jl10 Privacy Policy

jl10 ("jl10", "we", "us", "our"), the operator of the online gaming platform accessible at jl10.vip, is the personal information controller ("PIC") in respect of all personal data collected and processed through the jl10 platform.

As PIC, jl10 determines the purposes for which your personal data is processed and the means by which such processing is carried out. jl10 is responsible for ensuring that personal data is processed in compliance with the Data Privacy Act of 2012 and all applicable regulations issued by the National Privacy Commission.

This Privacy Policy applies to:

• All registered jl10 account holders ("Players") residing in or accessing the platform from the Philippines;
• Visitors to the jl10.vip website who have not yet registered an account;
• Any individual who interacts with jl10 through its customer support channels, whether by Live Chat, email, or any other medium; and
• Any individual whose personal data jl10 processes in connection with its legal, regulatory, or anti-money laundering compliance obligations.

This Policy does not apply to third-party websites or platforms that may be linked from jl10.vip, or to third-party payment providers and game software providers whose own privacy policies govern the processing of personal data on their respective systems.

jl10 collects and processes the following categories of personal data from Players and platform visitors:

jl10 does not collect sensitive personal information as defined under the Data Privacy Act of 2012 (such as race, religion, political affiliation, or health data) unless specifically required for the resolution of a responsible gaming matter or a legal or regulatory obligation, and only with your prior explicit consent where required by law.

jl10 processes your personal data for the following specific and legitimate purposes:

• Account Registration and Management: To create, verify, and maintain your jl10 account, including processing login events and account security actions.
• Identity Verification (KYC): To verify your identity and age (21+) as required by PAGCOR's online gaming regulations and jl10's anti-money laundering obligations.
• Financial Transaction Processing: To process GCash, Maya, bank transfer, and other payment method deposits and withdrawals on your behalf.
• Game Operation: To provide, log, and resolve game rounds, including live dealer sessions, slot spins, sports bets, bingo draws, and sabong wagering.
• Bonus and Promotion Administration: To verify eligibility, credit, and track the wagering requirements of promotions claimed by your account.
• Anti-Money Laundering (AML) Compliance: To monitor transactions for suspicious activity and fulfil jl10's obligations under the Anti-Money Laundering Act of 2001 (RA 9160) as amended, and PAGCOR's AML framework.
• Fraud Prevention and Platform Integrity: To detect, investigate, and prevent fraudulent activity, collusion, cheating, and abuse of the jl10 platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide assistance via Live Chat and email.
• Responsible Gaming: To administer deposit limits, loss limits, session time controls, self-exclusion requests, and to identify patterns of play that may indicate problem gambling behaviour.
• Legal and Regulatory Compliance: To comply with jl10's obligations under Philippine law, PAGCOR regulations, court orders, and lawful requests from regulatory authorities.
• Marketing and Promotions: To send promotional offers, game updates, and platform announcements to Players who have consented to receive marketing communications. This purpose is subject to your opt-out right, as described in Section 13.
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the jl10 platform experience for Philippine players.

jl10 processes your personal data on one or more of the following lawful bases, as recognised under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary for the performance of jl10's contract with you — specifically, the Terms and Conditions governing your jl10 account and platform access.
• Legal Obligation: Processing is required for jl10 to comply with applicable law, including PAGCOR's licensing and regulatory requirements, the Anti-Money Laundering Act, and lawful orders from regulatory authorities.
• Consent: Where processing is not required by contract or law, jl10 will seek your explicit consent, particularly for marketing communications and the processing of any sensitive personal information. Consent may be withdrawn at any time.
• Legitimate Interests: Processing is necessary for jl10's legitimate interests in operating a secure, fair, and commercially sustainable platform — provided those interests are not overridden by your fundamental rights and freedoms.

jl10 does not sell, rent, or trade your personal data. We share personal data only in the following circumstances and only to the extent strictly necessary for the stated purpose:

• Payment Processors: GCash (G-Xchange, Inc.), PayMaya Philippines, GrabPay Philippines, BPI, BDO, UnionBank, 7-Eleven CLiQQ operator, and other payment service providers receive the minimum data required to process your deposit or withdrawal transactions.
• Identity Verification Providers: Third-party KYC service providers receive identity documents and associated data to perform age and identity verification on jl10's behalf.
• Game Software Providers: Certified game providers (including but not limited to Pragmatic Play, PG Soft, and Evolution Gaming) receive session tokens and bet data necessary to operate the games accessed through your account. These providers do not receive your full identity profile.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, and courts of competent jurisdiction may receive personal data where jl10 is legally required to disclose it.
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by jl10 may access personal data under binding confidentiality obligations where necessary for the delivery of professional services.
• Group Companies: Where jl10 operates within a corporate group structure, personal data may be shared with affiliated entities for the purposes of group-level compliance, fraud prevention, and responsible gaming monitoring. All group entities are bound by data sharing agreements consistent with this Policy.

Some of jl10's service providers — including certain game software providers and KYC technology providers — may process personal data on servers located outside the Philippines. Where such cross-border transfers occur, jl10 ensures that appropriate safeguards are in place, including:

• Contractual data protection clauses that impose obligations on the receiving entity equivalent to those under the Philippine Data Privacy Act;
• Transfer to jurisdictions recognised by the NPC as providing adequate data protection; and/or
• The implementation of technical and organisational security measures appropriate to the sensitivity of the data transferred.

Cross-border transfers are conducted only where necessary for the operation of jl10's platform and in compliance with NPC guidelines on cross-border data flow.

jl10 retains personal data for as long as is necessary to fulfil the purposes described in Section 4, and in accordance with any minimum retention periods required by Philippine law or PAGCOR regulations:

• Account and Identity Data: Retained for the duration of your active jl10 account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Transaction and Betting History: Retained for a minimum of five (5) years from the date of each transaction, as required by anti-money laundering regulations.
• KYC Documents: Retained for a minimum of five (5) years following the completion of verification or account closure, whichever is later.
• Customer Support Communications: Retained for two (2) years from the date of the last support interaction, unless longer retention is required for dispute resolution or legal proceedings.
• Technical and Usage Data: Retained for a maximum of twelve (12) months, after which it is anonymised or deleted unless retention is required for security investigation purposes.
• Marketing Preferences: Retained until you withdraw consent or opt out of marketing communications.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original personal information.

jl10 implements a comprehensive set of technical, organisational, and physical security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction:

• Encryption in Transit: All data transmitted between your device and jl10's platform is encrypted using 256-bit SSL/TLS protocols.
• Encryption at Rest: Sensitive personal data stored on jl10's servers, including identity documents and financial data, is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted to jl10 personnel who require it to perform their job functions. Access is governed by role-based access controls, unique credentials, and activity logging.
• Two-Factor Authentication: jl10 offers and encourages the use of two-factor authentication (2FA) on all Player accounts as an additional layer of access security.
• Regular Security Audits: jl10's security infrastructure is subject to regular internal audits and periodic third-party penetration testing to identify and remediate vulnerabilities.
• Incident Response: jl10 maintains a documented data breach response procedure. In the event of a breach affecting Player data, jl10 will notify affected individuals and the NPC within the timeframes prescribed by the Data Privacy Act and NPC Circular No. 16-03.

jl10 uses cookies and similar tracking technologies on the jl10.vip website to operate the platform, improve your experience, and fulfil our security and compliance obligations. The types of cookies used by jl10 include:

• Strictly Necessary Cookies: These cookies are essential for the operation of the jl10 platform. They enable core functionality such as user authentication, session management, and security features. These cookies cannot be disabled without impairing platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymised or aggregated data about how Players use the jl10 platform — including which pages are visited most frequently and how Players navigate between sections. This data helps jl10 improve platform performance and user experience.
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred language or login method — to provide a more personalised experience on subsequent visits.
• Security Cookies: These cookies support jl10's fraud prevention and account protection systems by detecting unusual access patterns, managing session validity, and flagging suspicious activity.

jl10 does not use third-party advertising or behavioural tracking cookies on the jl10.vip platform. You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies may affect your ability to log in and use the platform.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data processed by jl10. These rights may be exercised by contacting jl10's Data Protection Officer as described in Section 15: