jll3 Privacy Policy

1.1 jll3 ("we," "us," or "our") is committed to protecting the privacy and personal data of all players who use the jll3 online gaming platform ("Platform") accessible at jll3.net. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data.

1.2 This Policy applies to all personal data collected through the jll3 Platform, including data provided during account registration, during gameplay, through customer support interactions, and through your use of our website and mobile web application.

1.3 This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are available on the jll3 Platform. By using jll3, you agree to the collection and use of your personal data as described in this Policy.

1.4 jll3 is designed for and directed at players in the Philippines. This Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission ("NPC").

2.1 For the purposes of the Philippine Data Privacy Act, jll3 acts as the personal information controller in respect of the personal data of its registered players and website visitors.

2.2 jll3 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact the DPO at any time using the contact details provided in Section 14 of this Policy.

3.1 jll3 collects the following categories of personal data:

3.2 jll3 does not collect sensitive personal information as defined under the DPA (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless strictly required for responsible gaming compliance (e.g., self-exclusion records) or as mandated by Philippine law.

4.1 jll3 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically when you access and use the jll3 Platform, including through cookies and similar tracking technologies (see Section 8);
• Third-party sources: Identity and fraud-check data from regulated identity verification service providers; payment data from licensed payment processors (GCash, PayMaya, Philippine banks); and publicly available information where permitted by law for AML/KYC purposes.

5.1 jll3 processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your jll3 account, process transactions, and deliver gaming services;
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, Anti-Money Laundering Act (AMLA) obligations, and NPC requirements;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your privacy rights;
• Consent: Processing for optional purposes such as marketing communications, where we have obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6.1 jll3 uses your personal data for the following purposes:

• Creating and managing your jll3 account and verifying your identity and age (21+ requirement);
• Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank transfer;
• Providing access to casino games, slots, bingo, and other jll3 gaming services;
• Administering bonuses, promotions, and loyalty programmes;
• Detecting and preventing fraud, money laundering, and other prohibited conduct;
• Monitoring gaming activity for responsible gaming purposes, including identifying at-risk players;
• Responding to customer support enquiries and resolving disputes;
• Complying with PAGCOR licensing conditions, AMLA reporting obligations, and other Philippine regulatory requirements;
• Improving the jll3 Platform through analytics and user research;
• Sending you service-related communications (account notices, security alerts, policy updates);
• Sending you marketing communications about jll3 promotions and new features, where you have consented to receive them.

7.1 jll3 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, and Philippine banking partners, for the purpose of processing your deposits and withdrawals;
• Identity verification providers: Regulated KYC/AML service providers engaged to verify your identity and screen against sanctions lists, as required by Philippine law;
• Game content providers: Licensed game studios and software providers whose games are available on the jll3 Platform, to the extent necessary to deliver gameplay and resolve disputes;
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers engaged to operate and secure the jll3 Platform, bound by data processing agreements;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities, where disclosure is required by law or regulatory directive;
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by court order or applicable law.

7.2 All third-party service providers engaged by jll3 are required to process personal data only on jll3's instructions and in accordance with applicable data privacy laws. jll3 does not transfer personal data outside the Philippines except where required by law or where adequate data protection safeguards are in place.

8.1 jll3 uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, display settings) to personalise your experience.
• Analytics cookies: Collect aggregated, anonymised data about how players use the Platform to help us improve performance and usability.
• Security cookies: Used to detect and prevent fraudulent activity and protect the integrity of the Platform.

8.2 You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the jll3 Platform. jll3 does not use third-party advertising or cross-site tracking cookies.

9.1 jll3 retains personal data for the following periods, or longer where required by Philippine law:

• Account and identity data: For the duration of your account and for five (5) years following account closure, as required by PAGCOR regulations and AMLA obligations;
• Transaction and gaming records: For five (5) years from the date of the transaction or gaming session, in accordance with AMLA and PAGCOR record-keeping requirements;
• Customer support records: For three (3) years from the date of the interaction;
• Marketing consent records: For the duration of your consent and for one (1) year following withdrawal of consent;
• Technical and usage data: For up to twelve (12) months, after which it is anonymised or deleted.

9.2 Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with jll3's data disposal procedures.

10.1 jll3 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the jll3 Platform;
• Encryption of sensitive data at rest, including financial and identity data;
• Role-based access controls limiting data access to authorised personnel only;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Multi-factor authentication for administrative access to systems containing personal data;
• Staff training on data privacy and security obligations.

10.2 While jll3 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your jll3 account credentials and for notifying us immediately of any suspected unauthorised access.

11.1 Under the Philippine Data Privacy Act, you have the following rights in respect of your personal data held by jll3:

• Right to be informed: The right to know what personal data jll3 holds about you and how it is processed;
• Right of 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 it is no longer necessary for the purposes for which it was collected, subject to jll3's legal retention obligations;
• Right to object: The right to object to processing of your personal data for direct marketing or where processing is based on legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• 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.

11.2 To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. jll3 will respond to all verified requests within fifteen (15) business days. We may need to verify your identity before processing your request.

12.1 The jll3 Platform is strictly intended for individuals aged 21 years and above. jll3 does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

12.2 If you believe that a person under 21 has registered on jll3 or provided personal data to us, please contact our support team immediately so that we can investigate and take appropriate action.

13.1 jll3 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, we will notify you by email or by a prominent notice on the jll3 Platform prior to the changes taking effect.

13.2 The effective date at the top of this Policy indicates when it was last updated. We encourage you to review this Policy periodically. Your continued use of the jll3 Platform following notification of any update constitutes your acknowledgement of the revised Policy.

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or jll3's data processing practices, please contact our Data Protection Officer:

• Email: privacy@jll3.net
• General Support: support@jll3.net
• Live Chat: Available 24/7 via the jll3 Platform
• Response Time: Within 15 business days for data privacy requests

14.2 If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).