12 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by PAGCOR and AMLC regulations.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Technical and usage data: Retained for up to twelve (12) months, after which it is aggregated or anonymized.
• Marketing preferences: Retained until you withdraw your consent or request erasure.

Upon expiry of the applicable retention period, jl12 will securely delete or anonymize your personal data in accordance with NPC-approved disposal methods.

9. Data Security

jl12 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest using industry-standard algorithms.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While jl12 takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your jl12 account credentials and for notifying us immediately of any suspected unauthorized access to your account.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl12 will notify the NPC within seventy-two (72) hours of becoming aware of the breach and will notify affected data subjects without undue delay, in accordance with the Data Privacy Act and NPC Circular No. 16-03.

10. Cookies and Similar Technologies

jl12 uses cookies and similar tracking technologies (such as web beacons and local storage) to enhance your experience on the Platform, remember your preferences, maintain your session, and analyze how the Platform is used.

10.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how visitors use the Platform, helping us identify areas for improvement. No personally identifiable information is collected through analytics cookies.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

10.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the Platform and your ability to access some features. Refer to your browser's help documentation for instructions on managing cookie preferences.

11. Your 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 jl12:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as described in this Policy.
• Right of access: You have the right to request a copy of the personal data jl12 holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have 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 our legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14. jl12 will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12. Minors and Age Restriction

jl12 is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine law governing casino-style gambling. jl12 does not knowingly collect personal data from individuals under the age of 21.

If jl12 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on jl12, please contact us immediately at the details provided in Section 14.

Gambling is addictive. Know when to stop. For responsible gaming resources, visit our Responsible Gaming page.

13. Changes to This Privacy Policy

jl12 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. When we make material changes to this Policy, we will update the "Last Updated" date at the top of this page and, where appropriate, notify you by email or through a prominent notice on the Platform.

Your continued use of the Platform following the posting of any updated Privacy Policy constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how jl12 protects your personal data.

14. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by jl12, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the in-app chat feature

Our support and DPO team operates on Philippine time (PHT, UTC+8). We aim to acknowledge all privacy-related inquiries within two (2) business days and to resolve them within fifteen (15) business days.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.