jl169 Privacy
Policy

jl169 is a PAGCOR-regulated online gaming platform operating at jl169.cam. As the operator of this platform, jl169 acts as the Personal Information Controller (PIC) in respect of the personal data of its players and users, as defined under the Philippine Data Privacy Act of 2012. This means jl169 determines the purposes for which your personal data is collected and processed, and is responsible for ensuring that such processing is carried out lawfully, fairly, and in accordance with this Policy.

jl169 may engage third-party service providers — including game technology providers, payment processors, and cloud infrastructure partners — who act as Personal Information Processors (PIPs) on behalf of jl169. These processors are contractually bound to handle your data only on jl169's instructions and in compliance with Philippine data protection law.

jl169 collects the following categories of personal data in the course of operating the platform and fulfilling regulatory obligations:

jl169 collects personal data through the following channels:

• Direct Collection: Information you provide during account registration, KYC verification, deposit and withdrawal transactions, support interactions, and completion of any forms or surveys on the jl169 platform.
• Automated Technical Collection: Data collected automatically when you access or use the jl169 platform, including server logs, session data, device identifiers, IP addresses, and browser fingerprint information gathered through standard web technology.
• Payment Processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment channels used to process your deposits and withdrawals. jl169 does not store full card numbers — payment card data is tokenised by the respective payment processor.
• Game Providers: Game session and outcome data from third-party game providers integrated into the jl169 platform, including JILI Gaming. This data is used to maintain accurate transaction records and resolve game-related disputes.
• Cookies and Tracking Technologies: As described in Section 7 of this Policy, jl169 uses cookies and similar technologies to collect usage and preference data when you visit jl169.cam.

jl169 processes your personal data for the following purposes:

• Account Administration: Creating, managing, and maintaining your jl169 player account, including authentication, password resets, and profile updates.
• Identity Verification (KYC): Fulfilling our PAGCOR licence obligations to verify the identity, age (21+), and eligibility of all players before activating withdrawal privileges.
• Payment Processing: Processing your deposits and withdrawals through GCash, PayMaya, and other supported payment methods, and maintaining accurate financial records as required by PAGCOR and AMLC regulations.
• Gaming Services Delivery: Providing access to games, tracking game sessions and outcomes, and maintaining the integrity of gaming records for dispute resolution purposes.
• Regulatory Compliance: Meeting jl169's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act of 2012, and other applicable Philippine laws and regulations.
• Responsible Gaming: Monitoring player activity to identify potential at-risk behaviour, administering self-exclusion requests, and enforcing deposit, loss, and session limits set by players or required under jl169's responsible gaming programme.
• Platform Security: Detecting and preventing fraud, account hacking, collusion, bot activity, money laundering, and other prohibited conduct that violates jl169's Terms & Conditions.
• Customer Support: Responding to your enquiries, resolving disputes, and maintaining records of support interactions.
• Platform Improvement: Analysing aggregated usage data to understand how players interact with jl169, identify technical issues, and improve the platform's functionality, game selection, and user experience.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates by email or SMS, where you have provided consent or where we have a legitimate interest in communicating with you as an existing player. You may opt out of marketing communications at any time through your account settings.

Under the Philippine Data Privacy Act of 2012, jl169 processes your personal data on the following lawful bases:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you as a registered jl169 player — including account management, game access, payment processing, and customer support.
• Legal Obligation: Processing required to comply with applicable Philippine law — including PAGCOR KYC requirements, AMLC anti-money laundering reporting obligations, and tax reporting requirements.
• Legitimate Interest: Processing for jl169's legitimate interests where these are not overridden by your privacy rights — including fraud prevention, platform security, and service improvement through aggregated analytics.
• Consent: Processing based on your freely given, specific, and informed consent — principally for optional marketing communications. You may withdraw consent for consent-based processing at any time without affecting the lawfulness of prior processing.

jl169 does not sell your personal data. We share your data only in the following circumstances and only to the extent necessary for the stated purpose:

• Game Technology Providers: Game session data is shared with third-party game providers (including JILI Gaming) to enable gameplay, determine outcomes, and resolve disputes. These providers are contractually bound to use player data only for these purposes.
• Payment Processors: Financial data necessary to complete deposit and withdrawal transactions is shared with GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and USDT infrastructure partners. Payment processors handle this data under their own privacy frameworks and applicable financial regulation.
• Regulatory Authorities: Identity, transaction, and account data may be disclosed to PAGCOR as the licensing authority, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government bodies where disclosure is required by law, court order, or regulatory directive.
• Cloud Infrastructure Providers: jl169 uses cloud hosting services to operate its platform. Server infrastructure providers may process certain technical data as a necessary consequence of hosting. These providers are subject to contractual data processing agreements that restrict their use of jl169 player data.
• Fraud Prevention and Security Partners: Technical data including IP addresses and device identifiers may be shared with cybersecurity and fraud detection partners to identify and prevent account fraud, hacking, and related prohibited conduct.
• Legal Proceedings: jl169 may disclose your personal data if required to do so in connection with legal proceedings, enforcement of our Terms & Conditions, or the protection of jl169's or another person's legal rights.

jl169.cam uses cookies and similar tracking technologies to improve the functionality and security of the platform. The following cookie categories are used:

• Strictly Necessary Cookies: Essential for the operation of the jl169 platform, including session management, authentication, security token verification, and fraud prevention. These cannot be disabled without impairing core platform functionality.
• Functional Cookies: Enable the platform to remember your preferences, such as language settings, preferred payment method display, and game lobby layout preferences, to provide a more personalised experience.
• Analytics Cookies: Used to collect aggregated, anonymised information about how visitors use jl169.cam — including pages visited, time spent, and navigation paths. This data helps jl169 identify areas for improvement. Analytics cookies do not identify individual players.

You may manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the jl169 platform. jl169 does not use third-party advertising or behavioural targeting cookies on its platform.

jl169 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and AMLC record-keeping obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLC reporting requirements and applicable Philippine tax regulations.
• Game Session Records: Retained for a minimum of three (3) years to support dispute resolution and regulatory audit requirements.
• Customer Support Records: Retained for three (3) years from the date of the relevant interaction.
• Technical and Security Logs: Retained for up to one (1) year for fraud prevention and security monitoring purposes.
• Marketing Consent Records: Retained until you withdraw consent, plus a reasonable period thereafter to demonstrate compliance.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jl169's data destruction procedures.

jl169 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS encryption for all data in transit between your device and jl169's servers.
• AES-256 encryption for personal data stored in jl169's databases.
• Bcrypt hashing for all stored passwords — meaning actual passwords are never stored in recoverable form.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Multi-factor authentication for jl169 internal systems that contain player data.
• Regular third-party penetration testing and security audits of the jl169 platform and infrastructure.
• 24/7 security monitoring with automated alerting for unusual access patterns or potential data breach indicators.
• Physical and logical data centre security controls at all hosting facilities.

In the event of a personal data breach that is likely to result in harm to affected players, jl169 will notify the Philippine National Privacy Commission (NPC) within 72 hours of becoming aware of the breach and will notify affected players as required under the Data Privacy Act of 2012.

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 jl169:

• Right to be Informed: The right to know what personal data jl169 holds about you, why it is being processed, and how it is being used — which this Privacy Policy is designed to fulfil.
• Right to Access: The right to request a copy of the personal data jl169 holds about you, along with information about how it is processed.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You may update most of your account information directly through your jl169 account settings; for identity data, please contact support.
• Right to Erasure: 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 jl169's legal obligations to retain certain data under PAGCOR and AMLC requirements.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible and where processing is based on your consent or on contract.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes. You may exercise this right at any time by updating your communication preferences in your account settings.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jl169 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact jl169's Data Protection Officer via our 24/7 Live Chat or by email at [email protected]. jl169 will respond to data rights requests within the periods prescribed by the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

jl169 strictly prohibits access to and use of its platform by persons under the age of 21, as required by PAGCOR regulations. jl169 does not knowingly collect personal data from individuals under 21. All account registrations are subject to mandatory age and identity verification through the KYC process.

If jl169 becomes aware that personal data has been collected from a person under 21, that account will be immediately closed, the data will be securely deleted to the extent permitted by regulatory record-keeping obligations, and any deposited funds will be returned to the original payment source.

jl169 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. The current version of this Policy, including its effective date, will always be published at jl169.cam/privacy-policy.

Where changes are material — meaning they significantly affect how we use your personal data or your rights as a data subject — jl169 will notify active players by email to their registered address or by prominent notice on the platform. Continued use of jl169 following the publication of a revised Privacy Policy constitutes your acknowledgment of the updated terms.

We encourage you to review this Privacy Policy periodically to stay informed of how jl169 protects and uses your personal information.

For all data privacy-related enquiries, requests to exercise your rights under the Data Privacy Act of 2012, or concerns about how jl169 handles your personal information, please contact us through the following channels:

• Live Chat: Available 24/7 on the jl169 platform — fastest response, typically under 2 minutes.
• Email: [email protected] — data privacy requests are handled by jl169's designated Data Protection Officer and typically receive a response within one business day.

If you are not satisfied with jl169's response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines through PAGCOR's official regulatory channels or directly with the NPC.