Privacy Policy – jl163 Philippines Gaming Platform

Introduction

This Privacy Policy ("Policy") describes how jl163 ("jl163," "we," "us," or "our") collects, uses, processes, stores, shares, and protects the personal data of users ("you," "User," or "Account Holder") who access the jl163 online gaming platform at jl163.vip and all associated services (the "Platform").

jl163 operates in the Philippines and processes personal data in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines ("NPC"). By registering an account or using the Platform, you acknowledge that you have read this Policy and consent to the processing of your personal data as described herein.

This Policy should be read alongside the jl163 Terms and Conditions, which are incorporated by reference. In cases of conflict between this Policy and the Terms and Conditions on privacy matters, this Policy shall prevail.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, jl163 is the personal information controller ("PIC") responsible for the personal data collected through the Platform. As PIC, jl163 determines the purposes and means of processing your personal data.

Where jl163 engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and cloud hosting services — those parties act as personal information processors ("PIP") under written data processing agreements that bind them to confidentiality and security obligations consistent with this Policy and the DPA.

Questions, requests, or complaints relating to your personal data should be directed to jl163 via the contact details provided in Section 16 of this Policy.

Personal Data We Collect

jl163 collects personal data across three broad categories, each linked to specific operational or legal purposes:

3.1 Registration and Identity Data

• Full legal name
• Date of birth (used to verify the 21+ age requirement)
• Registered Philippine mobile number
• Residential address
• Username and encrypted password credentials
• Government-issued ID details submitted during KYC (ID type, ID number, expiry date)
• Selfie or facial image submitted for biometric identity verification (where required)

3.2 Financial and Transaction Data

• Deposit and withdrawal transaction records (amount, date, time, payment method reference)
• Payment method identifiers (GCash mobile number, bank account last digits, PayMaya account reference)
• Account balance history
• Bonus and promotional credit records

3.3 Platform Usage and Technical Data

• Betting and gaming activity history (game type, stake, outcome, timestamp)
• Login and session logs (IP address, device type, operating system, browser type, login timestamps)
• Customer support interaction records (chat transcripts, issue category, resolution outcome)
• Responsible gaming activity (limit settings, self-exclusion activations, cooling-off periods)
• Cookie and session data as further described in Section 11

How We Collect Personal Data

jl163 collects personal data through the following channels:

• Directly from you: When you complete the Account registration form, submit KYC documents, initiate deposits or withdrawals, contact customer support, or update your Account settings;
• Automatically through Platform use: When you log in to jl163, browse the lobby, place wagers, or otherwise interact with the Platform, technical and usage data is automatically captured by Platform systems;
• From payment service providers: Transaction confirmation data and payment reference numbers are received from GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners in connection with deposit and withdrawal processing;
• From identity verification providers: Where third-party identity verification services are used to validate KYC documents, those providers may share verification outcome data and identity confirmation signals with jl163;
• Through cookies and similar technologies: As described in Section 11, session cookies and functional cookies capture technical data during your Platform sessions.

Purposes of Processing

jl163 processes personal data for the following purposes:

1. Account creation and management: Registering your account, maintaining your profile, and providing access to jl163 services;
2. Identity and age verification: Confirming that you are the person you claim to be and that you meet the 21+ age requirement under Philippine gaming regulations;
3. Payment processing: Facilitating deposits to and withdrawals from your jl163 Account via your chosen payment method;
4. Anti-money laundering (AML) and fraud prevention: Monitoring transaction patterns and account activity to detect and prevent money laundering, fraud, and other financial crime, as required by applicable Philippine law;
5. Customer support: Responding to enquiries, resolving disputes, and providing account assistance;
6. Regulatory compliance: Meeting obligations imposed by applicable Philippine gaming, financial, and data protection regulations;
7. Platform security: Detecting and preventing unauthorised access, account takeovers, and other security incidents;
8. Responsible gaming monitoring: Identifying behavioural patterns that may indicate problem gambling and providing appropriate safeguards;
9. Service improvement: Analysing aggregated, anonymised usage data to improve Platform features and user experience;
10. Communications: Sending you transactional notifications related to your Account (deposit confirmations, withdrawal updates, security alerts) via your registered Philippine mobile number.

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, jl163 processes personal data on the following legal bases:

• Contractual necessity: Processing your registration data, identity information, and transaction data is necessary to perform the contract between you and jl163 as set out in the Terms and Conditions. Without this processing, jl163 cannot provide its services to you;
• Legal obligation: Certain processing activities — including KYC verification, AML transaction monitoring, and data retention for regulatory reporting — are required by applicable Philippine law, including Republic Act No. 9160 (Anti-Money Laundering Act) and PAGCOR-related requirements;
• Legitimate interests: jl163 processes technical and usage data on the basis of its legitimate interest in operating a secure, reliable gaming platform, preventing fraud, protecting the rights of other Account Holders, and improving Platform functionality. These interests have been assessed as not overriding your privacy rights;
• Consent: Where processing is not required by contract or law, and where jl163 seeks to process your data for purposes such as promotional communications or certain non-essential analytics, we will seek your separate, freely given, specific, and informed consent.

Data Sharing and Disclosure

jl163 does not sell, rent, or share your personal data with third parties for their own commercial or marketing purposes. Personal data is disclosed to third parties only in the circumstances described below:

7.1 Service Providers and Processors

jl163 engages third-party service providers who process personal data on our behalf under written data processing agreements. These include:

• Payment processors (GCash / GXI, PayMaya / Voyager Innovations, BPI, BDO, Metrobank) for deposit and withdrawal processing;
• Identity and KYC verification providers for document authentication and age verification;
• Cloud infrastructure and hosting providers for data storage and Platform operation;
• Customer support platform providers for live chat and ticketing systems;
• Fraud detection and security monitoring services.

All service providers are bound by contractual obligations requiring them to process your personal data only for the specific purpose for which it was shared, and to implement appropriate technical and organisational security measures.

7.2 Regulatory and Law Enforcement Disclosure

jl163 may disclose personal data to regulators, law enforcement agencies, courts, or other government authorities in the Philippines where required by applicable law, court order, or regulatory direction. This includes disclosures required under the Anti-Money Laundering Act and related reporting obligations.

7.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of jl163's business or assets, personal data held by jl163 may be transferred to the acquiring entity, subject to that entity maintaining privacy protections no less stringent than those in this Policy. You will be notified of any material change to data controllership.

7.4 With Your Consent

jl163 may share your personal data with third parties in any other circumstances where you have provided your prior, explicit, and informed consent to such sharing.

International Data Transfers

jl163's primary operations are based in and focused on the Philippines. In certain operational circumstances — including the use of cloud infrastructure or technology providers with data centres located outside the Philippines — your personal data may be transferred to, stored in, or processed in a jurisdiction other than the Philippines.

Where such international transfers occur, jl163 takes the following steps to ensure adequate protection of your data:

• Transfers are made only to countries or organisations that provide adequate data protection standards, or pursuant to data transfer agreements incorporating standard contractual clauses;
• Recipient processors are bound by contractual obligations consistent with the Philippine DPA;
• jl163 monitors the data protection practices of its international service providers and may terminate arrangements that fail to meet required standards.

By using the jl163 Platform, you acknowledge and consent to international transfers of your personal data where necessary for the operation of the Platform, subject to the safeguards described above.

Data Security

jl163 implements a range of technical, organisational, and procedural security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption in transit: All data transmitted between your device and jl163 servers is encrypted using 256-bit Transport Layer Security (TLS/SSL);
• Encryption at rest: Sensitive personal data stored in jl163 databases — including identity information and payment references — is encrypted using industry-standard algorithms;
• Access controls: Access to systems containing personal data is restricted to authorised personnel on a need-to-know basis, enforced through role-based access control and multi-factor authentication;
• Password security: Account passwords are stored as irreversible cryptographic hashes. jl163 staff cannot view your password in plain text;
• Security monitoring: Platform systems are monitored for unusual activity, intrusion attempts, and security incidents;
• Regular security assessments: jl163 conducts periodic security reviews and vulnerability assessments of Platform infrastructure.

While jl163 applies all reasonable security measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. You are responsible for maintaining the security of your own Account credentials and for notifying jl163 promptly if you suspect any unauthorised use of your Account.

Data Retention

jl163 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law and regulatory obligations. The following general retention principles apply:

• Active Accounts: Personal data is retained for the full duration of your Account's active status plus a minimum post-closure retention period;
• Closed Accounts: Following Account closure, jl163 retains transaction records, identity verification data, and gaming history for a minimum period of five (5) years to comply with Anti-Money Laundering Act requirements and potential dispute resolution needs;
• KYC Documents: Copies of government-issued ID documents submitted for KYC are retained for a minimum of five (5) years post-Account closure;
• Support Records: Customer support interaction records are retained for a minimum of three (3) years following the interaction;
• Technical Logs: Server and access logs are typically retained for 12 months for security and fraud investigation purposes.

Where retention beyond these minimum periods is required by a specific legal obligation, court order, or ongoing investigation, data will be retained for the duration of that requirement.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents recovery.

Cookies and Similar Technologies

The jl163 Platform uses cookies and similar browser storage technologies to operate certain Platform functions. Cookies are small text files placed on your device by the jl163 website during your visit.

11.1 Types of Cookies Used by jl163

• Strictly necessary cookies: These cookies are essential for the Platform to function. They enable core features such as maintaining your login session, remembering your language preferences, and processing your bets. The Platform cannot function properly without these cookies and they cannot be disabled;
• Functional cookies: These cookies remember your preferences — such as game lobby display settings — to provide a more personalised experience. They do not track your activity across other websites;
• Security cookies: Used to detect fraudulent login attempts, identify unusual session behaviour, and support the Platform's anti-fraud systems.

11.2 Managing Cookies

You can control cookies through your browser settings — most browsers allow you to view, delete, and block cookies. Note that disabling strictly necessary cookies will impair your ability to use the Platform, including the ability to log in to your jl163 Account. jl163 is not responsible for any reduction in Platform functionality resulting from cookie restrictions you apply through your browser.

Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl163:

• Right to be informed: You have the right to be notified about how your personal data is being processed, as set out in this Policy;
• Right of access: You may request a copy of the personal data held about you by jl163, including the categories of data, the purposes of processing, and any third parties with whom it has been shared;
• Right to rectification: If your personal data held by jl163 is inaccurate or incomplete, you have the right to request correction. You may update certain details directly through your Account settings;
• Right to erasure: In certain circumstances, you may request that jl163 delete your personal data. This right is subject to limitations where retention is required by law, regulatory obligation, or for the establishment, exercise, or defence of legal claims;
• Right to object: You may object to the processing of your personal data for purposes based on jl163's legitimate interests, or for direct marketing where you have previously consented;
• Right to data portability: Where technically feasible and legally applicable, you may request that jl163 provide your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: If you believe jl163 has processed your personal data in violation of the DPA, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact jl163 via the live chat support on the Platform or by email at the address provided in Section 16. jl163 will respond to valid data subject requests within thirty (30) days of receipt, or within such shorter period as may be required by applicable law. Identity verification may be required before jl163 processes a data access or erasure request.

Children's Privacy and the 21+ Age Requirement

jl163 enforces the 21+ age requirement at registration through date-of-birth collection and during KYC through government-issued ID verification. If jl163 becomes aware that personal data has been collected from a person under the age of twenty-one, the following actions will be taken immediately:

• The Account will be suspended and no further Platform access will be permitted;
• All personal data collected from the underage individual will be securely deleted to the extent permitted by applicable regulatory requirements;
• Any real-money Account Balance will be returned to the depositing payment method, net of any amounts already withdrawn;
• The incident will be documented in jl163's compliance records.

If you are a parent or guardian and have reason to believe that a person under the age of twenty-one has registered an Account on jl163 using false information, please contact jl163 support immediately via live chat.

Data Processing for Responsible Gaming

jl163 uses gaming activity data and account usage patterns to fulfil its responsible gaming obligations to players. Specifically, jl163 may:

• Monitor account activity for indicators associated with problem gambling behaviour, including but not limited to rapid escalation of bet sizes, extended unbroken play sessions, and patterns consistent with chasing losses;
• Apply responsible gaming interventions — such as mandatory cooling-off prompts or support resource notifications — based on activity data, without requiring individual player reports;
• Maintain records of self-exclusion elections and deposit limit settings to enforce those settings across all Platform touchpoints;
• Share anonymised, aggregated responsible gaming data with regulators as required by applicable regulations.

This processing of gaming activity data for responsible gaming purposes is conducted on the basis of jl163's legal obligations and legitimate interest in player protection. You may not opt out of this processing while holding an active jl163 Account, as it forms part of jl163's duty of care to its players.

For more information on available responsible gaming tools, visit the jl163 Responsible Gaming page.

Updates to This Privacy Policy

jl163 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements, or Platform features. The effective date at the top of this Policy indicates when it was last updated.

In the case of material changes to this Policy — particularly those that affect how your personal data is used or shared — jl163 will provide advance notice to active Account Holders via their registered Philippine mobile number or through a Platform notification prior to the changes taking effect.

Your continued use of the jl163 Platform following notification of Policy updates constitutes your acceptance of the revised Policy. If you do not agree with a material change, you may request Account closure and the return of your available Account Balance.

Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy or jl163's data processing practices, please contact us through the following channels:

• Live Chat Support: Available 24/7 on the jl163 Platform — click the chat icon on any page
• Email: [email protected] (plain text — not a clickable link)
• Response Target: jl163 aims to acknowledge written data privacy enquiries within 72 hours and provide a substantive response within 30 days

Filing a Complaint with the NPC

If you are not satisfied with jl163's response to a privacy concern or data subject request, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines ("NPC"). The NPC is the independent regulatory authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines. Details on how to file a complaint with the NPC are available on the NPC's official website.

jl163 cooperates fully with NPC investigations and will respond to any formal NPC enquiries or directives within the required timeframes.