jl85 Privacy Policy

1 Introduction

jl85 ("we," "us," "our") is committed to protecting the privacy and personal data of all individuals who use the jl85 online gaming platform accessible at jl85.asia ("Platform"). This Privacy Policy ("Policy") describes the types of personal information we collect, the purposes for which we use it, the circumstances in which it may be shared, and the rights available to you as a data subject under Philippine law.

This Policy applies to all players registered on the jl85 Platform, whether they access the Platform from Metro Manila, Cebu, Davao, Cagayan de Oro, or any other location in the Philippines or otherwise. By creating an account on jl85, depositing funds, or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2 Scope of This Policy

This Policy applies to all personal information collected by jl85 in connection with the operation of the Platform, including information collected during account registration, gameplay, financial transactions, customer support interactions, and communications via the Platform's live chat function.

This Policy does not apply to third-party websites, applications, payment processors, or services that may be accessible through or in connection with the jl85 Platform. Those third parties operate under their own privacy policies, which you should review independently. jl85 is not responsible for the privacy practices of any third-party service provider beyond the data-sharing arrangements described in Section 7 of this Policy.

3 Data We Collect

jl85 collects personal information that is necessary to provide, operate, and secure the Platform. The categories of personal data we process are described below.

3.1 Account Registration Data

When you create a jl85 account, we collect the following information:

• Mobile number (Philippine format, used as your primary identifier)
• Username (chosen by you at registration)
• Password (stored as a cryptographic hash — we cannot read your password in plain text)
• Date of birth (for age verification — all players must be 21 or above)

3.2 Identity Verification (KYC) Data

For identity verification and compliance with anti-money laundering regulations, jl85 may request:

• Government-issued photo identification (e.g., PhilSys National ID, passport, driver's licence)
• Proof of address (e.g., utility bill, bank statement)
• Selfie or facial image for identity confirmation

3.3 Financial Transaction Data

We collect records of all financial transactions conducted through your jl85 account:

• Deposit amounts, dates, and payment methods (GCash, PayMaya, BPI, BDO, Metrobank, 7-Eleven, Cebuana)
• Withdrawal requests, amounts, dates, and destination payment details
• GCash mobile number or bank account details associated with withdrawals

3.4 Gaming Activity Data

• Game sessions, wager history, game outcomes, and account balance movements
• Responsible gaming tool settings (deposit limits, self-exclusion status)

3.5 Technical and Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Session timestamps and login history
• Cookies and similar tracking technologies (see Section 8)

3.6 Communications Data

• Content of live chat conversations with jl85 customer support
• Email correspondence sent to and received from jl85 support
• Records of complaints, disputes, and their resolution

4 How We Collect Data

jl85 collects personal data through the following channels:

• Directly from you — through account registration, identity verification submissions, deposit and withdrawal requests, and communications with our support team.
• Automatically — through the Platform's technical infrastructure, including server logs, cookies, session tracking, and similar technologies, when you access or use the Platform.
• From payment processors — transaction confirmation data from GCash, PayMaya, and banking partners to verify that deposits have been processed and withdrawals have been received.
• From identity verification services — where jl85 uses a third-party KYC provider to verify the authenticity of identification documents submitted by players.
• From regulatory and law enforcement authorities — where jl85 receives data requests as part of a lawful regulatory investigation or legal process.

5 How We Use Your Data

jl85 uses the personal data we collect for the following purposes:

• Account management: Creating, maintaining, and administering your jl85 account, processing logins, and securing access to your Wallet.
• Service delivery: Providing access to all games, processing deposits and withdrawals via GCash and other payment methods, and delivering customer support through live chat.
• Identity verification and fraud prevention: Verifying that you are who you say you are, confirming you meet the 21+ age requirement, and detecting and preventing fraudulent, abusive, or illegal activity on the Platform.
• Regulatory compliance: Meeting our obligations under PAGCOR regulations and Philippine anti-money laundering law, including maintaining transaction records and filing required reports to regulatory authorities.
• Responsible gaming: Monitoring gaming activity to identify patterns consistent with problematic gambling behaviour, and administering self-exclusion and deposit limit tools where requested by players.
• Platform security: Detecting and responding to security threats, investigating suspicious login activity, and maintaining the integrity of the jl85 Platform.
• Communication: Sending account-related notifications such as withdrawal confirmations, security alerts, and support replies through your registered mobile number or via Platform notifications.
• Legal proceedings: Establishing, exercising, or defending legal claims where jl85 is a party to a dispute or regulatory proceeding.

6 Legal Basis for Processing

Under the Philippines' Data Privacy Act of 2012 and its Implementing Rules, personal data may only be processed where a lawful basis exists. jl85 relies on the following bases for processing your personal data:

• Contractual necessity: Processing your registration data, financial transaction data, and gaming activity data is necessary to perform the contract between you and jl85 (i.e., to operate your account and deliver the Platform's services).
• Legal obligation: Processing for identity verification (KYC), anti-money laundering compliance, and regulatory reporting is necessary to comply with obligations under Philippine law and PAGCOR directives.
• Legitimate interests: Processing for security monitoring, fraud detection, and improvement of Platform functionality is carried out in pursuit of jl85's legitimate interests, provided that these interests are not overridden by your fundamental privacy rights.
• Consent: Where jl85 sends you marketing or promotional communications, we do so on the basis of your consent, which you may withdraw at any time by contacting support via live chat.

7 Data Sharing and Disclosure

jl85 does not share your personal data with third parties except in the following circumstances:

7.1 Payment Processors

Your GCash mobile number, PayMaya details, BPI, BDO, or Metrobank account information are shared with the relevant payment processor solely to facilitate your deposit or withdrawal transaction. These processors operate under their own privacy policies and are subject to applicable Philippine data protection regulations.

7.2 Identity Verification Providers

Where jl85 uses a third-party KYC service to verify your identity documents, the relevant identity information is shared with that provider solely for the purpose of verification. Such providers are engaged under appropriate data processing agreements.

7.3 Regulatory Authorities

jl85 is required by Applicable Law to share transaction records, player information, and related data with PAGCOR and other Philippine regulatory authorities, the Anti-Money Laundering Council (AMLC), and law enforcement agencies where required by a valid legal order or regulatory directive.

7.4 Legal Proceedings

jl85 may disclose personal data to legal advisors, courts, or opposing parties in legal proceedings where disclosure is necessary for the establishment, exercise, or defence of legal claims.

7.5 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets involving jl85, player data may be transferred to the relevant successor entity, subject to appropriate privacy protections and advance notice to affected players where required by law.

8 Cookies and Tracking Technologies

jl85 uses cookies and similar tracking technologies on the Platform to support the following functions:

• Session cookies: Maintain your logged-in state across pages during an active session. These are deleted when you close your browser.
• Functional cookies: Remember your preferences (such as language settings) to improve your experience on subsequent visits.
• Security cookies: Support login security by detecting suspicious access patterns and preventing session hijacking.
• Analytics cookies: Collect aggregated, anonymised data about Platform usage to help jl85 understand how the Platform is used and identify areas for improvement. This data does not identify individual players.

You may configure your browser to refuse or delete cookies; however, disabling certain cookies may affect the functionality of the Platform, including your ability to remain logged in during a gaming session.

9 Data Retention

jl85 retains your personal data for as long as your account is active and for such additional periods as are required by Applicable Law or justified by legitimate operational needs. Specific retention periods include the following:

• Account and registration data: Retained for the lifetime of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements.
• Financial transaction data: Retained for a minimum of ten (10) years from the date of the transaction, in compliance with Philippine anti-money laundering regulations.
• KYC / identity verification data: Retained for the duration of your account and for five (5) years following account closure.
• Customer support communications: Retained for three (3) years from the date of the interaction, or longer where the communication relates to an unresolved dispute or legal proceeding.
• Technical and security logs: Retained for up to twelve (12) months on a rolling basis, unless a longer period is required for an active security investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

10 Data Security

jl85 employs technical and organisational security measures commensurate with the sensitivity of the personal data we process. Key security measures include:

• 256-bit SSL/TLS encryption on all data transmissions between your device and the jl85 Platform.
• Cryptographic password hashing — your password is stored as a one-way hash and cannot be recovered or read by jl85 staff.
• Access controls — personal data is accessible only to jl85 personnel and authorised processors who require access for legitimate operational purposes.
• Intrusion detection systems — the Platform monitors for unauthorised access attempts and security anomalies in real time.
• Regular security assessments — jl85 conducts periodic reviews of its security posture to identify and address vulnerabilities.

11 Your Rights as a Data Subject

Under the Philippines' Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl85. These rights may be exercised by contacting jl85 support via live chat:

• Right to be Informed: The right to be notified of how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of Access: The right to obtain a copy of the personal data jl85 holds about you and information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by jl85.
• 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 overriding legal retention obligations.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Object: The right to object to processing of your personal data on the grounds of legitimate interests, particularly where you feel such processing is disproportionate to jl85's stated interests.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that jl85 has processed your personal data in violation of the Data Privacy Act of 2012.

jl85 will respond to data subject requests within a reasonable timeframe and in any case within thirty (30) calendar days of receipt. Some requests may require identity verification before they can be processed, to ensure that data is not disclosed to, or deleted at the request of, an unauthorised person.

12 Children and Minors

The jl85 Platform is strictly intended for individuals aged 21 years and above. jl85 does not knowingly collect personal data from individuals under the age of 21. Registration requires confirmation of age eligibility, and jl85 enforces age verification measures in compliance with PAGCOR regulations.

If jl85 becomes aware that personal data has been collected from a person under the age of 21 without appropriate parental or guardian consent, the relevant account will be immediately closed, the personal data will be deleted, and any funds in the account will be handled in accordance with applicable regulatory requirements.

If you have reason to believe that a minor has created an account on jl85, please notify us immediately via the live chat support function so that appropriate action can be taken without delay.

13 Cross-Border Data Transfers

Where jl85 uses service providers located outside the Philippines — such as cloud infrastructure providers, identity verification services, or technology partners — your personal data may be transferred to and processed in a jurisdiction other than the Philippines.

jl85 ensures that any cross-border transfer of personal data is conducted in accordance with the Data Privacy Act of 2012 and applicable NPC guidelines. This may include requiring recipient organisations to adhere to appropriate data protection standards, executing data transfer agreements, or relying on recognised legal mechanisms for international data transfers.

In all cases, jl85 retains responsibility for the security and appropriate use of your personal data, regardless of the geographic location of the service provider processing it on our behalf.

14 Changes to This Policy

jl85 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform functionality. When material changes are made, jl85 will notify registered players via the Platform or through their registered mobile number, and will update the "Effective Date" displayed at the top of this document.

Your continued use of the jl85 Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the amended Policy, you may exercise your right to close your account as described in our Terms and Conditions.

15 Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way jl85 processes your personal data, please contact us through:

• Live Chat: Available 24 hours a day, 7 days a week, directly through the jl85 Platform. This is the fastest way to reach our team for privacy-related requests. Average response time is under 2 minutes.
• Support Email: [email protected] — for written privacy requests or formal complaints that require a documented record.

If you are not satisfied with jl85's response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data protection matters under the Data Privacy Act of 2012.