Privacy Policy – jll33 Casino

Effective Date: 1 January 2026 | Last Updated: 1 January 2026

1. Introduction and Scope

This Privacy Policy ("Policy") describes how jll33 ("jll33," "we," "us," or "our"), the operator of the online gambling platform located at jll33.club ("Platform"), collects, uses, stores, discloses, and protects personal information relating to registered users, visitors, and other individuals who interact with the Platform ("you," "Player," or "Data Subject").

jll33 acts as the personal information controller in respect of personal data collected through the Platform. By registering a jll33 account or using the Platform in any capacity, you acknowledge that you have read and understood this Policy. This Policy is incorporated by reference into jll33's Terms and Conditions.

This Policy applies to all personal data collected through the jll33 website, mobile-optimised browser interface, live chat support, and any other channel through which jll33 interacts with users. It does not apply to third-party websites or services that may be referenced in connection with jll33, including payment processors and game providers, which operate under their own privacy policies.

2. Information We Collect

jll33 collects the following categories of personal information from or about registered players:

2.1 Registration and Identity Data

• Full legal name as it appears on your government-issued identification.
• Date of birth (required for age verification — minimum age 21 under Philippine law).
• Residential address, including barangay, city or municipality, province, and postal code.
• Email address and mobile phone number (used for account communications and security verification).
• Government-issued identification document type and number (e.g., Philippine passport, Unified Multi-Purpose ID, driver's license), collected during Know Your Customer (KYC) verification.

2.2 Financial Data

• Payment method details submitted for deposits and withdrawals, including GCash registered number, PayMaya account reference, BPI/BDO/Metrobank account name, and the last four digits of any credit card used.
• Transaction history, including deposit amounts, withdrawal requests, dates, and processing status.
• Bonus credit balances, wagering activity records, and loyalty point accumulations.

2.3 Gaming Activity Data

• Game session logs, bet history, game results, and account balance history.
• Sports betting selections, stake amounts, and settlement records.
• Responsible gaming settings applied to the account, including deposit limits and self-exclusion status.

2.4 Technical and Device Data

• IP address and approximate geographic location derived therefrom.
• Device type, operating system, browser type and version.
• Session duration, pages visited, and interaction data within the Platform.
• Cookie identifiers and similar tracking data as described in Section 6.

2.5 Communications Data

• Contents of live chat support conversations and email correspondence with jll33.
• Feedback, complaint, and dispute records.
• Marketing communication preferences and opt-out records.

3. How We Use Your Information

jll33 uses the personal data collected from players for the following purposes:

• Account creation and management: To register your jll33 account, verify your identity and age, maintain your account profile, and process login requests.
• Service delivery: To provide access to casino games, live dealer tables, sports betting, bingo, and all other jll33 gambling services.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, and bank transfer, and to verify that payment methods are registered in your name.
• Legal compliance: To fulfil obligations under Philippine anti-money laundering law (Republic Act No. 9160 as amended), PAGCOR licensing requirements, and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, and violations of jll33's Terms and Conditions.
• Responsible gaming: To monitor gaming patterns for indicators of problem gambling and to administer responsible gaming tools including deposit limits, self-exclusion, and session time reminders.
• Customer support: To respond to enquiries, resolve disputes, and provide technical assistance to jll33 account holders.
• Platform improvement: To analyse aggregated usage data, improve game performance, and develop new features for the jll33 Platform.
• Marketing communications: To send promotional offers, bonus notifications, and platform updates to players who have not opted out of such communications.

4. Legal Bases for Processing

jll33 processes personal data on the following legal grounds in accordance with the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the jll33 Terms and Conditions, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine law, including AML obligations, PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate interests: Processing conducted for fraud prevention, platform security, responsible gaming monitoring, and improvement of jll33 services, where such interests are not overridden by the rights and interests of Data Subjects.
• Consent: Processing of personal data for marketing communications and optional platform analytics, where consent has been obtained and may be withdrawn at any time.

5. Disclosure of Personal Data

jll33 does not sell, rent, or trade personal data to third parties for their own commercial purposes. Personal data may be disclosed in the following circumstances:

5.1 Service Providers

jll33 engages third-party service providers to support Platform operations, including payment processors (GCash, PayMaya, banking partners), game content providers, KYC verification services, and IT infrastructure providers. These parties are bound by contractual data processing agreements and are prohibited from using your data for any purpose beyond the specific service they provide to jll33.

5.2 Regulatory and Law Enforcement Authorities

jll33 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities where required by law, court order, or regulatory directive.

5.3 Business Transfers

In the event of a merger, acquisition, or transfer of all or substantially all of jll33's assets, personal data held by jll33 may be transferred to the successor entity, subject to equivalent privacy protections and notification to affected Data Subjects.

6. Cookies and Tracking Technologies

jll33 uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Essential cookies: Required for Platform functionality including session management, login state persistence, and security token verification. These cannot be disabled without affecting core Platform features.
• Analytics cookies: Used to collect aggregated data on how players interact with the jll33 Platform, including pages visited, session duration, and error occurrences. This data is used to improve Platform performance and user experience.
• Preference cookies: Store your Platform preferences, including language settings, game filter selections, and notification preferences.
• Marketing cookies: Used with your consent to personalise promotional communications based on your activity on the Platform. You may opt out of marketing cookies through your browser settings or account preferences.

You may control cookie settings through your browser. Note that disabling essential cookies may prevent certain jll33 Platform features from functioning correctly.

7. Data Retention

jll33 retains personal data for as long as necessary to fulfil the purposes described in this Policy, including any applicable legal retention obligations. The following retention periods apply:

• Account data: Retained for the duration of the active account relationship and for a minimum of five (5) years following account closure, as required under Philippine AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Support correspondence: Retained for three (3) years following resolution of the relevant enquiry or dispute.
• Marketing preferences: Retained until withdrawal of consent or account closure, whichever is earlier.

8. Data Security

jll33 implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data processed, including:

• 256-bit SSL/TLS encryption for all data in transit between user devices and jll33 servers.
• Encryption of sensitive data fields at rest within jll33's database infrastructure.
• Role-based access controls ensuring that only authorised personnel access personal data on a need-to-know basis.
• Regular security audits and penetration testing of the jll33 Platform and supporting infrastructure.
• Intrusion detection systems and real-time monitoring for anomalous access patterns.
• Incident response procedures, including player notification protocols in the event of a data breach affecting their personal information.

Notwithstanding these measures, no online platform can guarantee absolute security. Players are reminded to maintain strong, unique passwords for their jll33 accounts and to enable two-factor authentication where available.

9. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, Filipino data subjects have the following rights with respect to their personal data held by jll33:

• Right to be informed: The right to be notified of the identity of the data controller, the purposes of processing, and the data subjects' rights.
• Right to access: The right to obtain a copy of personal data held by jll33 about you and information about how it is being used.
• Right to rectification: The right to request correction of inaccurate, incomplete, or outdated personal data.
• Right to erasure or blocking: The right to request deletion or suppression of personal data where processing is no longer necessary, consent has been withdrawn, or data was unlawfully processed — subject to legal retention obligations.
• Right to data portability: The right to receive a copy of personal data you have provided to jll33 in a structured, commonly used electronic format.
• Right to object: The right to object to processing of your personal data for direct marketing purposes at any time.
• Right to damages: The right to claim compensation where you have suffered damage as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of personal data.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, contact jll33 via live chat or at [email protected]. jll33 will respond to verifiable data subject requests within thirty (30) days of receipt.

10. Children's Privacy

The jll33 Platform is strictly intended for adults aged 21 years and above. jll33 does not knowingly collect personal data from individuals under the age of 21. If jll33 becomes aware that personal data has been collected from a person under 21 without verifiable parental consent, jll33 will delete such data and close the associated account immediately. If you believe a minor has accessed or registered on the jll33 Platform, please notify us immediately at [email protected].

11. Cross-Border Data Transfers

In the course of providing services to jll33 players, personal data may be transferred to and processed in countries other than the Philippines, for example where game content providers or infrastructure providers maintain their servers. Where such transfers occur, jll33 ensures that appropriate safeguards are in place — including contractual data processing agreements with data importers — to provide a standard of protection equivalent to that afforded under Philippine law.

12. Changes to This Policy

jll33 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, jll33 will notify affected players by posting a notice on the Platform and, where practicable, by sending a notification to your registered email address. Your continued use of the jll33 Platform following the effective date of any amendment constitutes your acknowledgement of the updated Policy.

13. Contact and Complaints

For privacy-related enquiries, data subject rights requests, or complaints relating to jll33's data handling practices, please contact:

• Live Chat: Available 24/7 from the jll33 Platform.
• Email: [email protected]

If you are not satisfied with jll33's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). The NPC provides a formal complaints mechanism for data subjects whose rights under the Data Privacy Act of 2012 have been infringed.