jlmm ph Privacy Policy

1 Who We Are

jlmm ph is an online gaming platform operated for Filipino players, accessible at jlmmph.org. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), jlmm ph acts as the Personal Information Controller (PIC) with respect to the personal data of its registered users and website visitors.

jlmm ph is headquartered in Manila, Philippines, and operates in compliance with PAGCOR guidelines and applicable Philippine data protection legislation. All data processing activities described in this Policy are conducted within the framework of Philippine law.

2 Personal Data We Collect

jlmm ph collects the following categories of personal data from users:

• Identity Data: Full legal name, date of birth, government-issued ID number (e.g., PhilSys ID, passport, driver's license), nationality, and gender.
• Contact Data: Email address, mobile number, and residential address (including city, province, and postal code within the Philippines).
• Financial Data: GCash account details, Maya/PayMaya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and debit card details used for deposits and withdrawals.
• Account Data: Username, encrypted password, account preferences, communication preferences, and responsible gaming settings.
• Transaction Data: Records of all deposits, withdrawals, game wagers, bonus claims, and promotional activity associated with your jlmm ph account.
• Technical Data: IP address, browser type and version, device type, operating system, time zone, and session data collected automatically when you access jlmmph.org.
• Usage Data: Information about how you navigate and interact with the jlmm ph Platform, including pages visited, games played, session duration, and click patterns.
• Communications Data: Records of your interactions with jlmm ph customer support, including live chat transcripts, email correspondence, and support ticket history.

3 How We Collect Your Data

jlmm ph collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing identity verification (KYC), making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access jlmmph.org.
• Third-Party Sources: Identity verification data from KYC service providers, fraud prevention data from anti-money laundering (AML) screening services, and payment data from our authorized payment processing partners.
• Publicly Available Sources: In limited circumstances, jlmm ph may supplement your profile with information from publicly available Philippine government databases for identity verification purposes.

4 How We Use Your Personal Data

jlmm ph uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your jlmm ph account, including processing your registration and verifying your identity.
• Service Delivery: To provide access to games, process deposits and withdrawals in Philippine Peso (₱), and deliver the full range of jlmm ph services.
• Regulatory Compliance: To fulfill our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Philippine Data Privacy Act, including KYC verification and transaction monitoring.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the jlmm ph Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support channels.
• Responsible Gaming: To monitor gaming behavior, enforce responsible gaming limits, and identify players who may need support in accordance with our Responsible Gaming Policy.
• Marketing & Promotions: To send you relevant promotional offers, bonus notifications, and platform updates, where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of jlmmph.org.

5 Legal Basis for Processing

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

• Contractual Necessity: Processing required to fulfill our obligations under the jlmm ph Terms and Conditions, including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA requirements, and tax obligations.
• Legitimate Interests: Processing conducted for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

jlmm ph does not sell or rent your personal data to third parties. We may share your data with the following categories of recipients only where necessary and in accordance with applicable law:

• Payment Processors: GCash, Maya, and our partner banks receive the financial data necessary to process your deposits and withdrawals.
• KYC & AML Providers: Identity verification and anti-money laundering screening services that assist jlmm ph in meeting its regulatory obligations.
• Technology Partners: Cloud hosting providers, cybersecurity services, and analytics platforms that support the operation of jlmmph.org under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or court order.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by jlmm ph, subject to professional confidentiality obligations.

All third-party service providers engaged by jlmm ph are contractually required to process your personal data only for the specified purpose and in compliance with the Philippine Data Privacy Act.

7 Cookies & Tracking Technologies

jlmm ph uses cookies and similar tracking technologies to enhance your experience on jlmmph.org. The following types of cookies are used:

• Essential Cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Performance Cookies: Collect anonymized data about how visitors use jlmmph.org to help us improve Platform performance and identify technical issues.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming limits, to personalize your experience.
• Analytics Cookies: Used to understand user behavior patterns and improve the jlmm ph Platform. Data collected is aggregated and anonymized where possible.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of jlmmph.org. Your continued use of the Platform after being informed of our cookie practices constitutes consent to the use of cookies as described above.

8 Data Retention

jlmm ph 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:

• Account Data: Retained for the duration of your active jlmm ph account, plus a minimum of 5 years after account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC & Identity Documents: Retained for a minimum of 5 years after the end of the business relationship, or longer if required by a regulatory investigation.
• Customer Support Records: Retained for 3 years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing Consent Records: Retained for the duration of your consent, plus 1 year after withdrawal of consent as evidence of compliance.

Upon expiry of the applicable retention period, jlmm ph will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

9 Data Security

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

• Encryption: All data transmitted between your device and jlmmph.org is protected using SSL/TLS encryption. Sensitive data at rest, including financial information and identity documents, is encrypted using AES-256 or equivalent standards.
• Access Controls: Access to personal data is restricted to authorized jlmm ph personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Two-Factor Authentication: jlmm ph supports and encourages the use of two-factor authentication (2FA) for all player accounts to prevent unauthorized access.
• Regular Security Audits: jlmm ph conducts periodic security assessments, penetration testing, and vulnerability scans to identify and remediate potential weaknesses in our systems.
• Staff Training: All jlmm ph personnel with access to personal data receive regular training on data protection obligations and security best practices.

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

10 Your Data Protection Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jlmm ph:

• Right to Be Informed: The right to know what personal data jlmm ph collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data jlmm ph holds about you, along with information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by jlmm ph.
• 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 our legal retention obligations.
• 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 Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another service provider where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14 of this Policy. jlmm ph will respond to all verified data rights requests within 30 calendar days of receipt.

11 Children's Privacy

The jlmm ph Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. jlmm ph does not knowingly collect personal data from individuals under the age of 21.

If jlmm ph discovers that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete all related personal data, and refund any deposits in accordance with applicable regulations.

If you are a parent or guardian and believe that your child has registered on jlmm ph, please contact our customer support team immediately so that we can take appropriate action.

12 Third-Party Links

jlmmph.org may contain references to third-party services, such as payment processors and game providers. While jlmm ph takes care to work only with reputable partners, we are not responsible for the privacy practices of third-party websites or services.

This Privacy Policy applies solely to data collected by jlmm ph through jlmmph.org and our associated services. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of jlmm ph.

13 Updates to This Privacy Policy

jlmm ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. The most current version of this Policy will always be available at jlmmph.org/privacy-policy.

Where changes are material, jlmm ph will notify registered users via email or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of jlmm ph following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms.

We recommend that you review this Privacy Policy periodically to stay informed about how jlmm ph protects your personal information.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by jlmm ph, please contact our Data Protection Officer (DPO):

• Data Protection Officer: jlmm ph Privacy & Compliance Team
• Email: [email protected]
• Support Email: [email protected]
• Operating Hours: 24 hours a day, 7 days a week (Philippine Standard Time)
• Location: Manila, Philippines

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with our response to your data rights request.