jl23 Privacy Policy

This Privacy Policy ("Policy") describes how jl23 ("jl23," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal information of users ("you," "Player," or "User") who access or use the jl23 online casino platform at jl23.org (the "Platform").

This Policy applies to all personal data processed by jl23 in connection with your use of the Platform, including data collected during account registration, identity verification, gameplay, payment transactions, customer support interactions, and marketing communications.

jl23 is committed to protecting your privacy and handling your personal data responsibly, transparently, and in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

jl23 collects personal data through various means, including information you provide directly, data generated through your use of the Platform, and information received from third parties. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Registration data: Full name, date of birth, gender, nationality, email address, mobile number, and residential address.
• Identity verification (KYC) data: Government-issued ID (e.g., Philippine passport, PhilSys ID, SSS ID, driver's license), selfie or live photo, proof of address documents, and source of funds documentation where required.
• Payment data: GCash mobile number, PayMaya account details, bank account information (account name, account number, bank name). jl23 does not store full card numbers or CVV codes.
• Communications data: Messages, emails, and chat transcripts exchanged with jl23 customer support.
• Responsible gaming data: Self-exclusion requests, deposit limit preferences, and cooling-off period settings.

2.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages visited, games played, session duration, click patterns, and navigation paths within the Platform.
• Transaction data: Deposit and withdrawal history, game wager history, bonus usage, and account balance records.
• Location data: General geographic location derived from IP address for regulatory compliance and fraud prevention purposes.
• Cookie data: Information collected through cookies and similar tracking technologies as described in Section 8 of this Policy.

2.3 Data from Third Parties

• Identity verification results from KYC service providers.
• Fraud risk scores and AML screening results from compliance service providers.
• Payment confirmation data from GCash, PayMaya, and banking partners.
• Publicly available information used for enhanced due diligence where required by law.

jl23 uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your jl23 player account, including processing your registration and verifying your identity.
• Service delivery: To provide access to jl23 games, process deposits and withdrawals, and deliver the features and functionality of the Platform.
• Regulatory compliance: To fulfill our obligations under the Philippine Data Privacy Act, Anti-Money Laundering Act, and applicable PAGCOR regulations, including KYC verification, AML screening, and transaction monitoring.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible gaming: To implement and manage responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent. You may opt out at any time through your account settings.
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the jl23 Platform.
• Legal proceedings: To establish, exercise, or defend legal claims where necessary.

jl23 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given clear, informed consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary to perform our contract with you, including providing gaming services, processing payments, and managing your account.
• Legal obligation: Where processing is required to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR requirements, and tax reporting.
• Legitimate interests: Where processing is necessary for jl23's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.

jl23 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients:

5.1 Service Providers

jl23 engages trusted third-party service providers to assist in delivering the Platform, including KYC and identity verification providers, payment processors (GCash, PayMaya, banking partners), cloud hosting and infrastructure providers, customer support platform providers, and fraud detection and AML screening services. All service providers are contractually required to process your data only on jl23's instructions and to maintain appropriate security measures.

5.2 Regulatory and Law Enforcement Authorities

jl23 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities where required by law, court order, or regulatory directive.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of jl23's assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the privacy practices of the new entity prior to the transfer taking effect.

jl23 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years after account closure, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for compliance documentation.
• Technical and usage logs: Retained for up to twelve (12) months, unless required for longer periods for security investigations.

Upon expiry of the applicable retention period, jl23 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

jl23 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS 1.3 encryption for all data transmitted between your device and the jl23 Platform.
• AES-256 encryption for personal and financial data stored at rest.
• Multi-factor authentication options for player accounts.
• Regular security audits and penetration testing by independent third parties.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Continuous monitoring for suspicious activity and unauthorized access attempts.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl23 will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Philippine Data Privacy Act.

jl23 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly necessary cookies: Required for the Platform to function correctly, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and game display options to personalize your experience.
• Analytics cookies: Collect anonymized data about how players use the Platform to help us improve performance and user experience.
• Security cookies: Used for fraud detection, bot prevention, and to protect the integrity of the Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jl23 Platform. jl23 does not use third-party advertising cookies or share cookie data with advertisers.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl23:

To exercise any of these rights, please contact jl23's Data Protection Officer at privacy at jl23.org. jl23 will respond to your request within thirty (30) days. We may require identity verification before processing your request. Some requests may be subject to legal retention obligations that override your right to erasure.

The jl23 Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. jl23 does not knowingly collect personal data from individuals under 21 years of age.

If jl23 becomes aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on jl23, please contact us immediately at support at jl23.org.

jl23 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. When we make material changes, we will notify you via the Platform or by email to your registered address at least fourteen (14) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the jl23 Platform after the effective date of any revision constitutes your acceptance of the updated Policy. We encourage you to review this page periodically.

If you have any questions, concerns, or requests regarding this Privacy Policy or jl23's data practices, please contact our Data Protection Officer:

• Data Protection Officer Email: privacy at jl23.org
• General Support Email: support at jl23.org
• Live Chat: Available 24/7 via the jl23 Platform

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated. Information about the NPC and its complaint procedures is available through official Philippine government channels.