jl697 Privacy Policy — How We Collect, Use & Protect Your Data

1. Data Controller Identity

This Privacy Policy applies to personal data processed by jl697.club ("jl697", "we", "us", "our"), a PAGCOR-licensed online gaming platform operating in the Republic of the Philippines. jl697 acts as the data controller in respect of all personal information collected through jl697.club and related services.

For the purposes of this Policy, "personal data" has the meaning given under Republic Act No. 10173 (Data Privacy Act of 2012) and includes any information that identifies, or could reasonably identify, a natural person.

2. Personal Data We Collect

jl697 collects personal data through your use of the Platform. The categories of data collected, and the context in which they are collected, are described in the table below:

jl697 does not collect sensitive personal information (as defined under RA 10173, Section 3[l]) unless strictly required for regulatory compliance, in which case such collection is conducted under applicable lawful criteria and with appropriate safeguards.

3. Legal Basis for Processing

jl697 processes personal data on the following legal bases, as applicable to each processing activity:

• Contractual necessity: Processing required to fulfil our obligations to you under the jl697 Terms & Conditions, including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including RA 10173, the Anti-Money Laundering Act (RA 9160, as amended), PAGCOR regulations, and NPC directives.
• Legitimate interests: Processing necessary for jl697's legitimate interests in operating a safe, fair, and secure gaming platform — including fraud detection, security monitoring, responsible gaming compliance, and Platform improvement — where such interests are not overridden by your fundamental rights.
• Consent: Where jl697 relies on consent as the lawful basis for processing (for example, for optional marketing communications), such consent is obtained separately, is freely given, and may be withdrawn at any time without detriment.

4. How We Use Your Personal Data

jl697 uses your personal data for the following purposes:

• Creating and managing your jl697 Account, including identity and age verification under PAGCOR's KYC requirements.
• Processing deposits and withdrawals through GCash, Maya, BPI, BDO, Metrobank, and other accepted payment methods.
• Delivering and improving the games, features, and services available on jl697.club.
• Fulfilling anti-money laundering (AML) and counter-terrorism financing (CTF) obligations under Philippine law, including reporting obligations to the Anti-Money Laundering Council (AMLC).
• Monitoring for problem gambling indicators and administering jl697's responsible gaming tools, including deposit limits, cooling-off periods, and self-exclusion, in accordance with PAGCOR's responsible gaming framework.
• Detecting, preventing, and investigating fraud, cheating, money laundering, and other prohibited conduct on the Platform.
• Providing customer support and resolving account queries.
• Sending transactional communications related to your Account (e.g., deposit confirmations, security alerts, withdrawal status notifications).
• Sending promotional communications about jl697 offers, bonuses, and new games — where you have consented or where such communications are permitted under applicable law. You may opt out of promotional communications at any time.
• Conducting internal analytics to understand how Filipino players use jl697 and to improve the Platform experience.
• Complying with reporting obligations to PAGCOR and other Philippine regulatory authorities.

5. Data Sharing & Disclosure

jl697 does not sell, rent, or trade your personal data. We share your data only in the following circumstances:

• Service Providers: Third-party vendors engaged by jl697 to provide essential services — including payment processors (GCash, Maya), game software providers, KYC/identity verification providers, customer support platforms, and cloud infrastructure providers — receive personal data strictly as necessary for their contracted service. All such providers are bound by data processing agreements and are prohibited from using your data for their own purposes.
• Regulatory Authorities: jl697 is obligated to disclose player data to PAGCOR, the AMLC, the National Privacy Commission, and other Philippine government bodies where required by law or where jl697 reasonably determines such disclosure is necessary to comply with a legal obligation.
• Law Enforcement: jl697 may disclose personal data to Philippine law enforcement authorities where required by court order, subpoena, or where jl697 reasonably believes disclosure is necessary to protect the safety of any person or to prevent crime.
• Business Transfers: In the event of a merger, acquisition, or sale of assets involving jl697, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and your rights under RA 10173 will be respected.

jl697 does not share personal data with advertising networks, data brokers, or any third party for the purpose of commercial profiling or targeted advertising without your explicit prior consent.

6. Cookies & Tracking Technologies

jl697.club uses cookies and similar tracking technologies to enable core platform functionality, improve user experience, and gather analytics data. The following categories of cookies are used:

• Essential Cookies: Required for the Platform to function. These include session authentication cookies, load balancing tokens, and security tokens. These cannot be disabled without disrupting your use of jl697.
• Functional Cookies: Remember your preferences, such as language settings and last-visited game categories, to personalise your experience on subsequent jl697 sessions.
• Analytics Cookies: Collect aggregated, anonymised usage data to help jl697 understand how Filipino players navigate the Platform. This data is used solely for internal Platform improvement.

You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the performance of jl697.club on your device.

7. Data Security

jl697 implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jl697 servers.
• Encryption of sensitive data at rest, including government ID details and financial transaction records.
• Role-based access controls restricting internal access to personal data on a need-to-know basis.
• Regular penetration testing and vulnerability assessments of jl697 systems.
• Multi-factor authentication requirements for all jl697 staff accessing production systems.
• Incident response procedures aligned with NPC Circular No. 16-03 requirements.

While jl697 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own jl697 Account credentials. Never share your password with anyone — jl697 staff will never ask for your password.

8. Data Retention

jl697 retains personal data for as long as is necessary for the purpose for which it was collected, or as required by applicable Philippine law:

• Account data and KYC records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, pursuant to AML obligations.
• Gaming history: Retained for a minimum of three (3) years for responsible gaming monitoring and PAGCOR compliance purposes.
• Support communications: Retained for two (2) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

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

9. Your Data Rights Under RA 10173

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jl697:

• Right to be Informed: You have the right to know how jl697 collects and uses your personal data — which this Privacy Policy provides.
• Right of Access: You may request a copy of the personal data jl697 holds about you, including information on how it has been used.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held by jl697.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to jl697's legal retention obligations under PAGCOR and AML regulations.
• Right to Object: You may object to processing of your personal data based on legitimate interests, including direct marketing. Objections to marketing communications will be honoured immediately.
• Right to Data Portability: You may request that jl697 provide your personal data in a structured, machine-readable format for transfer to another controller, where technically feasible.
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe jl697 has violated your rights under RA 10173.

To exercise any of these rights, please contact jl697's Data Protection Officer at [email protected]. jl697 will respond to all data rights requests within fifteen (15) business days of receipt. We may request proof of identity before processing a request.

10. Children, Minors & Age Restriction

jl697 is strictly an adult gaming platform. We do not knowingly collect personal data from any individual under the age of 21. Use of jl697 by persons under 21 is prohibited under PAGCOR regulations and Philippine law.

If jl697 discovers or has reason to believe that a registered user is under 21 years of age, we will immediately suspend the Account, conduct an investigation, and report the matter to PAGCOR as required. All deposits made by an underage user will be returned to the funding source, and no winnings will be paid out.

Parents and guardians who believe a minor may have accessed jl697 should contact our support team at [email protected] immediately.

11. International Data Transfers

jl697 primarily processes and stores personal data within secure data centre facilities. Where it is necessary to transfer personal data to service providers operating outside the Philippines — for example, global cloud infrastructure or software providers — jl697 ensures that such transfers are subject to appropriate safeguards consistent with RA 10173 and NPC guidelines, including contractual data processing agreements that require the recipient to maintain standards equivalent to Philippine data protection law.

jl697 will not transfer your personal data to any jurisdiction that does not provide adequate protection for personal data without first implementing appropriate contractual or technical safeguards.

12. Changes to This Privacy Policy

jl697 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. The "Last updated" date at the top of this page will reflect the most recent revision.

Where changes are material — i.e., where they significantly affect your rights or our data processing activities — jl697 will notify registered players by email or through a prominent notice on the Platform at least 14 days before the changes take effect. Your continued use of jl697 following the effective date of any amendment constitutes acceptance of the revised Policy.

13. Contact & Data Protection Officer

jl697 has appointed a Data Protection Officer (DPO) in accordance with the requirements of RA 10173 and NPC Circular No. 17-01. For all privacy-related inquiries, data rights requests, or complaints, please contact:

jl697 is committed to resolving all privacy concerns promptly and in accordance with RA 10173. If you are not satisfied with our response, you have the right to escalate your complaint directly to the NPC.