Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how jlss ("jlss", "we", "us", "our") collects, uses, stores, and protects the personal information of users ("you", "Player") who access or use the jlss website, mobile platform, and related services (collectively, the "Platform").

jlss is committed to protecting the privacy and personal data of all players on the Platform. This Policy is intended to be transparent and easy to understand. We encourage you to read it carefully so you know exactly how your information is handled when you use jlss.

This Policy forms part of the Terms & Conditions of the jlss Platform. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

This Policy applies to all personal data collected through the jlss Platform, including data collected via the website, live chat, email correspondence, and any other channel through which you interact with us.

02 Personal Data We Collect

jlss collects personal data that is necessary to provide our services, comply with legal obligations, and maintain the security and integrity of the Platform. The categories of personal data we collect include:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or biometric data unless specifically required by law or regulation and with your explicit consent.

03 How We Collect Your Data

jlss collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from GCash, PayMaya, BPI, BDO, and Metrobank in connection with transaction processing.
• Publicly available sources: Information from public databases used for identity verification or fraud prevention purposes.

04 How We Use Your Personal Data

jlss uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and administer your jlss player account, including processing your registration and verifying your identity.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the core features of the jlss Platform.
• Legal and regulatory compliance: To fulfil our obligations under applicable Philippine law, including KYC, AML, and responsible gaming requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: To monitor gaming patterns, identify potentially problematic behavior, and administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the jlss Platform.
• Personalisation: To tailor game recommendations, promotional offers, and platform content to your preferences and gaming history.

jlss will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

05 Legal Basis for Processing

jlss processes your personal data on one or more of the following legal bases, in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines:

• Contractual necessity: Processing is necessary to perform our contract with you — i.e., to operate your jlss account and deliver the services you have requested.
• Legal obligation: Processing is required to comply with applicable laws and regulations, including KYC, AML, and responsible gaming obligations.
• Legitimate interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent as the legal basis for processing — for example, for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

06 Data Sharing & Disclosure

jlss does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only where necessary and in accordance with this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers who assist us in verifying your identity and screening for financial crime risks.
• Technology and infrastructure providers: Cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Game content providers: Game studios and software providers whose games are available on the jlss Platform, to the extent necessary for game delivery and technical support.
• Regulatory and law enforcement authorities: Where required by law, court order, or regulatory instruction, including disclosures to PAGCOR or other competent Philippine authorities.
• Fraud prevention agencies: Third-party fraud detection and prevention services used to protect the Platform and its players.

All third parties with whom jlss shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

07 Cookies & Tracking Technologies

The jlss Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and gather analytics data. A cookie is a small text file placed on your device when you visit a website.

We use the following types of cookies on the jlss Platform:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymised data about how players use the Platform, which pages are visited most frequently, and where errors occur. This data helps us improve the jlss experience.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jlss Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate securely.

08 Data Retention

jlss retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and regulatory record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the end of the business relationship.
• Customer support communications: Retained for up to three (3) years from the date of the interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Technical and usage data: Retained for up to two (2) years from the date of collection, after which it is anonymised or deleted.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

When personal data is no longer required, jlss will securely delete or anonymise it in accordance with our data disposal procedures. Anonymised data that can no longer be linked to an individual may be retained indefinitely for analytical purposes.

09 Data Security

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

• SSL/TLS encryption: All data transmitted between your device and the jlss Platform is encrypted using industry-standard SSL/TLS protocols.
• Encryption at rest: Sensitive personal and financial data stored on our servers is encrypted using AES-256 or equivalent encryption standards.
• Access controls: Access to personal data is restricted to authorised jlss personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-factor authentication: Available for all jlss player accounts to provide an additional layer of login security.
• Regular security audits: Our Platform and infrastructure undergo regular security assessments and penetration testing by qualified security professionals.
• Incident response: jlss maintains a data breach response procedure. In the event of a breach that poses a risk to your rights and freedoms, we will notify you and the relevant authorities in accordance with applicable law.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173) of the Philippines, you have the following rights with respect to your personal data held by jlss:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed. This Policy fulfils that obligation.
• Right of access: You have the right to request a copy of the personal data that jlss holds about you, along with information about how it is being used.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact the jlss support team. We will respond to all data subject requests within thirty (30) days of receipt. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

11 Children's Privacy

The jlss Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any winnings generated by an underage player will be forfeited.

If you are a parent or guardian and believe that your child has registered an account with jlss, please contact our support team immediately so that we can investigate and take appropriate action.

12 Changes to This Policy

jlss reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will notify registered players via email or a prominent notice on the Platform.

The date of the most recent revision is always displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how jlss protects your personal data. Your continued use of the Platform following the publication of any changes constitutes your acceptance of the revised Policy.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way jlss handles your personal data, please contact our Data Privacy team. We are committed to addressing all privacy-related enquiries promptly and transparently.

You can reach us via live chat on the Platform, available 24 hours a day, 7 days a week. For written enquiries, our email address is: [email protected]

Please include "Privacy Request" in the subject line of your email and provide your registered username along with a clear description of your query. We aim to respond to all privacy-related correspondence within 48 hours.