Privacy Policy – jll16

Introduction

jll16 ("jll16," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the jll16 online casino and sports betting platform (the "Platform"). This Privacy Policy ("Policy") describes how jll16 collects, uses, stores, shares, and protects personal information in connection with your use of the Platform and any related services.

This Policy applies to all registered players, visitors to the jll16 website, and any other individuals whose personal data jll16 processes in the course of operating the Platform. By registering an account or 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.

jll16 processes personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and the implementing rules and regulations issued by the National Privacy Commission (NPC). Where applicable, jll16 also observes internationally recognized data protection principles.

Personal Data We Collect

jll16 collects the following categories of personal data from players and Platform users:

Identity and Contact Information:

• Full legal name, date of birth, and gender;
• Residential address, city, province, and postal code;
• Mobile phone number and email address;
• Government-issued identification documents (e.g., Philippine passport, driver's license, SSS/GSIS ID, PhilSys ID) submitted for identity and age verification purposes.

Financial Information:

• GCash account number or PayMaya account details used for deposits and withdrawals;
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where applicable;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references;
• Account balance and wagering history.

Technical and Usage Data:

• IP address, device type, operating system, and browser type;
• Login timestamps, session duration, and pages visited on the Platform;
• Game activity logs, betting history, and bonus usage records;
• Geolocation data (city/region level) derived from IP address.

Communications Data:

• Records of communications with jll16 customer support, including live chat transcripts and email correspondence;
• Responses to surveys, promotions, or feedback requests.

How We Collect Your Data

jll16 collects 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, server logs, and similar tracking technologies;
• Third-party sources: Identity verification data from KYC (Know Your Customer) service providers; fraud detection signals from payment processors; and publicly available information used to verify the accuracy of data you have provided.

jll16 does not collect sensitive personal information (as defined under the Data Privacy Act of 2012) unless it is strictly necessary for regulatory compliance, such as for anti-money laundering (AML) verification purposes, and only with your explicit consent where required by law.

How We Use Your Personal Data

jll16 uses the personal data it collects for the following purposes:

• Account management: To register and maintain your jll16 account, verify your identity and age, and manage your account settings and preferences;
• Service delivery: To process deposits and withdrawals, provide access to games and betting markets, and deliver the core functionality of the Platform;
• Regulatory compliance: To comply with PAGCOR-compliant operational requirements, anti-money laundering (AML) obligations, and the Data Privacy Act of 2012, including mandatory record-keeping and reporting obligations;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct;
• Customer support: To respond to your enquiries, resolve complaints, and provide assistance with account and transaction issues;
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce deposit limits and self-exclusion requests, and provide responsible gaming tools;
• Platform improvement: To analyze usage patterns, conduct internal research, and improve the performance, features, and user experience of the Platform;
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications or where jll16 has a legitimate interest in doing so.

Legal Basis for Processing

jll16 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing required to perform the contract between you and jll16, including account registration, payment processing, and service delivery;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR compliance requirements, and tax reporting;
• Legitimate interests: Processing necessary for jll16's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications and certain cookie uses. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing and Disclosure

jll16 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. jll16 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals;
• Identity verification providers: KYC and AML service providers engaged to verify player identity and age in compliance with regulatory requirements ;
• Game content providers: Third-party game studios and software providers whose games are accessible through the jll16 Platform, who may receive limited technical data necessary to deliver game content;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulatory mandate;
• Law enforcement: Philippine law enforcement agencies, where jll16 is legally compelled to disclose information or where disclosure is necessary to prevent or investigate suspected criminal activity;
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by jll16, subject to strict confidentiality obligations;
• Technology service providers: Cloud hosting, cybersecurity, analytics, and customer support platform providers engaged by jll16 to operate and maintain the Platform, subject to data processing agreements that require them to process data only on jll16's instructions.

Where jll16 shares personal data with third-party service providers, it requires those providers to implement appropriate technical and organizational security measures and to process personal data only for the purposes specified by jll16.

Data Retention

jll16 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your active account relationship with jll16, and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements under Philippine law;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR compliance obligations;
• Customer support records: Retained for up to three (3) years from the date of the last interaction, unless a longer retention period is required for the resolution of a dispute or legal claim;
• Marketing consent records: Retained for the duration of your consent and for a reasonable period thereafter to demonstrate compliance with consent requirements;
• Technical and usage logs: Retained for up to twelve (12) months, unless a longer period is required for security investigation or fraud prevention purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with jll16's data disposal procedures.

Data Security

jll16 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jll16's servers;
• Encryption of sensitive data fields at rest within jll16's databases;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists;
• Continuous monitoring of systems for unauthorized access attempts and anomalous activity;
• Formal data breach response procedures, including notification to the National Privacy Commission and affected individuals within the timeframes required by the Data Privacy Act of 2012.

While jll16 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your jll16 account credentials and for notifying jll16 immediately if you suspect unauthorized access to your account.

Cookies and Tracking Technologies

jll16 uses cookies and similar tracking technologies (including web beacons and local storage) to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, authentication, and security features. These cookies cannot be disabled without affecting core Platform functionality;
• Functional cookies: Used to remember your preferences, such as language settings, display preferences, and previously visited game categories, to provide a more personalized experience;
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the Platform, including pages visited, session duration, and navigation paths, to help jll16 improve Platform performance and user experience;
• Marketing cookies: Used to deliver relevant promotional content and to measure the effectiveness of jll16's marketing campaigns. These cookies are only placed with your consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality and performance of the jll16 Platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

Your Data Privacy Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by jll16:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data jll16 holds about you, along with information about how it is being processed;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held by jll16;
• 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 jll16's 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 jll16's legitimate interests;
• Right to data portability: The right to receive a copy of personal data you have provided to jll16 in a structured, commonly used, and machine-readable format;
• 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 prior processing;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe jll16 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact jll16's Data Protection Officer via the contact details provided in Section 14 of this Policy. jll16 will respond to all verified requests within the timeframes required by applicable law.

Children's Privacy

The jll16 Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming regulations. jll16 does not knowingly collect personal data from individuals under the age of 21.

If jll16 becomes aware that personal data has been collected from a person under the age of 21, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on the jll16 Platform, please contact our support team immediately so that appropriate action can be taken.

Age verification is a mandatory step in the jll16 registration process. jll16 reserves the right to request documentary proof of age at any time and to suspend accounts pending satisfactory verification.

Third-Party Links and Services

The jll16 Platform may contain references to third-party game providers and payment services that operate under their own privacy policies. jll16 is not responsible for the privacy practices of third-party service providers whose services are integrated into the Platform.

When you interact with a third-party payment provider such as GCash or PayMaya to complete a deposit or withdrawal, your transaction data is also subject to that provider's own privacy policy and terms of service. jll16 encourages you to review the privacy policies of any third-party services you use in connection with the Platform.

jll16 does not control and is not responsible for the content, privacy practices, or data handling of any third-party services, and the inclusion of any third-party service on the Platform does not constitute an endorsement of that service's privacy practices.

Updates to This Privacy Policy

jll16 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or jll16's data processing practices. The date of the most recent revision will be indicated at the top of this page.

Where changes to this Policy are material, jll16 will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy.

jll16 recommends that you review this Privacy Policy periodically to stay informed of how your personal data is being protected. If you have any concerns about changes to this Policy, please contact our Data Protection Officer using the details in Section 14.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or jll16's data processing practices, you may contact our Data Protection Officer. jll16 is committed to addressing all privacy-related enquiries promptly and transparently.

Our customer support team is available 24 hours a day, 7 days a week via live chat on the Platform. For formal data privacy requests or complaints, please submit your enquiry in writing to the following address (plain text — not a clickable link):

Email: [email protected]

Please include your full name, registered email address, and a clear description of your request or concern. jll16 will acknowledge all written privacy requests within three (3) business days and provide a substantive response within fifteen (15) business days, or within such other period as may be required by applicable law.

If you are not satisfied with jll16's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.