Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") is issued by jlss ("jlss," "we," "us," or "our") and applies to all personal data collected, processed, stored, and used in connection with the jlss online gaming platform accessible at jlss.one (the "Platform"), including all associated mobile applications, customer support channels, and promotional activities.

This Policy is intended to inform you — as a visitor, registered player, or prospective player of jlss — about how we handle your personal information in a transparent, lawful, and accountable manner consistent with the requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC").

By accessing the Platform or registering a jlss account, 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 the Platform immediately.

2. Data Controller Information

For the purposes of the Data Privacy Act of 2012, jlss acts as the personal information controller ("PIC") in respect of the personal data collected through the Platform. Our designated Data Protection Officer ("DPO") is responsible for overseeing compliance with this Policy and applicable data protection law.

You may contact our Data Protection Officer for any privacy-related inquiries, data subject access requests, or complaints at the following:

• Email: [email protected] (subject line: "Data Privacy Request")
• Platform: Via the live chat support function after logging in to your jlss account.
• Response Time: We aim to acknowledge all data privacy requests within three (3) business days and resolve them within fifteen (15) business days.

3. Data We Collect

jlss collects personal data that falls into the following categories, depending on how you interact with the Platform:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — you must be 21 or older)
• Gender (optional, for personalization purposes)
• Nationality and country of residence
• Government-issued identification document type and number (e.g., Philippine passport, driver's license, PhilSys National ID, UMID, SSS ID)
• Selfie or photograph submitted for identity verification

3.2 Contact Data

• Email address
• Philippine mobile number
• Residential address (province, city/municipality)

3.3 Financial & Transaction Data

• GCash or PayMaya / Maya account number (masked)
• Bank account details for bank transfer transactions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank)
• Debit card details (card number masked; only last four digits retained)
• Deposit and withdrawal history
• Transaction amounts in Philippine Peso (₱)
• Source of funds declarations where required by AML regulations

3.4 Gaming Activity Data

• Game session logs (games played, duration, stakes, outcomes)
• Bonus and promotion usage history
• jlss Rewards program points and redemption history
• Responsible gaming tool settings (deposit limits, self-exclusion status)

3.5 Technical & Device Data

• IP address and approximate geolocation (province/city level)
• Device type, operating system, and browser version
• Session timestamps and login history
• Cookie identifiers and similar tracking data (see Section 8)

3.6 Communications Data

• Customer support chat transcripts and email correspondence
• Feedback and survey responses
• Promotional communication preferences

4. How We Collect Your Data

jlss collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from accredited verification service providers; fraud and AML screening data from compliance service providers; payment confirmation data from GCash, PayMaya, and banking partners.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with compliance obligations.

5. How We Use Your Data

jlss uses your personal data for the following purposes:

6. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our obligations under the jlss Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine law, including AML regulations, PAGCOR licensing requirements, and tax obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and optional personalization features, where you have provided explicit, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

jlss does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya / Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals.
• Identity verification providers: Accredited KYC service providers for age and identity verification in compliance with PAGCOR requirements.
• AML and fraud screening providers: Compliance technology providers used to screen transactions and player activity against regulatory watchlists.
• IT and infrastructure providers: Cloud hosting and cybersecurity service providers who process data on our behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law or regulatory directive.
• Legal and professional advisors: Lawyers, auditors, and accountants where disclosure is necessary for the conduct of legal proceedings or professional advice.

All third-party service providers who process personal data on behalf of jlss are bound by contractual data processing agreements that require them to maintain appropriate security measures and process data only in accordance with jlss's instructions and applicable law.

8. Cookies & Tracking Technologies

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

• Strictly necessary cookies: Required for the Platform to function, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game lobby layout, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymized data about how players use the Platform to help us identify areas for improvement. No personally identifiable information is included in analytics reports.
• Marketing cookies: Used only with your consent to deliver relevant promotional content within the jlss Platform. jlss does not use third-party advertising networks.

You can manage your cookie preferences through your browser settings. Disabling strictly necessary cookies may affect the functionality of the Platform. For detailed cookie information, refer to the cookie settings panel accessible from the Platform footer.

9. Data Retention

jlss retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law :

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC-recommended data disposal procedures.

10. Data Security

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

• Encryption in transit: All data transmitted between your device and jlss servers is protected using TLS 1.3 protocol.
• Encryption at rest: Sensitive data stored on jlss servers — including identity documents, payment details, and account credentials — is encrypted using AES-256.
• Access controls: Access to personal data is restricted to authorized jlss personnel on a strict need-to-know basis. All staff with access to personal data undergo regular data privacy training.
• Multi-factor authentication: Administrative access to systems containing personal data requires multi-factor authentication.
• Regular security audits: jlss conducts periodic vulnerability assessments and penetration testing of the Platform infrastructure.
• Incident response: jlss maintains a documented data breach response procedure. In the event of a personal data breach that poses a real risk to your rights and freedoms, jlss will notify the NPC within 72 hours and affected players without undue delay, as required by the DPA.

11. Your Rights Under the DPA

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jlss:

• Right to be informed: The right to know what personal data jlss collects about you and how it is used — which is the purpose of this Policy.
• Right of access: The right to request a copy of the personal data jlss holds about you, including information on how it has been processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your jlss account settings.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: The right to lodge 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, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." We will respond within fifteen (15) business days of receiving a valid request.

12. Children & Minors

The jlss Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine law governing casino-style gambling. jlss does not knowingly collect personal data from individuals under the age of 21.

If you are a parent or guardian and believe that a minor has registered an account or provided personal data to jlss without your consent, please contact us immediately at [email protected]. We will promptly investigate and, where confirmed, close the account and delete all associated personal data.

jlss employs age verification procedures at registration and reserves the right to request additional proof of age at any time. Accounts found to belong to individuals under 21 will be immediately suspended and all data handled in accordance with applicable law.

13. Cross-Border Data Transfers

jlss primarily stores and processes personal data within the Republic of the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines — for example, cloud hosting or identity verification services — jlss ensures that such transfers are carried out in compliance with Section 21 of the DPA and the NPC's rules on cross-border data flows.

Specifically, jlss ensures that any recipient of personal data outside the Philippines provides an adequate level of data protection, either through contractual data transfer agreements incorporating NPC-approved standard contractual clauses, or through other lawful transfer mechanisms recognized under Philippine data protection law.

14. Changes to This Policy

jlss reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — jlss will notify registered players via their registered email address and/or a prominent notice on the Platform at least seven (7) days before the changes take effect.

Your continued use of the jlss Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. We recommend reviewing this page periodically to stay informed of any updates.

15. Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by jlss, please contact our Data Protection Officer:

• Email: [email protected] (subject: "Data Privacy Request")
• Live Chat: Available daily through the jlss Platform after logging in to your account.

If you are not satisfied with our response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC) — the independent government body responsible for administering and implementing the Data Privacy Act of 2012 in the Philippines.