jll44 Privacy Policy

jll44 ("we," "us," or "our") is committed to safeguarding the privacy and personal data of every Filipino player who uses the jll44 platform. We understand that when you share your personal information with us — whether during account registration, identity verification, or everyday platform use — you are placing trust in jll44, and we take that responsibility seriously.

This Privacy Policy has been prepared in compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, along with its Implementing Rules and Regulations issued by the National Privacy Commission (NPC). It applies to all personal data collected, used, stored, and processed by jll44 in connection with the operation of the j ll44 online gaming platform.

By accessing jll44 at any time — whether you are browsing as a guest, registering a new account, logging in to an existing account, making a deposit, or placing a wager — you acknowledge that you have read, understood, and agreed to the data practices described in this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of the jll44 platform immediately.

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, jll44 acts as the Personal Information Controller in respect of all personal data collected from players and visitors through the jll44 platform. As Personal Information Controller, jll44 determines the purposes and means by which your personal data is processed.

Where jll44 engages third-party service providers to assist in platform operations — such as payment processors, KYC verification partners, or cloud hosting providers — those parties may act as Personal Information Processors under jll44's instruction. jll44 remains responsible for ensuring that such processors handle your data in accordance with the requirements of the Data Privacy Act of 2012 and this Privacy Policy.

jll44 collects only the personal data that is necessary and proportionate to the purposes for which it is collected. The categories of personal data we may collect from you include the following:

jll44 collects personal data through several channels and mechanisms in the ordinary course of operating our platform for Filipino players:

• Account registration: When you create a jll44 account, you voluntarily provide identity and contact information required to set up your player profile.
• KYC verification: When you submit government-issued identification documents and selfie verification as part of the jll44 Know Your Customer process prior to processing your first withdrawal.
• Deposits and withdrawals: When you transact through GCash, Maya, BPI, BDO, Metrobank, or other supported Philippine payment channels, financial data associated with those transactions is collected and retained.
• Platform activity: As you navigate and interact with the jll44 website and game lobby, usage data and technical data are automatically collected through cookies, server logs, and analytics tools.
• Customer support: When you contact jll44's support team via email or live chat, we collect and retain the content of your communications and any documents or screenshots you provide.
• Promotions and surveys: When you participate in jll44 promotional campaigns, competitions, or voluntary feedback surveys, the information you provide in those contexts is collected.
• Third-party verification partners: jll44 may receive additional data about you from licensed KYC and identity verification service providers as part of the player onboarding and fraud prevention process.

jll44 uses the personal data we collect for the following specific purposes, each of which is grounded in a lawful basis as described in Section 6 of this Privacy Policy:

• Account management: Creating, maintaining, and administering your jll44 player account, including processing login credentials, account settings, and communication preferences.
• Identity and age verification: Confirming your identity and verifying that you meet the minimum age requirement of 21 years in accordance with PAGCOR regulations applicable to online gaming in the Philippines.
• Payment processing: Facilitating deposits and withdrawal transactions through your chosen Philippine payment method, and maintaining accurate financial records in connection with your jll44 Wallet.
• Regulatory and legal compliance: Fulfilling jll44's obligations under applicable Philippine law, including anti-money laundering (AML) regulations, counter-terrorism financing (CTF) requirements, and PAGCOR-related regulatory obligations.
• Platform security and fraud prevention: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, bonus abuse, money laundering, and other prohibited conduct on the jll44 platform.
• Responsible gaming: Monitoring gaming activity patterns to identify potential problem gambling behavior and, where appropriate, reaching out to players to offer responsible gaming tools including deposit limits, session reminders, and self-exclusion options.
• Customer support: Responding to your inquiries, resolving disputes, processing complaints, and providing technical assistance related to your jll44 account or gaming activity.
• Platform improvement and analytics: Analyzing aggregated usage data to improve the jll44 platform's performance, user experience, game library, and feature offerings.
• Marketing communications: Where you have given your consent, sending you promotional offers, bonus announcements, and platform news by email or notification. You may withdraw your marketing consent at any time by contacting [email protected].

Under the Data Privacy Act of 2012, jll44 processes your personal data on one or more of the following lawful bases:

• Consent: Where you have freely, specifically, and informedly given your consent to the processing of your personal data for a particular purpose — such as receiving marketing communications or participating in voluntary surveys.
• Contractual necessity: Where the processing of your personal data is necessary to perform the contract between you and jll44 — including fulfilling your account registration, processing your transactions, and delivering gaming services.
• Legal obligation: Where jll44 is required by applicable Philippine law or regulation to process your personal data — including AML compliance obligations, regulatory reporting, and responding to lawful requests from government authorities such as PAGCOR, the Anti-Money Laundering Council (AMLC), or law enforcement agencies.
• Legitimate interests: Where processing is necessary for jll44's legitimate business interests — such as fraud prevention, platform security, responsible gaming monitoring, and improving the player experience — provided that those interests are not overridden by your fundamental rights and freedoms.

Where jll44 relies on consent as its legal basis for any processing activity, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

jll44 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the limited circumstances described below:

• Payment service providers: GCash, Maya, GrabPay, BPI, BDO, Metrobank, InstaPay, PesoNet, and other Philippine payment partners receive the financial data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and applicable Philippine financial regulations.
• KYC and identity verification partners: Licensed third-party KYC verification service providers receive your identity documents and verification data solely for the purpose of confirming your identity and age as part of the jll44 onboarding process.
• Regulatory and government authorities: jll44 may be required to disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts of competent jurisdiction in the Philippines, where required by applicable law or a lawful order.
• Technology and hosting providers: Cloud infrastructure, platform hosting, and cybersecurity service providers may have access to personal data in the course of providing technical services to jll44. These providers are bound by data processing agreements that require them to handle your data in accordance with this Privacy Policy and applicable Philippine law.
• Fraud prevention networks: jll44 may share data with industry fraud prevention services to identify and prevent fraudulent account activity, bonus abuse, or financial crime across the online gaming sector.
• Business transfers: In the event of a merger, acquisition, or sale of all or a portion of jll44's business assets, personal data held by jll44 may be transferred to the relevant successor entity. You will be notified of any such transfer and the applicable privacy terms via the email address registered to your jll44 account.

jll44 retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following general retention guidelines apply:

• Account data: Personal data associated with your jll44 account is retained for the duration of your active account relationship with jll44, and for a period of five (5) years following account closure, in accordance with applicable record-keeping obligations under Philippine law.
• KYC and identity documents: Identity verification documents are retained for a minimum of five (5) years from the date of verification or account closure, whichever is later, consistent with AML regulatory requirements applicable in the Philippines.
• Transaction records: Financial transaction records, including deposit and withdrawal histories, are retained for a minimum of five (5) years from the date of each transaction for AML compliance and dispute resolution purposes.
• Gaming activity records: Game history, wagering records, and session logs are retained for a period of three (3) years following the date of the activity, after which they are securely deleted or anonymised.
• Support communications: Customer support correspondence is retained for a period of two (2) years from the date of each communication, unless a longer retention period is required for ongoing dispute resolution.
• Marketing data: Where you have consented to receive marketing communications from jll44, your contact data used for marketing purposes is retained until you withdraw your consent or request erasure.

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

The jll44 platform uses cookies and similar tracking technologies to enable core platform functionality, enhance your gaming experience, and support platform analytics and security systems. A cookie is a small data file placed on your device when you visit the jll44 website. The types of cookies used by jll44 include:

• Strictly necessary cookies: These cookies are essential for the jll44 platform to function correctly. They enable features such as session authentication, account login state management, and platform navigation. These cookies cannot be disabled without impairing core platform functionality.
• Performance and analytics cookies: These cookies collect aggregated, anonymised data about how players interact with the jll44 platform — including which pages are visited most frequently, session duration, and error reports. This data is used solely to improve platform performance and user experience.
• Functional cookies: These cookies remember your preferences — such as language settings, display preferences, and responsible gaming configuration — to provide a more personalised experience on jll44.
• Security cookies: These cookies support jll44's fraud detection and platform security systems by helping to identify suspicious access patterns and unauthorized login attempts.

You may manage your cookie preferences through your browser settings at any time. However, please note that disabling strictly necessary cookies may prevent you from accessing certain features of the jll44 platform, including account login and transaction functionality.

jll44 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security infrastructure includes, but is not limited to:

• Encryption in transit: All data transmitted between your device and the jll44 platform is encrypted using industry-standard TLS (Transport Layer Security) protocols, ensuring that your personal data and financial information cannot be intercepted during transmission.
• Encryption at rest: Sensitive personal data stored within jll44's systems — including identity documents and financial data — is encrypted at rest using robust encryption standards.
• Access controls: Access to personal data within jll44's systems is strictly limited to authorised personnel on a need-to-know basis. All internal access is subject to role-based access controls, multi-factor authentication, and audit logging.
• Penetration testing and vulnerability assessments: jll44's platform undergoes regular security assessments, including penetration testing by qualified security professionals, to identify and remediate potential vulnerabilities before they can be exploited.
• Incident response: jll44 maintains a documented data breach incident response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, jll44 will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

While jll44 employs rigorous security measures, no online platform can guarantee absolute security. You are also responsible for maintaining the security of your own jll44 account credentials. If you suspect that your account has been compromised, please contact our support team at [email protected] immediately.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by jll44:

• Right to be informed: You have the right to be informed whether your personal data is being collected and processed, and for what purposes — which is the primary purpose of this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data that jll44 holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request that inaccurate or incomplete personal data held by jll44 be corrected or updated. You may update basic profile information directly within your jll44 account settings, or contact our support team for assistance.
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis exists for continued processing. Please note that certain data may need to be retained to fulfil jll44's legal obligations under Philippine law.
• Right to object: You have the right to object to the processing of your personal data on the basis of legitimate interests, direct marketing, or profiling, in circumstances where jll44 cannot demonstrate overriding legitimate grounds for the processing.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible.
• Right to damages: You have the right to claim compensation from jll44 for any damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data, in accordance with applicable Philippine law.

To exercise any of the above rights, please submit a written request to jll44's Data Privacy Officer at [email protected] with the subject line "Data Rights Request — [Type of Request]." We will respond to all verified data rights requests within fifteen (15) business days of receipt.

The jll44 platform is strictly intended for individuals who are 21 years of age or older, in accordance with the minimum age requirement for online gambling participation established by PAGCOR regulations in the Philippines. jll44 does not knowingly collect personal data from individuals under the age of 21.

As part of the jll44 account registration and KYC verification process, all players are required to confirm their date of birth and provide government-issued identification to verify that they meet this age requirement. Any account found to belong to a person under 21 years of age will be immediately suspended, and all associated personal data will be deleted from jll44's systems in accordance with the provisions of the Data Privacy Act of 2012.

If you are a parent or guardian and believe that a minor may have created a jll44 account or provided personal data to jll44 without your knowledge, please contact us immediately at [email protected] and we will investigate and take appropriate action without delay.

The jll44 platform may contain references to third-party payment providers and service partners in the context of describing available deposit and withdrawal methods. jll44 does not include outbound hyperlinks to external third-party websites within the platform's main content areas.

Where you access third-party services — such as GCash or Maya — in connection with processing a deposit or withdrawal on jll44, those services operate independently and are governed by their own privacy policies and terms of service. jll44 is not responsible for the privacy practices or data handling of any third-party service provider, and encourages you to review the privacy policies of any external platform you use in connection with your jll44 account.

jll44 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, platform features, applicable Philippine law, or regulatory requirements. When material changes are made to this Privacy Policy, jll44 will notify registered players by posting a prominent notice on the jll44 platform and, where appropriate, by sending a notification to your registered email address.

The "Last Updated" date displayed at the top of this Privacy Policy reflects the most recent revision. Your continued use of the jll44 platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any revised Privacy Policy, you must cease using the jll44 platform and may request account closure by contacting our support team.

We encourage all jll44 players to review this Privacy Policy periodically to stay informed about how we protect and manage your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or jll44's data handling practices, please contact our Data Privacy Officer using the details below:

jll44 is committed to treating every Filipino player's personal data with the highest standards of care, transparency, and respect. Your trust in jll44 is something we work hard to earn and maintain every day.