jl25 Privacy Policy

1 About This Privacy Policy

1.1  This Policy applies to all personal data processed by jl25 in connection with the operation of jl25.asia and its associated services — including the casino game lobby, sports betting section, customer support, account management, and payment processing functions.

1.2  jl25 is committed to complying with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission of the Philippines ("NPC"). Where jl25 processes data of individuals in other jurisdictions, it applies a standard of protection no less stringent than that required by Philippine law.

1.3  This Policy should be read alongside the jl25 Terms & Conditions and any specific notices or consents presented to you at the time of collection, which may provide additional detail about particular processing activities.

2 Data Controller

2.1  For the purposes of applicable data privacy law, jl25 is the personal information controller (PIC) in respect of all personal data collected through jl25.asia. jl25 determines the purposes and means of processing personal data relating to its players, visitors, and support interactions.

2.2  jl25 has designated a Data Privacy Officer (DPO) who is responsible for overseeing compliance with applicable data privacy legislation, handling data subject rights requests, and serving as the point of contact for the National Privacy Commission. The DPO may be contacted via the email address listed in Section 14 of this Policy.

3 Personal Data We Collect

3.1  jl25 collects personal data through multiple channels and at different stages of your relationship with the platform. The categories of data we collect include:

A. Registration and Identity Data

• Full legal name;
• Date of birth (to verify you are 21 years of age or older);
• Philippine mobile number (used as your primary account identifier and for OTP delivery);
• Email address;
• Preferred username and encrypted password;
• Residential address and city (e.g., Manila, Cebu, Davao, Quezon City).

B. Identity Verification (KYC) Data

• Government-issued Philippine ID (e.g., PhilSys ID, passport, driver's license, SSS ID, GSIS ID, voter's ID, PRC ID) — including the ID image and the data encoded therein;
• Proof of address documentation where requested;
• Selfie or live video verification where required to match ID to account holder.

C. Financial and Transaction Data

• GCash, PayMaya, or bank account details used for deposits and withdrawals;
• Transaction history — deposit amounts, withdrawal requests, bet amounts, game outcomes;
• Cryptocurrency wallet addresses where used for transactions;
• Currency: all financial data is denominated in Philippine Peso (PHP).

D. Gaming Activity Data

• Games played, bet sizes, win/loss records, session durations;
• Sports bets placed, markets selected, odds at time of bet;
• Bonus and promotion activity, wagering requirement progress;
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status).

E. Technical and Usage Data

• IP address at login and during sessions;
• Device type, operating system, and browser type;
• Pages visited, features accessed, and session duration on jl25.asia;
• Cookie and similar tracking data (see Section 7).

F. Communications Data

• Live chat transcripts with jl25 support agents;
• Email correspondence with jl25 customer support and compliance teams;
• Feedback, complaints, and dispute records.

4 How We Use Your Personal Data

4.1  jl25 processes your personal data for the following purposes:

4.2  Where jl25 processes your data on the basis of legitimate interests, we have assessed that our interests do not override your fundamental rights and freedoms. You have the right to object to legitimate-interest processing as described in Section 10.

4.3  jl25 does not use automated decision-making that produces legal or similarly significant effects without human oversight, except for real-time fraud and AML screening systems where delay would create security risk. Where such automated screening results in an account action affecting you, you have the right to request human review.

5 Legal Basis for Processing

5.1  jl25 processes personal data only where a valid legal basis exists under the Philippine Data Privacy Act. The legal bases jl25 relies upon are:

• Contract performance: Processing necessary to provide the gaming services you registered for, process your transactions, and manage your account;
• Legal obligation: Processing required to comply with applicable Philippine law — including AML obligations, age verification requirements, and regulatory reporting;
• Legitimate interests: Processing for fraud prevention, platform security, service improvement, and responsible gaming monitoring — where jl25's interests are balanced against your privacy rights;
• Consent: Processing for direct marketing communications and personalized promotions, where you have provided explicit, freely given, informed, and specific consent. You may withdraw consent at any time.

5.2  If you withdraw consent for marketing communications, this does not affect the lawfulness of processing carried out prior to withdrawal, nor does it affect jl25's ability to contact you for account management or legal compliance purposes.

6 Sharing Your Personal Data

6.1  jl25 does not sell or rent personal data. We share personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment processors and e-wallet providers (including GCash, PayMaya, and participating Philippine banks — BPI, BDO, Metrobank, UnionBank) for the purpose of processing your deposits and withdrawals;
• Identity verification (KYC) service providers engaged to assist with document verification and age confirmation;
• Game content providers whose games are offered within the jl25 platform, to the limited extent required to operate certified RNG games;
• Fraud prevention and AML screening services used to identify unusual financial activity and protect the integrity of the platform;
• Regulatory and law enforcement authorities in the Philippines, where jl25 is legally required or compelled to disclose information — including the National Privacy Commission, relevant law enforcement agencies, and gaming regulatory bodies;
• Professional advisers including legal counsel, auditors, and compliance consultants, subject to applicable confidentiality obligations;
• IT and infrastructure service providers that support the operation of jl25.asia, under data processing agreements that restrict their use of your data.

6.2  All third parties with whom jl25 shares personal data are required to implement appropriate technical and organizational security measures and to use the data only for the specific purposes for which it was shared.

7 Cookies and Tracking Technologies

7.1  jl25 uses cookies and similar tracking technologies on jl25.asia to operate the platform, remember your preferences, maintain your session, and analyze how the platform is used. The categories of cookies used are:

• Strictly necessary cookies: Required for the platform to function — including session management, login state, and security tokens. These cannot be disabled without impairing core platform functionality;
• Functional cookies: Remember your preferences (e.g., game settings, preferred language) to improve your experience on return visits;
• Analytics cookies: Collect aggregated, anonymized data about how visitors use jl25.asia — pages visited, session durations, error rates — to help jl25 improve the platform;
• Security cookies: Used for fraud detection, bot identification, and suspicious activity monitoring.

7.2  jl25 does not use third-party advertising or tracking cookies that follow you across other websites. All analytics data collected via cookies is used solely for jl25's own internal purposes.

7.3  You may control cookie settings through your browser. Disabling strictly necessary cookies may affect your ability to use core jl25 platform features. On your first visit to jl25.asia, you will be presented with a cookie consent banner that allows you to manage non-essential cookie categories.

8 Data Security

8.1  jl25 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption in transit: All data transmitted between your browser and jl25 servers is encrypted using 256-bit TLS/SSL, the same standard used by Philippine banking applications;
• Encryption at rest: Sensitive data stored on jl25 servers — including KYC documents, financial records, and authentication credentials — is encrypted at rest;
• Access controls: Internal access to player data is restricted to authorized personnel on a strict need-to-know basis, with role-based access controls and full audit logging;
• Password security: Passwords are stored as salted one-way cryptographic hashes. jl25 staff cannot read your password;
• OTP verification: Sensitive account actions are protected by one-time PIN authentication sent to your registered Philippine mobile number;
• Regular security audits: jl25 conducts periodic vulnerability assessments and security reviews of its infrastructure and application code;
• Incident response: jl25 maintains a formal data breach response plan and will notify affected players and the NPC as required by applicable law in the event of a material breach.

9 Data Retention

9.1  jl25 retains personal data for as long as necessary to fulfill the purpose for which it was collected, comply with legal obligations, enforce our Terms & Conditions, and resolve disputes. The following general retention principles apply:

• Active account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in accordance with Philippine AML and gaming regulatory requirements;
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, as required by applicable law;
• Transaction records: Retained for a minimum of five (5) years, consistent with financial recordkeeping obligations under Philippine law;
• Support and communications records: Retained for three (3) years from the date of the interaction, or longer if required for a pending dispute or regulatory matter;
• Technical and usage logs: Retained for up to twelve (12) months for security monitoring and fraud detection purposes, after which they are deleted or anonymized;
• Marketing consent records: Retained for the duration of consent and for up to three (3) years following withdrawal of consent, as evidence of compliance.

9.2  Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized in accordance with jl25's data disposal procedures. Anonymized data — from which no individual can be identified — may be retained indefinitely for statistical and analytical purposes.

10 Your Privacy Rights

10.1  Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by jl25:

• Right to be informed: The right to know whether jl25 holds personal data about you, how it was collected, and for what purpose it is processed;
• Right to access: The right to request a copy of the personal data jl25 holds about you, and information about how it is processed;
• Right to rectification: The right to have inaccurate or incomplete personal data corrected. For minor corrections (e.g., contact details), you can update your data directly in your jl25 account settings;
• Right to erasure / blocking: The right to request the deletion or blocking of personal data where retention is no longer necessary, or where processing was unlawful. This right is subject to jl25's legal obligations to retain certain data under Philippine law;
• Right to object: The right to object to the processing of your personal data on the basis of legitimate interests. jl25 will cease such processing unless compelling legitimate grounds exist that override your objection;
• Right to data portability: The right to receive your personal data in a structured, commonly used format for transfer to another controller, where technically feasible;
• Right to withdraw consent: Where jl25 processes your data on the basis of consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing;
• Right to complain: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe jl25 has breached its data privacy obligations.

10.2  To exercise any of the above rights, contact jl25's Data Privacy Officer at the address provided in Section 14. jl25 will respond within thirty (30) days of receiving a verifiable request. Identity verification may be required before certain requests are fulfilled.

10.3  jl25 will not discriminate against you for exercising your privacy rights — exercising a privacy right will not affect your ability to use jl25 services, except where the erasure or blocking of data makes it technically impossible to continue providing a service that depends on that data.

11 Children's Privacy and Age Restrictions

11.1  jl25 is strictly an adults-only platform. The minimum age for creating and using a jl25 account is 21 years old, as required by Philippine gaming regulations.

11.2  jl25 does not knowingly collect personal data from individuals under 21 years of age. Where jl25 has reasonable grounds to believe that personal data has been submitted by or relates to a person under 21, that data will be deleted as quickly as possible and the associated account will be closed.

11.3  Age is verified during the account registration process and again at the KYC verification stage through government-issued Philippine ID. If you are a parent or guardian and believe a minor has accessed or registered on jl25.asia, please contact jl25 support immediately so the account can be investigated and closed.

12 International Data Transfers

12.1  jl25 primarily processes personal data within the Philippines. Where technical service providers or infrastructure partners maintain servers or processing facilities outside the Philippines, jl25 ensures that such transfers are protected by appropriate safeguards — including contractual data processing agreements that impose data protection standards consistent with Philippine law — prior to any transfer of personal data.

12.2  jl25 does not transfer personal data to countries or entities that do not provide an adequate level of data protection without implementing appropriate safeguards or obtaining your explicit consent to such transfer.

13 Changes to This Privacy Policy

13.1  jl25 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or operational requirements. The revised Policy will be published at jl25.asia/privacy-policy with an updated "Last Updated" date.

13.2  Where changes are material — particularly where they affect your rights or expand the categories of data collected — jl25 will provide at least 14 days' advance notice via your registered email address where reasonably practicable.

13.3  Your continued use of jl25 following the effective date of a revised Policy constitutes your acceptance of the changes. If you do not accept the changes, you should discontinue use and request account closure.

14 Contact and Complaints

14.1  For questions about this Privacy Policy, to exercise your data subject rights, or to report a privacy concern, contact jl25's Data Privacy Officer:

• Live chat: 24/7, accessible from within your jl25 account after login — fastest response channel
• Email: [email protected] — use subject line "Privacy Request" for data subject rights inquiries

14.2  jl25 will acknowledge privacy requests within 5 business days and provide a full response within 30 days. For complex requests, jl25 may extend the response period by a further 30 days with prior notice.

14.3  If you are not satisfied with jl25's response to a privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph). jl25 cooperates fully with NPC investigations.