jli3 Privacy Policy

1. Introduction

jli3 ("jli3", "we", "us", "our") operates the online gaming platform accessible at jli3.app and is committed to protecting the privacy and personal data of all users ("Player", "you", "your") who access or use our services. This Privacy Policy ("Policy") describes how jli3 collects, processes, stores, shares, and protects personal information in connection with your use of the jli3 platform, including all games, account features, promotions, and customer support services.

This Policy is drafted in compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). It also reflects jli3's obligations under PAGCOR's data governance requirements applicable to licensed online gaming operators.

By registering an account on jli3 or continuing to use the jli3 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 any part of this Policy, please discontinue use of jli3 immediately.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, jli3 acts as the Personal Information Controller with respect to the personal data of its registered players and website visitors. jli3 determines the purposes and means of processing personal data collected through the jli3 platform.

All data-related inquiries, requests, and complaints may be directed to jli3's designated Data Protection Officer ("DPO") using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

jli3 collects the following categories of personal data from players and website visitors:

3.1 Identity & Contact Information

• Full legal name as it appears on a government-issued ID;
• Date of birth (used to verify the 21+ age requirement);
• Nationality and country of residence;
• Residential address (barangay, city/municipality, province, ZIP code);
• Email address;
• Mobile phone number.

3.2 Identity Verification Documents

• Copies of government-issued identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID, PRC ID, voter's ID);
• Proof of address documents where required for enhanced KYC;
• Selfie or liveness verification images where required.

3.3 Financial Information

• GCash or Maya mobile wallet account details (account name and registered number);
• Bank account details for bank transfer transactions (account name, bank name, account number);
• Debit card details (card number, expiry — stored in tokenised form only);
• Transaction history including deposits, withdrawals, and gaming activity.

3.4 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session logs, login timestamps, and activity records;
• Game play history, bet amounts, and outcomes;
• Cookies and similar tracking technologies (see Section 10).

3.5 Communications Data

• Records of communications with jli3 customer support, including chat transcripts and email correspondence;
• Feedback, survey responses, and promotional opt-in preferences.

jli3 does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive information is collected (e.g., government ID numbers), it is handled with heightened security measures.

4. How We Collect Your Data

jli3 collects personal data through the following means:

• Account Registration: Information you provide when creating your jli3 account;
• KYC Verification: Documents and images submitted during identity verification;
• Deposits & Withdrawals: Payment details provided during financial transactions;
• Platform Usage: Automatically collected technical and gameplay data as you use jli3;
• Customer Support: Information shared when you contact jli3 support;
• Promotions & Surveys: Data provided when you participate in jli3 promotions or complete surveys;
• Third-Party Verification Services: Identity and fraud-check data received from authorised KYC and AML service providers.

5. How We Use Your Personal Data

jli3 processes your personal data for the following purposes:

jli3 will not use your personal data for any purpose incompatible with those listed above without first obtaining your explicit consent or as otherwise required by law.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, jli3 processes your personal data on the following legal bases:

• Consent: Where you have given explicit consent, such as for marketing communications or optional data collection;
• Contractual Necessity: Processing required to fulfil our obligations under the jli3 Terms & Conditions, including account management and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws;
• Legitimate Interests: Processing necessary for jli3's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.

7. Sharing Your Data

jli3 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 only to the extent necessary for the purposes described in this Policy:

• KYC & AML Service Providers: Third-party identity verification and anti-money laundering screening providers engaged to assist with regulatory compliance;
• Payment Processors: GCash, Maya, and banking partners required to process your deposits and withdrawals;
• Game Providers: Licensed game studios and live casino operators whose games are hosted on the jli3 platform, to the extent necessary for game delivery and fairness auditing;
• IT & Security Providers: Cloud hosting, cybersecurity, and fraud detection service providers operating under strict data processing agreements;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law or court order;
• Professional Advisers: Legal counsel, auditors, and accountants bound by professional confidentiality obligations.

All third-party service providers engaged by jli3 are required to process personal data only on jli3's instructions and in accordance with applicable data protection laws. jli3 does not authorise any third party to use your personal data for their own independent purposes.

8. Data Retention

jli3 retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods include:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Customer support communications: Retained for three (3) years from the date of the last interaction;
• Marketing preferences: Retained until you withdraw consent or request deletion, whichever is earlier.

Upon expiry of the applicable retention period, jli3 will securely delete or anonymise your personal data in accordance with its data disposal procedures, unless further retention is required by a specific legal obligation.

9. Data Security

jli3 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and jli3's servers;
• Encryption of sensitive data at rest, including financial credentials and identity documents;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to jli3's systems;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jli3 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.

While jli3 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your jli3 login credentials confidential and for notifying jli3 immediately if you suspect any unauthorised access to your account.

10. Cookies & Tracking Technologies

jli3 uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyse usage patterns, and deliver a personalised experience. The types of cookies used on jli3 include:

• Strictly Necessary Cookies: Essential for the platform to function, including session management and security tokens. These cannot be disabled;
• Functional Cookies: Remember your language preferences, display settings, and login state to improve your experience;
• Analytics Cookies: Collect anonymised data about how players use jli3 to help us improve the platform's performance and content;
• Marketing Cookies: Used to deliver relevant promotional content based on your activity on jli3, where you have consented to receive marketing communications.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jli3 platform. jli3 does not use cookies to collect personal data beyond what is described in this Policy.

11. Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jli3:

• Right to be Informed: The right to know what personal data jli3 collects and how it is processed — as set out in this Policy;
• Right of Access: The right to request a copy of the personal data jli3 holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• 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, subject to jli3's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe your data rights have been violated.

To exercise any of the above rights, please contact jli3's Data Protection Officer using the details in Section 15. jli3 will respond to all verified data rights requests within fifteen (15) business days. We may request proof of identity before processing your request to protect against unauthorised access.

12. Minors & Age Restriction

jli3 strictly prohibits access by persons under twenty-one (21) years of age, in accordance with Philippine law and PAGCOR regulations. jli3 does not knowingly collect personal data from individuals under 21. If jli3 becomes aware that personal data has been collected from a person under 21, such data will be deleted immediately and the associated account will be closed.

If you believe a minor has registered on jli3 or provided personal data to jli3, please contact our support team at [email protected] immediately so that we can take appropriate action.

13. International Data Transfers

jli3 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or game studios located outside the Philippines — for example, internationally hosted cloud infrastructure or live casino studio operators — jli3 ensures that such transfers are subject to appropriate safeguards, including contractual data processing agreements that require the recipient to maintain data protection standards equivalent to those required under the Data Privacy Act of 2012.

jli3 will not transfer your personal data to any jurisdiction that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

14. Changes to This Policy

jli3 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. Material changes will be communicated to registered players via email or an in-platform notification prior to taking effect. The "Last Updated" date at the top of this Policy will be revised accordingly.

Your continued use of jli3 following the effective date of any amendment constitutes your acknowledgement of the updated Policy. We encourage you to review this Policy periodically. The current version is always available at jli3.app/privacy-policy.

15. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact jli3's Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data rights under the Data Privacy Act of 2012 have not been adequately addressed by jli3.