jl10 Privacy Policy

1. Introduction

jl10 ("we", "us", "our", "the Platform") operates the online gaming platform available at jl10.org and its associated mobile applications and services (the "Services"). We are committed to protecting the personal data and privacy of all individuals who use the jl10 platform ("Players", "Users", "you").

This Privacy Policy ("Policy") describes how jl10 collects, uses, stores, shares, and otherwise processes personal information in connection with the Services. It is issued in compliance with Republic Act No. 10173 (the Data Privacy Act of 2012, "DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission of the Philippines ("NPC").

By creating a jl10 account, accessing the Services, or otherwise providing your personal information to jl10, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree to this Policy, you must not use the jl10 Services.

This Policy should be read together with the jl10 Terms & Conditions, which govern the overall relationship between you and jl10.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and its IRR, jl10 acts as the Personal Information Controller (PIC) in respect of the personal data collected through the jl10 platform. This means jl10 determines the purposes and means of processing personal data collected from Players and Users of the Services.

Where jl10 engages third-party service providers to process personal data on jl10's instructions — for example, payment processors, identity verification providers, and cloud infrastructure partners — those parties act as Personal Information Processors (PIPs) under binding data processing agreements that require them to maintain confidentiality and security standards consistent with jl10's obligations under the DPA.

jl10 has designated a Data Protection Officer (DPO) as required under Section 21 of the DPA. The DPO can be contacted through the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

jl10 collects the following categories of personal data in connection with the operation of the Services:

jl10 does not intentionally collect sensitive personal information as defined under Section 3(l) of the DPA (such as health data, political affiliation, or religious beliefs) except where strictly required for responsible gaming assessments (e.g., problem gambling self-declarations) or as required by law.

4. How We Collect Your Personal Data

jl10 collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, respond to a survey, or participate in a promotion.
• Automatically: When you access and use the jl10 platform, we collect technical and usage data through server logs, session tracking, cookies, and similar technologies as described in Section 10.
• From third-party identity verification providers: Where jl10 uses an authorised third-party service to verify the authenticity of identity documents submitted during KYC, limited verification results are shared with jl10.
• From payment providers: Payment processors such as GCash, PayMaya, and banking institutions provide transaction confirmation data to jl10 in connection with deposit and withdrawal processing.
• From PAGCOR and regulatory bodies: jl10 may receive information about Players from PAGCOR in connection with its regulatory obligations, including player protection and exclusion notifications.

5. How jl10 Uses Your Personal Data

jl10 processes your personal data for the following purposes:

5.1 Account Management

To create and maintain your jl10 account, authenticate your identity at login, process account settings changes, and provide you with access to the Services.

5.2 KYC and Regulatory Compliance

To verify your identity and age (21+) as required by PAGCOR's licensing conditions, to comply with the Anti-Money Laundering Act of 2001 (RA 9160 as amended), and to fulfil jl10's obligations as a PAGCOR-licensed operator including the submission of required regulatory reports.

5.3 Transaction Processing

To process deposits to your jl10 wallet via GCash, PayMaya, bank transfer, and other accepted methods; to process withdrawal requests to your verified payment account; and to maintain accurate financial records in connection with your jl10 account activity.

5.4 Customer Support

To respond to your enquiries, complaints, and support requests submitted through live chat, email, or any other jl10 support channel. Support records may be retained for quality assurance and regulatory audit purposes.

5.5 Platform Improvement & Security

To monitor platform performance, detect and prevent fraud, unauthorised access, money laundering, and other prohibited activity; to conduct security investigations; and to improve the functionality, stability, and content of the jl10 platform based on aggregated usage analysis.

5.6 Responsible Gaming

To enforce PAGCOR player protection requirements including age verification, self-exclusion processing, deposit limit management, and the identification of potentially vulnerable players for appropriate intervention.

5.7 Marketing Communications

Where you have provided your explicit consent, to send you information about jl10 promotions, bonuses, new games, and platform updates via SMS, email, or push notification. You may withdraw marketing consent at any time through your account notification settings.

6. Legal Bases for Processing

Under the Data Privacy Act of 2012, jl10 relies on the following lawful bases for processing your personal data:

• Contractual necessity (Section 12(b) DPA): Processing necessary for the performance of the contract between you and jl10, including account operation, transaction processing, and customer support.
• Legal obligation (Section 12(c) DPA): Processing required for jl10 to comply with its PAGCOR licence conditions, AML obligations under RA 9160, tax obligations, and other applicable Philippine law.
• Legitimate interests (Section 12(f) DPA): Processing for fraud prevention, platform security, responsible gaming enforcement, and service improvement, where these interests are not overridden by your data protection rights.
• Consent (Section 12(a) DPA): Processing for direct marketing communications and optional analytics features, where you have provided freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without detriment to your account.

7. Data Sharing & Third-Party Disclosure

jl10 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients in the circumstances described:

7.1 Payment Processors

GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment providers receive only the data necessary to process your deposit or withdrawal request. These providers operate under their own privacy policies and applicable Bangko Sentral ng Pilipinas (BSP) regulations.

7.2 Identity Verification Providers

Where jl10 uses a third-party KYC verification service, your identity documents and the extracted identity data are shared with that provider under a data processing agreement. The provider processes your data solely to provide verification results to jl10 and is prohibited from using your data for any other purpose.

7.3 Regulatory and Law Enforcement Authorities

jl10 is required by Philippine law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), and law enforcement agencies where compelled by law, court order, or regulatory directive. Such disclosures are made to the minimum extent required by the applicable legal obligation.

7.4 Technology and Infrastructure Partners

jl10 uses cloud hosting, analytics, and security service providers to operate the platform. These providers act as Personal Information Processors under binding agreements that restrict their use of your data to providing services to jl10.

7.5 Game Content Providers

Game studios whose content is available on jl10 may receive aggregated, anonymised game performance data. Individual player identity data is not shared with game providers without your express consent.

8. Data Retention

jl10 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by law and regulation:

• Account and KYC records: Retained for a minimum of five (5) years from the date of account closure, as required under PAGCOR's record-keeping obligations and the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AML reporting requirements and BIR record-keeping obligations.
• Support communications: Retained for a minimum of two (2) years from the date of the communication, unless a longer retention period is required for ongoing disputes or regulatory proceedings.
• Technical and usage logs: Retained for up to twelve (12) months from collection, after which they are anonymised or deleted unless required for an ongoing security investigation.
• Marketing consent records: Retained for the duration of your consent, plus two (2) years following withdrawal of consent as an audit record.

Following the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original personal data.

9. Data Security

jl10 implements technical and organisational security measures appropriate to the nature of the personal data we process and the risks involved. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your browser or device and jl10's servers is encrypted in transit using industry-standard TLS encryption.
• Encryption at rest: Sensitive personal data — including identity documents, financial data, and password credentials — is encrypted in our databases using industry-standard algorithms.
• Password security: Passwords are stored using cryptographic hashing with salting. jl10 never stores or transmits passwords in plaintext.
• Access controls: Access to personal data within jl10's systems is restricted to authorised personnel who require the data to perform their job functions, based on the principle of least privilege.
• Incident response: jl10 maintains a documented personal data breach response procedure. In the event of a breach affecting your data, jl10 will notify you and the National Privacy Commission as required under Section 20(f) of the DPA.
• Third-party security assessments: Key technology partners undergo security assessments prior to onboarding and are contractually required to maintain security standards consistent with jl10's obligations.

While jl10 takes all reasonable steps to protect your personal data, no transmission or storage system is completely secure. You are also responsible for maintaining the security of your own account credentials as described in the jl10 Terms & Conditions.

10. Cookies & Similar Technologies

jl10 uses cookies and similar tracking technologies on the jl10 platform. A cookie is a small text file placed on your device when you access jl10. We use the following categories of cookies:

10.1 Strictly Necessary Cookies

These cookies are essential for the operation of the jl10 platform. They manage your login session, maintain your account state across pages, and enable security features such as CSRF protection. These cookies cannot be disabled without impairing core platform functionality.

10.2 Functional Cookies

These cookies remember your preferences — such as your chosen game lobby view, notification settings, and responsible gaming tool configurations — so that jl10 can provide a personalised experience on subsequent visits.

10.3 Analytics Cookies

With your consent, jl10 uses analytics cookies to understand how Players interact with the platform in aggregate — which features are most used, how navigation flows, and where performance improvements are needed. Analytics data is processed in aggregate form and is not linked to individual Player identity for reporting purposes.

10.4 Managing Cookies

You can manage or delete cookies through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use the jl10 platform. Your cookie preferences can also be updated through the jl10 cookie consent settings displayed on first visit to the platform.

11. Your Data Rights

Under the Philippine Data Privacy Act of 2012 and its IRR, you have the following rights in relation to the personal data jl10 holds about you:

• Right to be informed (Section 16(a) DPA): The right to be informed of how your personal data is being or will be processed — which this Policy fulfils.
• Right to access (Section 16(b) DPA): The right to request a copy of the personal data jl10 holds about you, along with information about how it is being processed.
• Right to rectification (Section 16(c) DPA): The right to request correction of inaccurate or incomplete personal data. Basic account data (name, email, mobile) can be updated through your jl10 account settings; KYC corrections require a support request.
• Right to erasure (Section 16(d) DPA): The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to jl10's legal retention obligations under PAGCOR and AML regulations.
• Right to object (Section 16(f) DPA): The right to object to processing of your personal data on grounds of legitimate interests or for direct marketing purposes. Objection to marketing is processed immediately through your account notification settings.
• Right to data portability (Section 18 DPA): The right to receive a copy of personal data you have provided to jl10 in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe jl10 has processed your personal data in breach of the DPA.

To exercise any of the above rights, please submit a written request to jl10 via live chat or email (see Section 15). jl10 will respond within fifteen (15) business days of receiving a verified request, consistent with NPC guidelines.

12. Children's Privacy

jl10 is strictly an adult platform available only to individuals who are 21 years of age or older, in compliance with PAGCOR's minimum age requirements for online gaming in the Philippines.

jl10 does not knowingly collect or process personal data from individuals under 21 years of age. Age verification is conducted as part of the KYC process for all accounts. If jl10 becomes aware that personal data of an individual under 21 has been collected, such data will be deleted immediately and the account will be closed.

If you believe that a minor has registered on jl10, please contact jl10 support immediately so that appropriate action can be taken.

13. International Data Transfers

jl10 primarily processes your personal data within the Philippines. However, certain technology infrastructure partners and game content providers may store or process data on servers located outside the Philippines.

Where personal data is transferred outside the Philippines, jl10 ensures that appropriate safeguards are in place in accordance with Section 21 of the DPA, including contractual clauses requiring overseas recipients to maintain data protection standards equivalent to those required under Philippine law.

jl10 does not transfer personal data to jurisdictions that do not offer an adequate level of data protection without implementing appropriate contractual and technical safeguards as prescribed by the National Privacy Commission.

14. Updates to This Privacy Policy

jl10 may update this Privacy Policy from time to time to reflect changes in our data processing practices, changes in Philippine law, or updates to jl10's Services. Material changes to this Policy will be notified to registered Players by posting a notice within the jl10 platform and, where practicable, by sending a notification to your registered email address or mobile number.

The effective date of the current version of this Policy is displayed at the top of this document. We encourage you to review this Policy periodically. Your continued use of the jl10 Services following the effective date of a revised Policy constitutes acceptance of the updated terms.

Historical versions of this Policy are available on request from jl10's Data Protection Officer.

15. Contact & Complaints

For any queries, concerns, or requests relating to this Privacy Policy or jl10's handling of your personal data, please contact jl10's Data Protection Officer through the following channels:

• Live Chat: 24/7 support available inside your jl10 account dashboard — the fastest channel for most data requests
• Email: [email protected] (plain text — displayed for informational purposes; not a clickable link)

jl10 will acknowledge data subject requests within five (5) business days and respond substantively within fifteen (15) business days, or such shorter period as may be required by NPC guidelines for particular request types.

If you are not satisfied with jl10's response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory body responsible for the enforcement of the Data Privacy Act of 2012 in the Philippines.