Privacy Policy

1 Introduction

jl165.club ("jl165," "we," "us," "our") operates a licensed online casino and sports betting platform serving Filipino players. This Privacy Policy ("Policy") describes how jl165 processes personal data in connection with your use of the jl165 website, mobile platform, games, support services, and all associated features (collectively, "the Services").

By registering a jl165 account, using the jl165 login page, or otherwise accessing the Services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not consent to these practices, you must not use the jl165 platform.

This Policy is governed by Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations, as overseen by the National Privacy Commission (NPC). jl165 is also subject to PAGCOR's data handling requirements applicable to licensed online gaming operators.

2 Data We Collect

jl165 collects personal data in the following categories:

2.1 Registration Data

When you create a jl165 account, we collect: full legal name, date of birth, nationality, residential address (including city, province, and postal code), email address, and Philippine mobile number. This information is mandatory for account creation and age verification (21+ requirement).

2.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and anti-money laundering (AML) requirements, jl165 requires identity verification before processing withdrawals. KYC data may include: a copy of a government-issued photo ID (UMID, SSS ID, PhilHealth ID, driver's licence, or Philippine passport), a selfie with your ID, and proof of address (utility bill, bank statement, or barangay certificate dated within 90 days).

2.3 Financial Data

jl165 records all deposit and withdrawal transactions, including payment method details (GCash mobile number, Maya account reference, bank account numbers, crypto wallet addresses for USDT TRC20 transactions). jl165 does not store full payment card numbers. Payment method data is processed through certified third-party payment providers under their respective privacy frameworks.

2.4 Gaming Activity Data

jl165 automatically logs: game session timestamps, wager amounts, game outcomes, bonus claims and wagering progress, sports betting activity, and session duration. This data is used for account management, responsible gaming monitoring, fraud detection, and regulatory compliance.

2.5 Technical and Device Data

When you access jl165, we automatically collect: IP address, device type and model, operating system, browser type and version, screen resolution, session cookies, and login timestamps. This data is used for security, fraud prevention, geographic access control, and platform optimisation.

2.6 Support Communication Data

When you contact jl165 support via live chat or email, we retain records of your communications, including the content of messages and any attached documents, for quality assurance and dispute resolution purposes.

3 How We Use Your Data

jl165 processes your personal data for the following lawful purposes:

• Account Management: Creating, maintaining, verifying, and securing your jl165 account;
• Service Delivery: Processing deposits, withdrawals, game transactions, and bonus claims;
• Regulatory Compliance: Fulfilling PAGCOR licensing obligations, AML/KYC verification, and age verification (21+ enforcement);
• Fraud Prevention and Security: Detecting, investigating, and preventing unauthorised access, fraud, money laundering, and terms violations;
• Responsible Gaming: Monitoring for indicators of problem gambling behaviour and administering self-exclusion, deposit limits, and cool-off periods;
• Customer Support: Responding to enquiries, resolving disputes, and improving support quality;
• Platform Improvement: Analysing aggregated, anonymised usage data to improve jl165 services, game selection, and payment infrastructure;
• Communications: Sending transactional notifications (deposit confirmations, withdrawal status, security alerts) and, where you have opted in, promotional communications about jl165 bonuses and offers.

jl165 does not use your personal data for automated individual decision-making that produces legal or similarly significant effects without human oversight.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012, jl165 processes personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the jl165 Terms & Conditions agreement with you (account operation, payment processing, game delivery);
• Legal Obligation: Processing required to comply with PAGCOR regulations, AML laws, and other applicable Philippine statutory requirements;
• Legitimate Interests: Fraud prevention, security monitoring, and platform improvement — where these interests do not override your fundamental privacy rights;
• Consent: Promotional communications, where you have explicitly opted in. You may withdraw this consent at any time via Account Settings → Notifications.

5 Data Sharing and Disclosure

jl165 does not sell, rent, or trade your personal data to third parties. We share your data only in the following circumstances:

• Payment Processors: GCash (Mynt), Maya (Voyager), GrabPay, bank partners (BPI, BDO, Metrobank), and other payment providers receive the minimum data necessary to process your transactions. Each processor operates under its own privacy policy and regulatory framework.
• Game Providers: Licensed game studios (Pragmatic Play, PG Soft, Jili, Evolution Gaming, etc.) may receive anonymised session data for game performance monitoring. No personally identifiable information is transmitted to game providers.
• KYC / AML Verification Partners: Identity verification may be conducted through certified third-party KYC service providers. These providers process your ID documents solely for verification purposes under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities may require access to account and transaction data in the exercise of their regulatory functions. jl165 will comply with all lawful requests.
• Legal Proceedings: jl165 may disclose personal data where required by court order, subpoena, or other valid legal process.

All third-party processors engaged by jl165 are bound by contractual data processing agreements that prohibit unauthorised use of your personal data.

6 Data Retention

jl165 retains personal data for the following periods:

• Active Account Data: Retained for the duration of your account's active status plus 5 years following closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act;
• KYC Documents: Retained for a minimum of 5 years from the date of verification, as required by the AMLC;
• Transaction Records: Retained for a minimum of 5 years from transaction date;
• Support Communications: Retained for 2 years from the date of last interaction;
• Technical / Session Logs: Retained for 12 months, then anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with the DPA's disposal standards.

7 Cookies and Tracking Technologies

jl165 uses the following types of cookies and similar technologies on jl165.club:

• Strictly Necessary Cookies: Session cookies required for login authentication, security, and platform functionality. Cannot be disabled without preventing core service use.
• Functional Cookies: Cookies that remember your preferences (language, currency display, game history). These enhance your jl165 experience but are not essential.
• Analytics Cookies: Anonymised usage data used to understand how players navigate jl165, identify performance issues, and improve the platform. No personally identifiable data is transmitted to analytics services.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the jl165 login and gaming functions.

8 Data Security

jl165 implements industry-standard technical and organisational measures to protect your personal data, including:

• 256-bit SSL/TLS encryption on all data transmitted between your device and jl165 servers;
• Encrypted storage of sensitive personal and financial data at rest;
• Role-based access controls limiting data access to authorised jl165 personnel on a need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Multi-factor authentication for all jl165 administrative systems.

Notwithstanding these measures, no internet transmission is completely secure. jl165 cannot guarantee absolute security and recommends that you also take personal responsibility for securing your jl165 login credentials.

In the event of a personal data breach that poses a risk to your rights and freedoms, jl165 will notify the National Privacy Commission within 72 hours of discovery and will inform affected data subjects without undue delay, in accordance with the DPA's breach notification requirements.

9 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl165:

• Right to Be Informed: The right to know what personal data jl165 holds about you and how it is processed — fulfilled by this Policy;
• Right of Access: The right to request a copy of your personal data held by jl165;
• Right to Rectification: The right to correct inaccurate or incomplete personal data in your jl165 account;
• Right to Erasure: The right to request deletion of personal data where retention is no longer legally required — subject to jl165's regulatory retention obligations;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, contact jl165's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." jl165 will respond within 15 business days.

10 Children and Minors

jl165 is strictly prohibited from collecting personal data from individuals under the age of 21. The jl165 platform is exclusively for adults who meet the minimum age requirement under PAGCOR regulations. jl165 employs age verification measures during registration and KYC processes to prevent underage access.

If jl165 becomes aware that personal data has been collected from a person under 21 years of age, that account will be immediately suspended, all associated data will be deleted (subject to any mandatory AML retention requirements), and any funds will be returned via the original payment method.

11 Changes to This Policy

jl165 reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered players via email to the address registered on your jl165 account and/or via a prominent notice on jl165.club. Continued use of jl165 following notification of an updated Policy constitutes acceptance of the revised terms.

The effective date at the top of this Policy indicates when the current version took effect. Previous versions are available upon request by contacting jl165 support.

12 Contact and Data Protection Officer

For all privacy-related enquiries, data subject rights requests, or concerns about jl165's data practices, please contact:

• Data Protection Officer, jl165.club
• Email: [email protected] (subject: "Data Privacy Request")
• Live Chat: Available 24/7 within your jl165 account dashboard
• Support Page: jl165.club/support

For regulatory complaints, data subjects in the Philippines may also contact the National Privacy Commission (NPC) through its official channels at privacy.gov.ph.