jl19 Privacy Policy

This Privacy Policy (the "Policy") is issued by jl19 (the "Company," "We," "Us," or "Our"), the operator of the online gaming and sports betting platform accessible at jl19.club (the "Site" or "Platform"). This Policy describes how jl19 collects, uses, stores, discloses, and otherwise processes personal data relating to users of the jl19 platform, including registered account holders, visitors who browse the Site without registering, and any individual who interacts with jl19 through any channel.

This Policy applies to all personal data processed by jl19 in connection with the operation of the Site and its associated services, including account registration and management, payment processing, customer support, promotional communications, and regulatory compliance activities. It applies regardless of the device or browser used to access the jl19 platform.

This Policy should be read alongside jl19's Terms & Conditions, which govern your overall use of the Platform. In the event of any conflict between this Policy and the Terms regarding privacy matters, this Policy shall prevail.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, jl19 acts as the Personal Information Controller (PIC) with respect to the personal data of its users. As the PIC, jl19 determines the purposes and means of processing personal data collected through the jl19 platform.

Certain processing activities — specifically those conducted by third-party payment processors, game providers, and technology service providers acting under jl19's direction — are performed by these parties as Personal Information Processors (PIPs). jl19 ensures that all PIPs are bound by contractual data processing agreements that require them to maintain standards of data protection consistent with this Policy and applicable Philippine law.

Contact details for data privacy inquiries are provided in Section 13 of this Policy.

jl19 collects personal data through multiple channels, including account registration forms, payment transactions, gameplay activity, customer support interactions, and automated technical means. The categories of personal data we collect are as follows:

jl19 uses the personal data it collects for the following purposes, each of which corresponds to a lawful processing basis described in Section 5:

• Account Management: Creating, maintaining, and administering your jl19 account, including verifying your identity, processing login authentication, and handling account settings changes;
• Payment Processing: Processing deposits and withdrawal requests, verifying payment method ownership, and maintaining transaction records required by financial regulations;
• Identity Verification (KYC): Complying with PAGCOR's Know Your Customer requirements, verifying that account holders meet the 21+ age requirement, and satisfying anti-money-laundering (AML) obligations;
• Gameplay Services: Providing access to jl19's game library, recording wager outcomes, applying bonus credits, and tracking VIP loyalty points;
• Customer Support: Responding to inquiries, resolving disputes, processing complaints, and maintaining records of support interactions;
• Security & Fraud Prevention: Detecting and preventing unauthorized account access, fraudulent transactions, bonus abuse, and other prohibited activities;
• Regulatory Compliance: Meeting obligations under PAGCOR regulations, Philippine AML law, and the Data Privacy Act, including reporting obligations to competent authorities where required by law;
• Service Improvement: Analyzing aggregated gameplay and usage data to improve the jl19 platform, identify technical issues, and develop new features;
• Marketing Communications: Sending promotional emails, SMS, or in-platform notifications about bonuses, promotions, and new games — where you have provided consent and have not subsequently opted out.

jl19 does not use your personal data for any purpose not listed above without providing prior notice and, where required by law, obtaining your consent.

In accordance with Section 13 of the Data Privacy Act of 2012, jl19 processes personal data only where at least one of the following lawful bases applies:

• Contract Performance: Processing is necessary to perform the contract between jl19 and you (i.e., the Terms & Conditions), including account management, game access, payment processing, and support services;
• Legal Obligation: Processing is necessary for jl19 to comply with applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), and data retention requirements;
• Legitimate Interests: Processing is necessary for jl19's legitimate interests in security, fraud prevention, platform improvement, and business operations, where these interests are not overridden by your privacy rights;
• Consent: For non-essential processing activities, such as marketing communications, jl19 will obtain your specific, informed, and freely given consent before processing, and will honor any withdrawal of that consent promptly.

jl19 does not sell, rent, or trade your personal data. We may share your personal data with the following categories of third parties, strictly for the purposes described:

• Payment Processors: GCash (Mynt - Globe Fintech Innovations, Inc.), Maya (Voyager Innovations, Inc.), BPI, BDO, Metrobank, and other payment processors listed in our Cashier section receive the financial data necessary to process your deposit and withdrawal transactions. These processors operate under their own privacy policies and applicable Philippine law.
• Game Providers: Technology providers such as JILI Games, PG Soft, Pragmatic Play, and others receive your account identifier and wager data solely to deliver gameplay services and record game outcomes. They do not receive your identity or contact data unless specifically required by their platform architecture.
• Identity Verification Services: Third-party KYC providers may receive your identity document data to process verification checks on jl19's behalf. These providers are bound by strict data processing agreements.
• Cloud & Infrastructure Providers: jl19 uses cloud computing and hosting services. These providers may process technical data as part of providing infrastructure, under contractual obligations consistent with this Policy.
• Regulatory Authorities: jl19 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or Philippine law enforcement where required or permitted by law.
• Legal Advisors: In connection with legal proceedings or regulatory inquiries, jl19 may share relevant data with legal counsel and advisors under professional confidentiality obligations.

In all cases of third-party disclosure, jl19 limits the data shared to the minimum necessary for the stated purpose and requires receiving parties to maintain appropriate data security standards.

jl19 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small data files stored on your device by your browser when you visit the Site. The types of cookies used by jl19 are:

• Strictly Necessary Cookies: These are essential for the jl19 platform to function. They enable login session management, security token validation, and payment flow continuity. These cookies cannot be disabled without significantly impairing the Site's functionality.
• Functional Cookies: These cookies remember your preferences — such as language settings and last-visited game category — to provide a more personalized experience on jl19.
• Analytics Cookies: jl19 uses aggregated, anonymized analytics data to understand how users interact with the Site. This helps us identify technical issues, optimize page performance, and improve the overall user experience.
• Session Cookies: Temporary cookies deleted when you close your browser, used to maintain your jl19 session during active use.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your jl19 account.

jl19 retains personal data only for as long as it is necessary to fulfil the purposes for which it was collected or to comply with applicable legal, regulatory, and contractual obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active jl19 account and for a period of five (5) years following account closure, in compliance with PAGCOR's record-keeping requirements and Philippine AML regulations.
• Transaction Records: Deposit and withdrawal records are retained for a minimum of five (5) years following the transaction date, in accordance with the Anti-Money Laundering Act.
• KYC Documents: Identity verification documents are retained for the period required under PAGCOR regulations, typically five (5) years from the date of verification.
• Gameplay Logs: Game session records are retained for five (5) years to support dispute resolution, auditing, and regulatory compliance.
• Support Communications: Customer support records are retained for three (3) years following the closure of the relevant support case.
• Marketing Consent Records: Records of marketing consent and opt-out requests are retained for the duration of your account and for three (3) years following account closure.

Following the expiry of applicable retention periods, jl19 will securely delete or anonymize your personal data in accordance with standard data destruction practices.

jl19 implements a range of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, alteration, or disclosure. These measures include:

• Transport Encryption: All data transmitted between your device and jl19 servers is encrypted using Transport Layer Security (TLS) protocol, the industry standard for securing web communications;
• Data Encryption at Rest: Sensitive personal and financial data stored on jl19 infrastructure is encrypted at rest using industry-standard encryption algorithms;
• Access Controls: Access to personal data within jl19's systems is restricted to authorized personnel on a need-to-know basis, enforced through role-based access controls and multi-factor authentication for administrative systems;
• Two-Factor Authentication: jl19 offers OTP-based two-factor authentication for player logins from unrecognized devices, adding a layer of protection even if your password is compromised;
• Penetration Testing: jl19 conducts periodic security assessments and penetration tests to identify and remediate vulnerabilities in the platform;
• Incident Response: jl19 maintains a documented data breach response procedure. In the event of a confirmed data breach that poses a risk to your rights, jl19 will notify you and the National Privacy Commission within the timeframes required by the Data Privacy Act.

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you — as a data subject — have the following rights with respect to your personal data held by jl19:

To exercise any of the above rights, please contact jl19's Data Protection Officer as described in Section 13. jl19 will acknowledge your request within three (3) business days and provide a substantive response within fifteen (15) business days, or within such extended timeframes as permitted by the Data Privacy Act where the complexity of the request warrants it.

The jl19 platform is strictly prohibited for use by persons under 21 years of age. jl19 does not knowingly collect personal data from individuals below the age of 21. The minimum age restriction is mandated by PAGCOR regulations governing online gaming in the Philippines and is a fundamental eligibility requirement for holding a jl19 account.

jl19 implements age verification measures at account registration and may require documentary proof of age at any point. If jl19 discovers or has reasonable grounds to believe that personal data has been collected from a person below 21 years of age, jl19 will:

• Immediately suspend the account in question;
• Delete all personal data associated with the account to the extent permitted by legal retention obligations;
• Refund any net balance to the payment method used for deposit, where the funds can be verified as belonging to a legal guardian or adult account holder;
• Report the incident to PAGCOR and, where appropriate, to the National Privacy Commission.

jl19 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, PAGCOR regulatory requirements, or operational procedures. The "Last Updated" date at the top of this document will be revised upon each modification.

Material changes to this Policy — particularly those that affect how we use your personal data in ways you would not reasonably expect — will be communicated to registered jl19 account holders via the email address or mobile number associated with their account, or via a prominent in-platform notification. Where required by the Data Privacy Act, jl19 will obtain fresh consent for any new processing activities that the amendment introduces.

We encourage you to review this Privacy Policy periodically. Your continued use of the jl19 platform following the publication of an updated Policy constitutes your acknowledgment of the changes. If you do not agree with any amendment, you may close your account in accordance with jl19's Terms & Conditions.

For any privacy-related questions, requests, or concerns — including the exercise of data subject rights described in Section 10 — please contact jl19's Data Protection Officer (DPO) through the following channels:

• Email: [email protected] — use subject line "Data Privacy Request" for all formal DPA-related inquiries to ensure prioritized routing to the DPO;
• Live Chat: Available 24/7 on the jl19 platform for general privacy inquiries. For formal data subject access requests, email contact is preferred to create a documented record;

jl19 will acknowledge privacy requests within three (3) business days of receipt. Where a request requires identity verification before data can be disclosed or deleted, jl19 will request appropriate verification documentation within that initial acknowledgment.