jlphcom Privacy Policy

1 Introduction

1.1 jlphcom is committed to protecting the privacy and security of your personal data. We recognise that Filipino players entrust us with sensitive information when they register an account, make deposits, and engage in gaming activity on our platform. We take that trust seriously.

1.2 This Policy applies to all personal data collected through the jlphcom website at jlphcom.net, any associated mobile web interface, our customer support channels, and all related services. It applies to registered players, prospective players who browse the platform, and individuals who contact our support team.

1.3 This Policy should be read alongside jlphcom's Terms and Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference.

1.4 jlphcom's data handling practices are guided by the principles of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

2 Data Controller

2.1 jlphcom is the data controller responsible for the personal data processed under this Policy. As data controller, jlphcom determines the purposes for which and the means by which your personal data is processed.

2.2 If you have any questions, concerns, or requests relating to your personal data, you may contact our Data Protection Officer (DPO) via email. Contact details are provided in Section 14 of this Policy.

2.3 jlphcom has appointed a Data Protection Officer in accordance with the requirements of the Philippine Data Privacy Act. The DPO is responsible for overseeing compliance with this Policy and applicable data protection legislation.

3 Personal Data We Collect

3.1 jlphcom collects the following categories of personal data from players:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify you are 21 years of age or older);
• Gender;
• Nationality and country of residence;
• Residential address, including barangay, city or municipality, and province.

3.2 Contact Data

• Philippine mobile number;
• Email address;
• Preferred communication language.

3.3 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, PhilSys ID, driver's licence, SSS/GSIS ID, voter's ID, PRC ID);
• Proof of address documentation where required;
• Source-of-funds documentation for large deposits or where required by our AML procedures.

3.4 Financial Data

• Payment method details (e.g., GCash mobile number, Maya account reference, bank account details for BPI/BDO transfers) — stored only as references, never full account credentials;
• Transaction history including deposit amounts, withdrawal amounts, and dates;
• Wagering history and game play records.

3.5 Technical & Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type;
• Session duration and login timestamps;
• Pages visited, game sessions initiated, and feature interactions;
• Referring URLs.

3.6 Communications Data

• Records of communications between you and jlphcom customer support, including live chat transcripts and email correspondence;
• Survey responses and feedback submissions.

4 How We Collect Your Data

4.1 jlphcom collects personal data through the following means:

• Direct submission: When you register an account, complete KYC verification, make a deposit, request a withdrawal, or contact customer support, you provide data directly to us;
• Automated collection: When you use the platform, our servers and analytics tools automatically collect technical and usage data as described in Section 3.5;
• Cookies and similar technologies: As described in Section 9 of this Policy;
• Third-party verification providers: We may receive identity verification results from third-party KYC service providers engaged to assist in document authentication;
• Payment processors: Payment confirmation data is transmitted to us by GCash, Maya, GrabPay, BPI, BDO, and other payment providers when you complete a transaction.

5 Purpose & Legal Basis for Processing

5.1 jlphcom processes your personal data for specific, legitimate purposes. The table below sets out the primary purposes for which we process personal data and the legal basis for each:

5.2 Where jlphcom processes your data on the basis of legitimate interest, we have assessed that our interests are not overridden by your rights and interests as a data subject. You may request details of any legitimate interest assessment by contacting our DPO.

5.3 Where processing is based on your consent (e.g., for marketing), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

6.1 jlphcom does not sell, rent, or trade your personal data to third parties. We share your data only in the following limited circumstances:

6.1 Service Providers

We engage trusted third-party service providers who process data on our behalf under binding data processing agreements. These include identity verification providers, payment processors (GCash, Maya, GrabPay, BPI, BDO, 7-Eleven CLiQQ), cloud hosting providers, customer support software vendors, and fraud detection services. These providers may only process your data for the specific purposes instructed by jlphcom and may not use it for their own purposes.

6.2 Regulatory and Legal Authorities

jlphcom may be required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts of competent jurisdiction where required by applicable Philippine law, regulation, or legal process.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a material portion of jlphcom's assets, your personal data may be transferred to the acquiring entity. jlphcom will provide notice of any such transfer and ensure the receiving entity is bound by privacy obligations consistent with this Policy.

7 Data Retention

7.1 jlphcom retains your personal data for as long as is necessary to fulfil the purposes set out in this Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements.

7.2 The following general retention periods apply:

• Account and KYC data: Retained for a minimum of 5 years from the date of account closure, in accordance with AML and regulatory record-keeping obligations;
• Transaction and financial records: Retained for a minimum of 5 years from the date of the transaction;
• Customer support communications: Retained for 3 years from the date of the communication, or longer if the matter relates to an ongoing dispute;
• Technical and usage data: Retained for up to 24 months from the date of collection, unless required for longer for fraud investigation purposes;
• Marketing consent records: Retained until consent is withdrawn and for 1 year thereafter as evidence of the consent history.

7.3 At the end of the applicable retention period, jlphcom will securely delete or anonymise your personal data in accordance with our data disposal procedures.

8 Data Security

8.1 jlphcom implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure.

8.2 Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and jlphcom servers;
• Encryption of sensitive data at rest, including identity documents and payment references;
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need;
• Multi-factor authentication requirements for internal systems accessing personal data;
• Regular security audits and penetration testing of our platform and infrastructure;
• Staff training on data protection obligations and secure data handling procedures;
• Incident response procedures for the prompt detection, containment, and reporting of personal data breaches.

8.3 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jlphcom will notify the National Privacy Commission and affected players in accordance with the timeframes and requirements of the Philippine Data Privacy Act and its Implementing Rules and Regulations.

8.4 While jlphcom takes all reasonable measures to protect your data, no security system is impenetrable. You are responsible for maintaining the confidentiality of your account credentials and for using strong, unique passwords for your jlphcom account.

9 Cookies & Similar Technologies

9.1 jlphcom uses cookies and similar tracking technologies (collectively, "cookies") on the jlphcom platform. A cookie is a small text file stored on your device when you visit a website. Cookies allow us to recognise your browser and remember certain information.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as your chosen language, display settings, and game history. Disabling these may affect your experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the platform, which helps us improve performance and usability. We use privacy-respecting analytics tools hosted on our own infrastructure.

9.2 jlphcom does not use advertising or retargeting cookies. We do not allow third-party advertising networks to set cookies on the jlphcom platform.

9.3 You may control cookies through your browser settings. Please note that disabling cookies beyond strictly necessary ones may affect the functionality of certain features on the jlphcom platform.

10 Your Data Protection Rights

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jlphcom:

• Right to be Informed: The right to be informed about the manner in which your personal data is being processed, including the purposes and legal basis for processing — as set out in this Policy;
• Right of Access: The right to obtain confirmation of whether jlphcom holds your personal data and to receive a copy of that data;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or completed. For basic account information, you may update your data directly through your account settings;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where consent has been withdrawn, or where processing is unlawful. Please note this right is subject to jlphcom's legal and regulatory retention obligations;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller where technically feasible;
• Right to Object: The right to object to processing of your personal data carried out on the basis of legitimate interest, including direct marketing;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jlphcom has handled your personal data unlawfully.

10.2 To exercise any of the rights above, please contact our Data Protection Officer using the contact details in Section 14. jlphcom will respond to valid requests within 15 business days. We may ask you to verify your identity before processing a request.

11 Marketing Communications

11.1 jlphcom may send you promotional and marketing communications about our games, bonuses, and platform updates where you have opted in to receive such communications during registration or through your account settings.

11.2 Marketing communications may be sent via SMS to your registered Philippine mobile number, via email to your registered email address, or via in-platform notifications when you are logged in to jlphcom.

11.3 You may withdraw your consent to receive marketing communications at any time by:

• Updating your notification preferences in your jlphcom account settings;
• Clicking the unsubscribe link included in any marketing email;
• Contacting jlphcom customer support and requesting removal from marketing lists.

11.4 Withdrawal of marketing consent will not affect the delivery of transactional communications that are necessary for the operation of your account, such as deposit confirmations, withdrawal notifications, and security alerts.

12 Minors & Age Restriction

12.1 jlphcom's platform is strictly intended for individuals who are 21 years of age or older. jlphcom does not knowingly collect personal data from individuals under 21 years of age.

12.2 If jlphcom becomes aware that personal data has been collected from an individual under 21 years of age, we will immediately close the relevant account, return any deposited funds to the original payment source, and securely delete the personal data collected, except where retention is required by law.

12.3 Parents and guardians who believe a minor has registered an account with jlphcom are urged to contact our customer support team immediately at the email address provided in Section 14 of this Policy.

13 Changes to This Privacy Policy

13.1 jlphcom reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements.

13.2 When material changes are made to this Policy, jlphcom will notify registered players via the email address on their account and/or via an in-platform notification at least 7 days before the changes take effect, except where immediate changes are required for legal, regulatory, or security reasons.

13.3 The date at the top of this Policy indicates when it was last updated. Continued use of the jlphcom platform after an updated Policy has taken effect constitutes your acceptance of the revised terms.

13.4 We encourage you to review this Policy periodically to stay informed about how jlphcom is protecting your personal data.

14 Contact Us

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or jlphcom's handling of your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Privacy Policy Enquiry / Data Subject Request
• Response Time: jlphcom will acknowledge your enquiry within 2 business days and provide a full response within 15 business days.

14.2 You may also contact jlphcom's customer support team via live chat available directly within the platform 24 hours a day, 7 days a week, for general privacy-related queries.