jl13 Privacy Policy

1. Who We Are (Data Controller)

For the purposes of Republic Act 10173 (Data Privacy Act of 2012) and applicable PAGCOR data governance requirements, jl13.club ("jl13", "we", "us", "our") acts as the Data Controller responsible for personal information collected through the jl13 Platform. The jl13 Platform is an online casino and sports betting service regulated by PAGCOR and accessible at jl13.club, serving Filipino players across the Philippines, including those in Metro Manila, Cebu, Davao, Quezon City, Makati, and all other regions.

Our designated Data Protection Officer (DPO) can be reached at [email protected]. All data-related inquiries, requests, and complaints should be directed to the DPO in the first instance.

2. Personal Data We Collect

jl13 collects the following categories of personal data from Players and visitors to jl13.club:

2.1 Registration & Identity Data

• Full legal name as it appears on a valid Philippine government-issued ID.
• Date of birth (for age verification — 21+ requirement).
• Registered Philippine mobile number (for account authentication and OTP delivery).
• Email address.
• Physical address within the Philippines.

2.2 Identity Verification (KYC) Data

• Copy of a valid Philippine government-issued ID (UMID, PhilSys ID, driver's license, or Philippine passport).
• Selfie photograph taken at the time of KYC submission.
• Proof of address documents where required by PAGCOR compliance procedures.

2.3 Financial Data

• GCash or PayMaya mobile number associated with deposit/withdrawal transactions.
• Bank account details (account name, bank name, account number) where bank transfer methods are used.
• Transaction records: deposit amounts, withdrawal amounts, dates, and method of payment.

2.4 Gaming & Behavioural Data

• Game session records: games played, bet amounts, outcomes, session duration, and timestamps.
• Sports betting records: markets wagered on, stake amounts, odds taken, and settlement outcomes.
• Bonus usage history and wagering activity records.
• Responsible gaming tool settings: deposit limits, session limits, self-exclusion status.

2.5 Technical & Device Data

• IP address at time of registration and login.
• Device type, operating system, and browser version.
• Session timestamps and geolocation data (country/region level).
• Cookie identifiers and similar tracking technology data as described in Section 8.

3. How We Collect Personal Data

jl13 collects personal data through the following means:

• Direct submission: Information you provide when registering for a jl13 account, completing KYC verification, making deposits or withdrawals, contacting customer support, or updating your profile settings.
• Automated collection: Technical and behavioural data collected automatically when you use the jl13 Platform, including through cookies, server logs, and analytics tools.
• Third-party sources: Identity verification data cross-referenced with Philippine government ID databases where applicable, and fraud screening information received from payment providers including GCash and PayMaya.
• PAGCOR compliance channels: Information received from PAGCOR or other Philippine regulatory authorities in the context of their oversight functions.

4. Purposes of Processing Your Personal Data

jl13 processes your personal data for the following specific purposes:

• Account registration, authentication, and management — including login verification and OTP delivery.
• Identity verification (KYC) and ongoing monitoring as required by PAGCOR and AMLA regulations.
• Processing deposits, withdrawals, and maintaining accurate transaction records in Philippine Peso.
• Providing customer support to Filipino players, including resolving account issues, payment disputes, and game complaints.
• Administering bonuses and promotional offers and verifying compliance with promotion terms.
• Detecting and preventing fraud, money laundering, bonus abuse, and other prohibited conduct on the jl13 Platform.
• Implementing and monitoring responsible gaming tools, including deposit limits, session controls, and self-exclusion.
• Complying with PAGCOR regulatory reporting obligations, AMLA filing requirements, and other applicable Philippine laws.
• Improving the jl13 Platform through analysis of aggregated usage data and player behaviour patterns.
• Sending service communications — account notifications, security alerts, transaction confirmations — to your registered contact details.

5. Legal Basis for Processing

jl13 processes personal data on the following lawful bases under RA 10173:

• Consent: Where you have given clear, informed consent — for example, for marketing communications or optional profiling features.
• Contractual necessity: Processing required to perform the jl13 Player Agreement, including account management, game provision, and payment processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA, RA 10173, and other applicable Philippine laws.
• Legitimate interest: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights.

6. Sharing Your Personal Data

jl13 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Personal data may be shared only in the following circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to the extent necessary to process your deposits and withdrawals.
• Game providers: Third-party game studios (such as Pragmatic Play, PG Soft, Evolution) that provide game software to the jl13 Platform receive session data necessary to run individual game rounds.
• KYC and identity verification providers: Third-party identity verification services used to cross-reference your submitted KYC documents against official Philippine records.
• PAGCOR and Philippine authorities: Where required by PAGCOR's regulatory oversight, AMLA reporting obligations, a Philippine court order, or other lawful authority.
• Fraud prevention agencies: Where jl13 has reasonable grounds to suspect fraudulent activity, relevant data may be shared with fraud prevention bodies in the Philippines.

All third parties that process personal data on behalf of jl13 are bound by contractual data processing agreements requiring them to maintain appropriate data protection standards consistent with RA 10173.

7. Data Retention

jl13 retains personal data only for as long as necessary for the purposes for which it was collected, subject to the following retention periods:

• Account and KYC data: Retained for the duration of your active jl13 account plus a minimum of 5 years after account closure, as required by AMLA and PAGCOR regulations.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction, in compliance with AMLA record-keeping requirements.
• Game session records: Retained for 12 months from the date of each session for dispute resolution and regulatory audit purposes.
• Marketing consent records: Retained until withdrawn and for 3 years thereafter as evidence of consent compliance.
• Technical and device data: Retained for 12 months from collection for security and fraud detection purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with jl13's data destruction procedures.

8. Cookies & Tracking Technologies

jl13 uses cookies and similar tracking technologies on jl13.club for the following purposes:

• Essential cookies: Required for the Platform to function — session authentication, security tokens, and load balancing. These cannot be disabled without preventing access to jl13.
• Functional cookies: Remember your Platform preferences — language settings, game display options, and responsible gaming tool configurations.
• Analytics cookies: Used to analyse how Filipino players navigate jl13.club, identify technical issues, and improve Platform performance. Data is aggregated and does not personally identify individual users.
• Session security cookies: Used to detect and prevent session hijacking and cross-site request forgery (CSRF) attacks on your jl13 account.

You may manage non-essential cookies through your browser settings. Note that disabling functional cookies may affect your jl13 Platform experience.

9. Your Rights as a Data Subject

Under Republic Act 10173, Filipino players whose personal data is processed by jl13 have the following rights:

• Right to Access: You may request a copy of all personal data jl13 holds about you. Requests will be fulfilled within 20 working days.
• Right to Correction: You may request correction of inaccurate or incomplete personal data in your jl13 account at any time via your account profile or through customer support.
• Right to Erasure: You may request deletion of your personal data where jl13 no longer has a lawful basis for retaining it. Note that erasure requests cannot override legal retention obligations under AMLA and PAGCOR regulations.
• Right to Object: You may object to processing of your personal data on grounds of legitimate interest, particularly for profiling and marketing purposes.
• Right to Data Portability: You may request your personal data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact jl13's DPO at [email protected] with the subject line "Data Subject Request". jl13 will acknowledge your request within 3 business days and respond in full within 20 working days.

10. Data Security Measures

jl13 implements the following technical and organisational security measures to protect your personal data:

• TLS 1.3 encryption for all data in transit between your device and jl13.club servers.
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records.
• Bcrypt password hashing with salting — jl13 does not store plain-text passwords.
• Multi-factor authentication (OTP) for account access and high-value transactions.
• Regular penetration testing and vulnerability assessments by independent security firms.
• Strict internal access controls — jl13 staff access to personal data is limited to those with a demonstrated operational need.
• Comprehensive audit logging of all internal data access events.

11. Minors and Age Restriction

The jl13 Platform is strictly intended for persons aged 21 years and above. jl13 does not knowingly collect or process personal data from individuals under the age of 21. As part of the registration and KYC process, jl13 verifies the age of all Players. If jl13 becomes aware that personal data has been collected from a person under 21, that data will be immediately deleted and the associated account permanently closed in accordance with PAGCOR regulations.

Parents and guardians who believe a minor may have registered for jl13 are encouraged to contact [email protected] immediately for prompt investigation and resolution.

12. Third-Party Services and Links

The jl13 Platform may contain references to third-party game providers and payment services. This Privacy Policy applies solely to personal data processed by jl13 in connection with jl13.club. Third-party services — including GCash, PayMaya, and game provider platforms — operate under their own privacy policies and data practices, for which jl13 takes no responsibility. Players are encouraged to review the privacy policies of any third-party services they engage with.

13. Changes to This Privacy Policy

jl13 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or PAGCOR regulatory requirements. Where changes are material, jl13 will notify registered Players via their registered email address or via an in-Platform notification at least 14 days before the updated Policy takes effect. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. Continued use of jl13 after the effective date of any update constitutes acceptance of the revised Privacy Policy.

14. Contact & Data Protection Officer

For all privacy-related queries, data subject requests, or complaints regarding jl13's handling of your personal data, please contact our designated Data Protection Officer:

• Email: [email protected] (subject: "Privacy / Data Subject Request")
• Live Chat: Available 24/7 via the jl13 Platform for registered Players.

If you are not satisfied with jl13's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which supervises compliance with RA 10173 for all entities operating in the Philippine market.