jll3 Privacy Policy

1 Who We Are (Data Controller)

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), jll3 is the personal information controller responsible for the personal data collected through the jll3.club platform. When this Policy refers to "jll3," "we," "us," or "our," it refers to the jll3 entity operating the online casino platform accessible at jll3.club.

jll3 processes your personal data to provide online casino and sports betting services to registered Filipino players and to comply with applicable Philippine regulatory requirements, including those imposed by PAGCOR and the Anti-Money Laundering Council (AMLC).

2 Information We Collect

jll3 collects personal information only to the extent necessary to provide our services, fulfill legal obligations, and protect the security of our platform. The categories of information we collect include:

jll3 does not collect special categories of sensitive personal information (as defined under RA 10173) unless specifically required by law or with your explicit consent.

3 How We Use Your Personal Data

jll3 uses the personal data we collect for the following purposes:

• Account Management: Creating, maintaining, and securing your jll3 account; verifying your identity and eligibility (including the 21+ age requirement);
• Service Delivery: Enabling you to play games, place bets, deposit funds via GCash or other payment methods, and receive winnings;
• Payment Processing: Processing deposits and withdrawals, reconciling transactions, and issuing payouts to your GCash or bank account;
• Legal & Regulatory Compliance: Complying with PAGCOR regulations, the Anti-Money Laundering Act (RA 9160, as amended), RA 10173, and other applicable Philippine laws;
• Fraud Prevention & Security: Detecting and preventing unauthorized access, cheating, money laundering, and other prohibited activities;
• Responsible Gaming: Monitoring gaming behavior, enforcing deposit limits, and supporting self-exclusion requests in line with PAGCOR responsible gaming standards;
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates — only where you have not opted out;
• Customer Support: Responding to your enquiries, resolving disputes, and improving the quality of our support services.

4 Legal Basis for Processing

Under the Philippine Data Privacy Act, jll3 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our agreement with you (i.e., providing casino services under our Terms & Conditions);
• Legal Obligation: Processing required to comply with Philippine law, including AMLA reporting obligations and PAGCOR regulatory requirements;
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent and retain the right to withdraw it at any time.

5 Data Sharing & Disclosure

jll3 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share your data only in the following circumstances:

• Payment Processors: GCash (GXI), PayMaya, BPI, BDO, Metrobank, Visa/Mastercard networks, and InstaPay/PESONet operators — shared only to the extent necessary to process your transactions;
• KYC / Identity Verification Providers: Third-party identity verification services used to confirm your identity and age in compliance with RA 10173 and PAGCOR rules;
• Regulatory Authorities: PAGCOR, the AMLC, the National Privacy Commission (NPC), and other Philippine government agencies where required by law or court order;
• IT & Hosting Providers: Cloud hosting and security service providers engaged to operate the jll3 platform infrastructure, bound by data processing agreements;
• Professional Advisors: Legal, accounting, or audit firms engaged by jll3 in connection with its business operations, subject to professional confidentiality obligations.

6 Cookies & Tracking Technologies

jll3 uses cookies and similar tracking technologies on the jll3.club platform. Cookies are small data files stored on your device that help us deliver a personalized and functional experience. The categories of cookies we use include:

• Strictly Necessary Cookies: Essential for platform functionality (login sessions, security tokens). These cannot be disabled.
• Performance Cookies: Anonymous analytics data to understand how players navigate jll3.club and improve the user experience.
• Functional Cookies: Remember your preferences (language, display settings) across sessions.
• Marketing Cookies: Track promotional interactions. These are only set with your consent.

You may manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the jll3 platform.

7 Data Retention

jll3 retains your personal data for as long as your account is active and for a period thereafter as required by Philippine law. Specifically:

• Account and identity data is retained for a minimum of five (5) years after account closure, as required by AMLA regulations;
• Transaction records (deposits, withdrawals, bets) are retained for a minimum of five (5) years;
• Customer support communications are retained for three (3) years;
• Marketing consent records are retained for as long as consent is active plus two (2) years after withdrawal.

When retention periods expire, personal data is securely deleted or anonymized in a manner that prevents re-identification.

8 Security Measures

jll3 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jll3 servers;
• AES-256 encryption for sensitive data at rest, including payment credentials;
• Multi-factor authentication options for account access (SMS OTP / 2FA);
• Regular penetration testing and vulnerability assessments;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• 24/7 automated monitoring for suspicious login activity and data breach indicators.

In the event of a personal data breach that poses a risk to your rights and freedoms, jll3 will notify the National Privacy Commission (NPC) within 72 hours of discovery and will inform affected data subjects as required under RA 10173.

9 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jll3:

• Right to be Informed: The right to know what personal data jll3 collects and how it is used — as described in this Policy;
• Right to Access: The right to request a copy of the personal data jll3 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 there is no overriding legal obligation to retain it;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, machine-readable format;
• Right to Damages: The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.

To exercise any of these rights, contact the jll3 Data Protection Officer at the details provided in Section 13 below. jll3 will respond to verified requests within 15 business days.

10 Children & Minors

Parents and guardians who believe a minor has registered on jll3 should contact us immediately at [email protected] (not a clickable link) so we can take prompt action.

11 Cross-Border Data Transfers

Where jll3 transfers personal data outside the Philippines (for example, to cloud hosting providers with infrastructure in other countries), such transfers are conducted in accordance with RA 10173 and its Implementing Rules. jll3 ensures that adequate safeguards are in place — including contractual data transfer agreements — to protect your data to the same standard required under Philippine law.

12 Changes to This Privacy Policy

jll3 may update this Privacy Policy periodically to reflect changes in our data practices, platform features, or applicable Philippine law. Material changes will be communicated to registered users via SMS or email before they take effect. The revised Policy will be published on jll3.club with an updated "Last Updated" date. Your continued use of the jll3 platform after the effective date of any revision constitutes your acceptance of the updated Policy.

13 Contact & Data Protection Officer

For questions, concerns, or requests related to this Privacy Policy or the exercise of your rights under RA 10173, please contact the jll3 Data Protection Officer:

• Email: [email protected] (plain text only — not a clickable link)
• Live Chat: Available 24/7 through the jll3.club platform after login
• FAQ: Visit our FAQ page for common privacy questions

You also have the right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe jll3 has not handled your personal data in accordance with RA 10173.