jl25 Privacy Policy

This Privacy Policy applies to all personal data collected and processed by jl25 in connection with the operation of jl25.club and all associated services, including account registration, game play, financial transactions, customer support interactions, and marketing communications.

jl25 — the operating entity behind jl25.club — acts as the Personal Information Controller (PIC) as defined under Republic Act No. 10173 (the Data Privacy Act of 2012) with respect to all personal data it collects directly from players and website visitors.

Where jl25 engages third-party service providers (including game studios, payment processors, and technology vendors) who process personal data on jl25's behalf, those entities act as Personal Information Processors (PIPs) and are bound by appropriate data processing agreements that require them to protect your data in accordance with Philippine data protection law.

The following terms have the meanings given below throughout this Privacy Policy:

jl25 collects the following categories of personal data, depending on your interaction with the platform:

jl25 does not intentionally collect special categories of sensitive personal information beyond what is strictly required for KYC compliance and regulatory reporting.

jl25 collects personal data through the following methods:

• Directly from you: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting support, or completing any form on jl25.club.
• Automatically through your use of the platform: Technical data including IP addresses, device identifiers, browser information, session logs, and game activity data is collected automatically through platform systems and cookies as described in Section 11.
• From payment providers: When you transact via GCash, PayMaya, BPI, BDO, Metrobank, or USDT, jl25 receives transaction confirmation data (reference numbers, transaction amounts, and partial account identifiers) from those payment processors.
• From identity verification services: jl25 may use third-party KYC technology vendors to assist in verifying the authenticity of government-issued identification documents. These vendors process data on jl25's behalf under appropriate data processing agreements.

jl25 processes your personal data for the following specific, legitimate, and declared purposes:

• Account creation and management: To register and maintain your jl25 Account, authenticate your identity at login, and administer account-related communications.
• Service delivery: To provide access to jl25's game library, process deposits and withdrawals, credit bonuses, and deliver the full platform experience.
• Age and identity verification (KYC): To verify that you are at least 21 years of age as required by Philippine law and PAGCOR regulations, and to confirm your identity before processing withdrawals.
• Legal and regulatory compliance: To fulfill obligations under the Data Privacy Act, Anti-Money Laundering Act (RA 9160), PAGCOR licensing requirements, and other applicable Philippine laws — including filing reports to the Anti-Money Laundering Council (AMLC) where required.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, and unauthorized account access.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, administer self-exclusion and limit requests, and comply with PAGCOR's responsible gaming standards.
• Customer support: To respond to your enquiries, resolve complaints, and maintain records of support interactions for quality assurance.
• Platform improvement: To analyze aggregated, anonymized usage patterns to improve jl25's platform, game selection, and user experience.
• Marketing communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time.

jl25 processes personal data on the following legal bases under the Data Privacy Act of 2012:

• Contract performance: Processing necessary to create and manage your jl25 Account, process transactions, and deliver services pursuant to jl25's Terms and Conditions.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act itself, and other applicable Philippine statutory obligations.
• Legitimate interests: Processing for fraud prevention, account security, platform improvement, and responsible gaming monitoring, where these interests do not override the fundamental rights and freedoms of the data subject.
• Consent: Processing for optional marketing communications and for any processing activity not covered by the above bases — such consent being freely given, specific, informed, and revocable at any time.

jl25 does not sell personal data. jl25 may share personal data with the following categories of recipients strictly on a need-to-know basis and subject to appropriate contractual or legal protections:

• Game providers: Game studios (including PG Soft, Pragmatic Play, JILI, Evolution Gaming, and others) receive limited technical session data necessary to deliver their games through the jl25 platform.
• Payment processors: GCash (Mynt), PayMaya (PayMongo/Voyager), BPI, BDO, Metrobank, and USDT processing partners receive the minimum necessary financial data to process your deposits and withdrawals.
• KYC technology vendors: Third-party identity verification services receive the ID documents and personal data you submit for KYC — strictly for the purpose of verifying your identity and age on jl25's behalf.
• Regulatory authorities: jl25 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other government agencies where required by law, court order, or regulatory instruction — without notice to you where such notice is legally prohibited.
• Law enforcement: jl25 will cooperate with Philippine law enforcement agencies where required by valid legal process.
• Professional advisors: jl25's legal, accounting, and audit service providers may access personal data to the minimum extent necessary to provide their professional services — all subject to professional confidentiality obligations.

Some of jl25's third-party service providers — including certain game studios and cloud infrastructure providers — may be located or process data in jurisdictions outside the Philippines. Where such cross-border data transfers occur, jl25 ensures that:

• The recipient country provides an adequate level of data protection, as assessed by jl25 in light of the NPC's guidelines on cross-border data flows; or
• Appropriate contractual safeguards are in place — including data processing agreements containing standard contractual clauses — that require the foreign recipient to protect transferred personal data to a standard equivalent to Philippine law; and
• The transfer is limited to the minimum personal data necessary for the specific processing purpose.

By using jl25, you acknowledge that your personal data may be processed in countries outside the Philippines for the limited purposes described in this Policy, subject to the safeguards described above.

jl25 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention schedule applies:

At the expiry of the applicable retention period, personal data is securely destroyed or anonymized in accordance with jl25's data disposal procedures.

jl25 implements a comprehensive set of technical and organizational security measures designed to protect your personal data from unauthorized access, disclosure, alteration, and destruction. These include:

• Encryption: 256-bit SSL/TLS encryption for all data in transit; AES-256 encryption for sensitive data at rest.
• Access controls: Role-based access control (RBAC) limits access to personal data to jl25 personnel who require it to perform their designated duties. All access is logged and audited.
• Password security: Player passwords are stored as one-way cryptographic hashes — jl25 cannot retrieve or read your plain-text password.
• Two-factor authentication: OTP verification via registered Philippine mobile number is applied for new-device logins and sensitive account operations.
• Network security: Firewalls, intrusion detection systems, and DDoS mitigation are deployed across jl25's infrastructure.
• Penetration testing: jl25's platform undergoes periodic security testing by independent cybersecurity professionals.
• Staff training: All jl25 personnel with access to personal data receive data protection training upon onboarding and on an ongoing basis.

jl25 uses cookies and similar tracking technologies on jl25.club to facilitate platform operation, maintain your logged-in session, and analyze usage patterns. The following cookie types are used:

• Strictly necessary cookies: Required for the platform to function — including session management cookies that keep you logged in during your gaming session. These cannot be disabled without preventing proper platform operation.
• Functional cookies: Remember your preferences such as language settings, game preferences, and responsible gaming tool configurations.
• Analytics cookies: Collect aggregated, anonymized data about how visitors use jl25.club — including pages visited, session duration, and navigation paths — to help jl25 improve the platform. jl25 uses analytics tools provided by reputable technology vendors under data processing agreements.
• Security cookies: Used for fraud detection and to identify unusual login patterns or suspicious technical activity that may indicate unauthorized Account access.

Most browsers allow you to control cookie settings through the browser's settings menu. Please note that disabling strictly necessary cookies will prevent core platform functions from operating correctly. Disabling analytics cookies will not affect your ability to use jl25 but may affect jl25's ability to improve the platform based on usage data.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jl25. These rights may be exercised by contacting jl25's Data Protection Officer at the address in Section 16.

jl25 is a real-money gambling platform strictly limited to individuals who are 21 years of age or older. jl25 does not knowingly collect personal data from any individual under the age of 21.

All registrations are subject to KYC age verification prior to withdrawal processing. Where jl25 discovers or has reasonable grounds to believe that an Account has been registered by a person under 21 years of age, jl25 will immediately close the Account, cease processing any associated personal data, and securely delete the relevant data beyond what is required for regulatory reporting purposes.

If you believe a minor has registered a jl25 Account, please contact jl25's Data Protection Officer immediately at [email protected].

jl25.club may contain links to third-party game provider interfaces and payment gateways. Once you leave jl25.club and access a third-party service — even one embedded within the jl25 platform interface — that third party's own privacy policy governs the processing of your personal data on their systems.

jl25 is not responsible for the privacy practices of third-party game providers, payment processors, or any other external service whose link or interface may be accessible through jl25. jl25 recommends that you review the privacy policy of any third-party service before providing personal information directly to that service.

jl25 reviews and updates this Privacy Policy periodically to reflect changes in its data processing practices, applicable law, or regulatory guidance from the National Privacy Commission. The "Last Updated" date at the top of this Policy indicates when the most recent revision was made.

For material changes to this Policy — particularly changes that affect the legal basis for processing, the categories of personal data collected, or the rights of data subjects — jl25 will notify registered players via email to their registered contact address or via an in-platform notification, at least seven (7) calendar days before the revised Policy takes effect.

Continued use of jl25 following the effective date of any updated Privacy Policy constitutes your acknowledgment of the revised terms. If you do not agree with the revised Policy, you may request Account closure in accordance with jl25's Terms and Conditions.

jl25 has appointed a Data Protection Officer (DPO) as required under Section 21 of the Data Privacy Act and NPC Circular 17-01. The DPO oversees jl25's data protection compliance program, serves as the primary point of contact for data subject requests, and coordinates with the National Privacy Commission on data protection matters.

To exercise any of your data subject rights under Section 12, to withdraw consent to data processing, or to raise a concern about how jl25 handles your personal data, please contact the jl25 DPO through the following channels:

• Data Protection Officer — jl25: [email protected] (subject line: Data Privacy Request)
• General Support: [email protected]
• Live Chat: Available 24/7 at jl25.club

jl25 will acknowledge all data subject requests within 3 business days and will provide a substantive response within the timeframes prescribed by the Data Privacy Act and NPC regulations.

If you are unsatisfied with jl25's response to a data privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines.