jl163 Privacy Policy
How We Protect Your Data

1 Introduction

This Privacy Policy (the "Policy") describes how jl163 (referred to herein as "jl163," "We," "Us," or "Our") collects, uses, stores, discloses, and otherwise processes personal information about individuals who access or use the jl163 platform at jl163.app (the "Platform") and any related services (together, the "Service").

jl163 is committed to protecting the personal data of its players and to complying 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 (NPC) of the Philippines. jl163 also operates in compliance with the data-related requirements of the Philippine Amusement and Gaming Corporation (PAGCOR) as part of its regulatory obligations.

By registering for an account on jl163 or otherwise using the Service, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you should not create an account or use the Service.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection law, jl163 is the personal information controller in respect of personal data collected through the Platform and the Service. jl163 determines the purposes for which and the means by which personal data is processed.

jl163 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection legislation. Contact details for the DPO are provided in Section 15 of this Policy.

3 Personal Data We Collect

jl163 collects the following categories of personal data, depending on your interaction with the Service:

3.1 Registration and Account Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Registered mobile number and/or email address
• Username and encrypted password
• Preferred language and currency settings

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine National ID / PhilSys Card, passport, driver's licence, SSS ID, UMID)
• Proof of address documents where required
• Selfie or liveness verification image where applicable
• Taxpayer Identification Number (TIN) where required by Philippine law or PAGCOR regulations

3.3 Financial Data

• GCash mobile number, Maya / PayMaya account reference, or bank account details used for deposits and withdrawals
• Transaction history: deposits, withdrawals, wager amounts, winnings, and bonus credits
• Payment method type and relevant masked identifiers

3.4 Gaming Activity Data

• Games accessed, wagering patterns, session durations, and in-game decisions
• Sportsbook bet history including event, selection, stake, and outcome
• Responsible gaming tool settings, including deposit limits and self-exclusion status

3.5 Technical and Device Data

• IP address and geolocation data derived from IP
• Device type, operating system, browser type, and version
• Session identifiers, login timestamps, and session activity logs
• Referral source and marketing attribution data

3.6 Communications Data

• Customer support chat transcripts, emails, and call records (where applicable)
• Survey responses and feedback submitted via the Platform
• Preferences for marketing communications

4 How We Collect Your Data

jl163 collects personal data through the following means:

• Directly from you when you register an account, complete KYC verification, make deposits or withdrawals, contact support, respond to surveys, or adjust your account preferences.
• Automatically during your use of the Platform, including through server logs, session tracking, and technical cookies and similar technologies (see Section 10 for details on cookies).
• From third-party KYC and AML service providers that jl163 engages to perform identity verification, document authentication, and sanctions screening as required by PAGCOR regulations and Philippine AML laws.
• From payment processors and e-wallet providers (such as GCash and Maya networks) in connection with the processing of deposits and withdrawals — limited to data necessary to complete and record the transaction.
• From public sources and databases as permitted by Philippine law, including for fraud prevention, politically-exposed person (PEP) screening, and sanctions list checking.

5 Purposes of Processing and Legal Bases

The table below sets out the purposes for which jl163 processes personal data, the categories of data involved, and the legal basis for that processing under the Data Privacy Act of 2012:

6 Data Sharing and Disclosure

jl163 does not sell, rent, or trade your personal data to third parties for marketing purposes. jl163 may share your personal data with the following categories of recipients only to the extent necessary for the described purpose:

• KYC and AML service providers: Third-party providers engaged to perform identity document verification, liveness checks, and sanctions and PEP screening, as required by PAGCOR and Philippine AML regulations.
• Payment processors and e-wallet networks: GCash, Maya / PayMaya, and other licensed Philippine payment service providers engaged to process your deposits and withdrawals in Philippine Peso.
• Game software providers: International game development studios that supply the casino games on jl163 may receive session-level technical data necessary for game operation and certification audit purposes. These providers are bound by contractual data protection obligations.
• Cloud infrastructure and hosting providers: Providers that host the jl163 Platform and its databases, subject to contractual security and confidentiality requirements.
• PAGCOR: As jl163's regulatory authority, PAGCOR may require disclosure of player data including account information, KYC records, and gaming activity as part of its regulatory oversight functions. Such disclosures are mandatory.
• Philippine law enforcement and courts: jl163 will disclose personal data to the Anti-Money Laundering Council (AMLC), the National Bureau of Investigation (NBI), the Philippine National Police (PNP), courts, or other lawful authorities where required by a valid legal process, court order, or mandatory reporting obligation.
• Successor entities: In the event of a business merger, acquisition, or restructuring involving jl163, your personal data may be transferred to the successor entity, subject to the same data protection obligations as described in this Policy.

7 International Data Transfers

Certain service providers engaged by jl163 — particularly game software developers, cloud infrastructure providers, and fraud prevention systems — may be located or operate servers outside the Republic of the Philippines. Where personal data is transferred outside the Philippines, jl163 ensures that appropriate safeguards are in place as required by the Data Privacy Act of 2012 and the rules of the National Privacy Commission.

Such safeguards include contractual clauses that impose data protection obligations on the receiving party equivalent to those applicable in the Philippines, and, where available, transfer to jurisdictions that have been assessed as providing an adequate level of data protection. jl163 does not transfer personal data to countries or organisations that cannot demonstrate appropriate protections.

8 Data Retention

jl163 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected or as required by law. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by the Anti-Money Laundering Act (AMLA) of the Philippines and PAGCOR's record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years following the date of the relevant transaction, in line with AMLA obligations.
• Gaming activity and session logs: Retained for a minimum of three (3) years for responsible gaming monitoring, fraud prevention, and regulatory audit purposes.
• Customer support communications: Retained for two (2) years following the closure of the support case, unless a longer period is required for ongoing dispute resolution or legal proceedings.
• Marketing consent records: Retained for the duration of the marketing relationship and for one year following withdrawal of consent, as evidence of the consent given.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with jl163's data disposal procedures.

9 Security Measures

jl163 implements technical and organisational security measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, and unauthorised access. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and jl163.app.
• Encryption at rest for sensitive data stored on jl163 servers, including password hashing using industry-standard cryptographic functions.
• Access controls and role-based permissions limiting access to personal data to jl163 staff members and third-party personnel who require it for their specific functions.
• Two-factor authentication (2FA) available for player accounts to prevent unauthorised login.
• Session monitoring and anomaly detection to identify and flag unusual account activity patterns.
• Regular security assessments and penetration testing conducted by qualified security professionals.
• Staff data protection training for jl163 personnel who handle personal data.

Notwithstanding these measures, no data transmission over the internet or electronic storage system is completely secure. jl163 cannot guarantee absolute security but commits to implementing commercially reasonable and legally required security standards. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl163 will notify the National Privacy Commission and affected individuals in accordance with the Data Privacy Act and NPC Circular No. 16-03.

10 Cookies and Tracking Technologies

jl163 uses cookies and similar tracking technologies on the Platform to ensure it functions correctly, to remember your preferences, to analyse usage patterns, and where you have consented, to deliver relevant promotional content.

10.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to operate. These include session authentication cookies that keep you logged in during a session and security cookies that protect against cross-site request forgery (CSRF). These cannot be disabled without breaking the Service.
• Functional Cookies: Remember your preferences such as language settings and game lobby layout. These enhance your experience but are not essential to core functionality.
• Analytics Cookies: Collect anonymised or aggregated data about how players use the Platform — which pages are visited, how long sessions last, and where errors occur. This data is used solely to improve the Platform.
• Marketing Cookies: Used where you have consented to receive personalised promotional content. These track your activity on the Platform to assess the relevance of promotional offers.

10.2 Managing Cookies

You can manage non-essential cookies through your browser settings by disabling or deleting cookies. Note that disabling certain cookies may impair your experience on jl163.app. Strictly necessary cookies cannot be disabled via browser settings without breaking core Platform functionality.

11 Your Data Subject Rights

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights in respect of your personal data held by jl163:

• Right to be Informed: The right to be informed whether jl163 holds personal data about you, the purposes of processing, and your rights in relation to that data. This Policy fulfils this obligation.
• Right of Access: The right to request a copy of the personal data jl163 holds about you, together with information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. For basic account data, you may update your profile directly within your jl163 account settings.
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data where jl163 no longer has a lawful basis to retain it. Note that this right is subject to jl163's legal obligations to retain data under AMLA, PAGCOR regulations, and other applicable laws — data subject to mandatory retention periods cannot be deleted until those periods expire.
• Right to Object: The right to object to the processing of your personal data where that processing is based on jl163's legitimate interests. You also have an absolute right to object to processing for direct marketing purposes at any time.
• Right to Data Portability: The right to receive personal data you have provided to jl163 in a structured, commonly used, machine-readable format and to have it transmitted to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jl163 has violated your data protection rights. Contact information for the NPC is available on the NPC's official website.

12 Children's Privacy

The jl163 Service is strictly intended for adults aged 21 years and above as required by PAGCOR for all licensed online gambling platforms in the Philippines. jl163 does not knowingly collect personal data from individuals under the age of 21.

If jl163 becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, all associated funds will be forfeited (including any winnings), and the personal data will be deleted to the extent not required by law for reporting or investigation purposes.

If you are a parent or guardian and believe a person under 21 in your care has registered on jl163, please contact support immediately via Live Chat or at the contact details in Section 15 so we can take prompt action.

13 Marketing Communications

jl163 may send you promotional and marketing communications about new games, bonuses, promotions, and Platform features. jl163 will only send marketing communications to players who have provided consent to receive them, either at the time of registration or subsequently through account settings.

You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in your jl163 account settings;
• Clicking the "unsubscribe" link in any marketing email you receive from jl163; or
• Contacting jl163 support and requesting removal from marketing communications.

Withdrawal of marketing consent does not affect your ability to continue using the jl163 Service or to receive transactional communications relating to your account (such as deposit confirmations, withdrawal notifications, and security alerts).

14 Changes to This Privacy Policy

jl163 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending a notification to your registered email address or mobile number.

The "Last Updated" date at the top of this Policy will be revised to reflect the date of the most recent amendment. We encourage you to review this Policy periodically. Your continued use of the jl163 Service following the publication of an updated Policy constitutes your acceptance of the revised terms.

15 Contact Us and Data Protection Officer

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

jl163 is committed to resolving data privacy concerns promptly. We will acknowledge receipt of a data subject request within five (5) business days and will provide a substantive response within fifteen (15) business days, extendable by a further fifteen (15) days where the complexity of the request requires it, with prior notice to you of the extension.