jli18 Privacy Policy —
Your Data, Your Rights

jli18 is committed to protecting the personal data of all individuals who interact with our platform. This Privacy Policy has been prepared in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines (the "DPA"), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). It describes how jli18 collects, stores, uses, discloses, and protects the personal data of Philippine-based players and platform visitors.

This policy covers all personal data processing activities carried out by jli18 in connection with the jli18.app platform, including but not limited to: account registration and management, identity verification (KYC), financial transaction processing, customer support interactions, promotional communications, and platform analytics. It applies regardless of the device or method used to access jli18 — mobile browser, desktop browser, or any other access point.

jli18 processes personal data only for the purposes described in this policy and only to the extent necessary for those purposes. If you have questions about how we handle your personal data that are not answered in this policy, please contact our Data Protection Officer (DPO) using the contact information in Section 15 below.

For purposes of the Philippine Data Privacy Act of 2012 and this Privacy Policy, jli18 acts as the Personal Information Controller (PIC) with respect to the personal data of Players and platform visitors. As PIC, jli18 determines the purposes and means by which personal data is processed in connection with the operation of the jli18 platform.

jli18 has appointed a Data Protection Officer responsible for overseeing compliance with the DPA and this Privacy Policy, handling data subject rights requests, and serving as the point of contact for the National Privacy Commission on matters related to personal data processing. Contact details for the DPO are provided in Section 15 of this policy.

jli18 collects and processes the following categories of personal data in connection with platform operations. The specific data collected in any individual case depends on the nature of the interaction and the services used:

jli18 does not collect sensitive personal information as defined under the Philippine DPA — such as racial or ethnic origin, religious beliefs, health data, or sexual orientation — except where such information is incidentally provided by a Player (for example, in the context of a responsible gaming assessment) and only where its processing is strictly necessary for a legitimate, disclosed purpose.

jli18 collects personal data through the following channels and mechanisms:

• Direct Registration: When you create a jli18 account, you provide your mobile number or email address and other registration details directly to us.
• KYC Verification Process: When you submit government-issued identification documents for identity and age verification, jli18 receives and processes the personal data contained in those documents.
• Financial Transactions: When you make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, or Metrobank, jli18 receives transaction reference data from the payment processor necessary to reconcile your account.
• Platform Usage: jli18 automatically collects technical data and gaming activity data as you use the platform — this includes game plays, bets, session information, and device and browser data.
• Customer Support: When you contact jli18 support via live chat or email, the content of those communications is collected and stored for quality assurance and dispute resolution purposes.
• Cookies and Tracking Technologies: jli18 uses cookies and similar technologies as described in Section 10 of this policy to collect technical and preference data automatically during platform use.

Under the Philippine Data Privacy Act of 2012, jli18 must have a lawful basis for processing your personal data. The following lawful bases apply to jli18's data processing activities:

• Contractual Necessity: Processing your registration data, financial transaction data, gaming activity data, and identity verification data is necessary for jli18 to perform its obligations under the account agreement with you. Without this processing, jli18 cannot provide you with access to the platform or process your deposits and withdrawals.
• Legal Compliance: jli18 processes identity data, financial data, and gaming activity data to comply with applicable laws including anti-money laundering requirements, responsible gaming obligations, and PAGCOR-aligned regulatory requirements.
• Legitimate Interests: jli18 processes technical data and platform usage data on the basis of legitimate interests — specifically, to maintain platform security, prevent fraud, detect prohibited conduct, and improve platform performance and user experience.
• Consent: Where jli18 sends you marketing communications or places non-essential cookies on your device, this processing is based on your explicit consent, which you may withdraw at any time.

jli18 uses the personal data we collect for the following specific purposes. We will not use your data for any purpose not listed here without first notifying you and, where required, obtaining your consent:

• To create and manage your jli18 account, authenticate your identity at login, and maintain the security of your account session.
• To process your deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to reconcile your account balance accordingly.
• To conduct identity verification (KYC) as required before processing withdrawal requests and as required for regulatory compliance.
• To record your gaming activity for the purposes of account integrity, dispute resolution, regulatory reporting, and responsible gaming monitoring.
• To administer bonuses, promotions, and loyalty program benefits to which your account is eligible.
• To provide customer support, respond to account inquiries, and resolve disputes arising from your use of the jli18 platform.
• To detect and prevent fraud, money laundering, prohibited conduct, multi-accounting, and other activities that breach the jli18 Terms & Conditions.
• To monitor your gambling patterns for responsible gaming purposes — including detecting signs of potential gambling disorder and triggering account safeguards where appropriate.
• To send you service-related communications, including security alerts, account notifications, and updates to our Terms or Privacy Policy.
• To send you marketing communications about jli18 promotions and new features, where you have given your consent to receive such communications.
• To analyze aggregate platform usage data to improve the jli18 user experience, platform performance, and game offering.

jli18 does not sell, rent, or otherwise transfer your personal data to unaffiliated third parties for their own marketing or commercial purposes. Personal data is shared only in the following limited and necessary circumstances:

• Payment Processors: Your financial data is shared with Philippine payment processors (GCash/Maya, BPI, BDO, Metrobank) solely for the purpose of executing your requested deposits and withdrawals. These processors operate under their own privacy policies and are bound by applicable Philippine financial regulations.
• KYC Verification Providers: Identity documents submitted for KYC verification may be processed by third-party identity verification services engaged by jli18. These service providers are bound by data processing agreements that restrict their use of your data to KYC verification purposes only.
• Game Software Providers: Aggregated or session-level gaming activity data may be shared with certified game software providers for technical support, RTP verification, and game performance analysis purposes. Identifiable personal data is not shared with game providers beyond what is technically necessary to operate live dealer tables and multiplayer game environments.
• Regulatory and Law Enforcement Authorities: jli18 will disclose personal data to the National Privacy Commission, PAGCOR, the Anti-Money Laundering Council (AMLC), law enforcement agencies, or other competent authorities when required to do so by applicable Philippine law or in response to a valid legal order.
• Professional Advisors: jli18 may share limited personal data with legal advisors, auditors, or compliance consultants on a strictly need-to-know basis and subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or asset sale involving the jli18 platform, Player personal data may be transferred to the successor entity as part of that transaction, subject to the protections of this Privacy Policy.

jli18 retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any applicable legal obligations that may require retention for a specified minimum period. The following general retention periods apply:

• Account Registration Data: Retained for the duration of the account and for a period of five (5) years following account closure, in compliance with Philippine anti-money laundering retention requirements.
• KYC Identity Documents: Retained for five (5) years following the last transaction on the account, or longer if required by applicable regulatory authority.
• Financial Transaction Records: Retained for a minimum of five (5) years in accordance with the AMLA and applicable financial record-keeping regulations.
• Gaming Activity Records: Retained for a minimum of three (3) years for dispute resolution and regulatory compliance purposes.
• Customer Support Communications: Retained for two (2) years from the date of the final communication in a support thread.
• Marketing Consent Records: Retained for the duration of the consent and for two (2) years following its withdrawal, to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification. Anonymized aggregated data may be retained indefinitely for statistical and analytical purposes.

jli18 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Transport Encryption: All data transmitted between your device and the jli18 platform is protected by 256-bit SSL/TLS encryption — the same standard used by Philippine banks and major financial institutions.
• Password Security: Account passwords are stored exclusively as salted cryptographic hashes. jli18 never stores plain-text passwords and cannot recover them. This is why password reset functions generate a new password rather than retrieving the existing one.
• Two-Factor Authentication: jli18 offers SMS-based two-factor authentication for account login. We strongly recommend all Players enable this feature to protect against unauthorized account access.
• Access Controls: Access to Player personal data within jli18's internal systems is restricted to personnel with a legitimate operational need. Role-based access controls and audit logging are in place for all systems containing personal data.
• Data Storage: Sensitive Player data, including KYC documents and financial records, is stored in encrypted form on secure servers with appropriate physical and logical access controls.
• Security Monitoring: jli18 operates continuous monitoring of platform systems for unauthorized access attempts, anomalous account behavior, and potential data security incidents.

jli18 uses cookies and similar browser-based technologies to maintain session continuity, remember your preferences, measure platform performance, and — with your consent — deliver relevant promotional content. The following categories of cookies are used on the jli18 platform:

• Strictly Necessary Cookies: These cookies are essential for the jli18 platform to function. They include session authentication tokens, security cookies, and cookies that remember your language and display preferences. These cookies are placed automatically and cannot be disabled without impairing the platform's basic functionality.
• Functional Cookies: These cookies allow jli18 to remember your settings and preferences between sessions — such as your preferred interface theme and responsible gaming reminder settings. They do not track your behavior across other websites.
• Analytics Cookies: With your consent, jli18 places analytics cookies to understand how Players interact with the platform — which games are most popular, where navigation issues occur, and how performance can be improved. Analytics data is aggregated and does not identify individual Players.
• Marketing Cookies: With your consent, jli18 may place cookies to personalize promotional content displayed to you on the jli18 platform based on your gaming preferences. These cookies are only placed where you have opted in to receive personalized promotions.

You may manage your cookie preferences through your browser settings, which allow you to block or delete cookies from specific websites. Note that blocking strictly necessary cookies will impair your ability to use the jli18 platform, including remaining logged in to your account between page loads.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jli18. These rights are exercisable by contacting jli18's Data Protection Officer using the contact details in Section 15. jli18 will respond to all valid rights requests within fifteen (15) business days:

The jli18 platform is strictly for individuals who are twenty-one (21) years of age or older. jli18 does not knowingly collect or process the personal data of individuals under the age of 21. If jli18 becomes aware that personal data of an individual under 21 has been collected — whether through a fraudulent registration or any other means — jli18 will immediately delete that data, close the associated account, and return any deposited funds to the source payment method in accordance with jli18's underage gaming procedures.

jli18 requires all Players to confirm their age at registration and to complete KYC identity verification before processing any withdrawal. Age verification documents submitted through the KYC process are reviewed to confirm compliance with the 21+ age requirement. jli18 also monitors account activity for behavioral patterns that may indicate underage gambling and will trigger additional verification checks where appropriate.

jli18 primarily processes the personal data of Filipino Players within the Philippines. In certain circumstances, however, your data may be transferred to or processed by service providers or systems located outside the Philippines — for example, where jli18 uses internationally hosted cloud infrastructure or where game software providers operate servers outside Philippine territory.

Where personal data is transferred outside the Philippines, jli18 ensures that appropriate safeguards are in place in accordance with the requirements of the Philippine Data Privacy Act, including the use of data processing agreements that impose data protection obligations on the recipient party equivalent to those applicable under Philippine law. If you have questions about the specific international transfer safeguards applicable to your data, please contact our DPO.

jli18 reviews this Privacy Policy periodically and may update it to reflect changes in our data processing practices, legal or regulatory requirements, or the features of the jli18 platform. Material changes — meaning changes that affect your rights, the types of data we collect, or the purposes for which we use it — will be communicated to active Players via their registered email address or mobile number at least seven (7) days before the change takes effect, where practicable.

The "Last Updated" date at the top of this page always reflects the most recent revision. We encourage you to review this Privacy Policy periodically. Your continued use of the jli18 platform after the effective date of any revised policy constitutes your acknowledgment of the updated terms.

If you have any questions, concerns, or requests regarding this Privacy Policy or jli18's handling of your personal data, please contact the jli18 Data Protection Officer directly:

If you are not satisfied with jli18's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012 and is the appropriate body to contact if you believe your data privacy rights have been violated by jli18 or any other Philippine-based organization.