jll77 Privacy Policy

01 Introduction

jll77 ("jll77," "the Operator," "the Data Controller") operates an online gaming platform serving Filipino players across the Philippines. As a PAGCOR-licensed operator, jll77 is legally obligated to collect certain personal information from players for regulatory compliance, identity verification, and anti-money laundering purposes.

Beyond regulatory requirements, jll77 collects personal data only where it is necessary to deliver the Platform's gaming services, maintain account security, process payments, communicate with players, and continuously improve the user experience for the Filipino market.

This Privacy Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and applicable issuances of the National Privacy Commission ("NPC"). It is intended to inform you of your rights as a Data Subject and of jll77's obligations as a Personal Information Controller under Philippine law.

02 Data Controller Identity

The Data Controller responsible for your personal information is jll77, operating the Platform at jll77.vip under a license issued by PAGCOR. jll77 has designated a Data Protection Officer ("DPO") as required by the Data Privacy Act of 2012 and NPC Circular No. 16-03.

Inquiries, requests to exercise data subject rights, and complaints relating to personal data processed by jll77 may be directed to the jll77 Data Protection Officer via the contact details set out in Section 15 of this Policy.

03 Personal Data We Collect

jll77 collects the following categories of personal data from players and prospective players:

04 How We Collect Your Data

jll77 collects personal data through the following channels:

4.1 Direct Collection

• Account registration form — name, mobile number, email address, date of birth;
• KYC verification process — government ID documents, proof of address, selfie verification;
• Cashier and payment section — GCash number, Maya account, bank account details for withdrawals;
• Customer support interactions — live chat, email correspondence;
• Responsible gaming tool requests — self-exclusion applications, limit-setting.

4.2 Automated Collection

• Cookies, session tokens, and similar tracking technologies — see Section 8 for details;
• Server logs recording IP addresses, access times, pages requested, and browser types;
• Gaming platform systems recording all wager events, game session data, and transaction activity.

4.3 Third-Party Sources

• Payment processors (GCash, Maya, BPI, BDO, and others) may provide transaction confirmation and account verification data;
• PAGCOR self-exclusion registers, where jll77 is required to cross-reference player accounts against exclusion lists;
• Fraud prevention and AML screening services used to verify player identities against watchlists and sanctions databases, as required by Philippine law.

05 Legal Basis for Processing Personal Data

Under the Philippine Data Privacy Act of 2012, jll77 processes personal data on the following legal bases:

• Performance of a Contract: Processing your personal data is necessary to create and maintain your jll77 account, execute gaming transactions, process payments, and deliver the Platform's services to you;
• Legal Obligation: Processing is required to comply with jll77's obligations under PAGCOR's licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws and regulations;
• Legitimate Interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring, where such interests do not override your rights and freedoms as a Data Subject;
• Consent: Processing for marketing communications and certain cookies, where you have provided explicit, informed, and revocable consent.

06 How jll77 Uses Your Personal Data

jll77 uses collected personal data for the following specific purposes:

• To create, verify, and maintain your jll77 Account;
• To process deposits and withdrawals via GCash, Maya, Philippine bank transfers, and other supported payment methods;
• To verify your identity and age in compliance with PAGCOR's KYC requirements;
• To conduct AML screening and monitor transactions for suspicious activity as required under the AMLA;
• To detect and prevent fraudulent activity, account abuse, and cheating;
• To deliver customer support services via live chat and email;
• To administer bonuses, promotions, and loyalty rewards;
• To monitor gaming activity for responsible gaming purposes and to apply self-exclusion, cooling-off, and limit tools;
• To send account-related notifications including security alerts, deposit confirmations, and withdrawal updates;
• To send marketing and promotional communications, only where you have consented;
• To improve the jll77 Platform, including game library curation, UI design, and payment flow optimization;
• To comply with PAGCOR reporting obligations and other regulatory requirements;
• To resolve disputes and enforce jll77's Terms and Conditions.

07 Data Sharing and Third-Party Disclosure

jll77 does not sell, rent, or trade your personal data to third parties for their independent marketing or commercial use. jll77 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to contractual data protection obligations:

• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, Coins.ph, and other payment service providers — for the purpose of processing your deposits and withdrawals;
• Game Providers: JILI, Pragmatic Play, PG Soft, and other licensed game studios — limited technical data required to deliver game sessions;
• Identity Verification Providers: Third-party KYC service providers used to validate government ID documents in compliance with PAGCOR requirements;
• Anti-Money Laundering Services: Screening services used to comply with AMLA obligations, including sanctions screening and transaction monitoring;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government bodies, as required by Philippine law;
• Law Enforcement: Philippine law enforcement agencies, upon receipt of a valid court order, legal process, or lawful request;
• IT and Platform Service Providers: Cloud hosting, cybersecurity, customer support software, and analytics vendors operating under strict data processing agreements with jll77.

08 Cookies and Tracking Technologies

jll77 uses cookies and similar tracking technologies to operate the Platform, maintain authenticated sessions, detect fraud, analyze usage patterns, and deliver a consistent experience across devices. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for Platform operation — login session management, security tokens, and payment session cookies. These cannot be disabled without impairing Platform functionality;
• Analytics Cookies: Used to understand how players interact with the jll77 Platform — pages visited, session duration, game categories accessed. Data is aggregated and anonymized;
• Functional Cookies: Store your preferences such as language settings, recently played games, and notification preferences;
• Marketing Cookies: Used only where you have provided consent. These may be used to present relevant promotional content. You may withdraw consent at any time via jll77 account settings or by clearing browser cookies.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your jll77 Account.

09 Data Retention

jll77 retains personal data for as long as is necessary to fulfill the purposes for which it was collected and to comply with applicable legal obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your account relationship with jll77 and for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and Philippine AML law;
• Transaction Records: Maintained for a minimum of five (5) years from the date of each transaction, as mandated by the AMLA and PAGCOR requirements;
• KYC Documents: Retained for a minimum of five (5) years following account closure or the date of the last regulated transaction;
• Customer Support Records: Retained for up to three (3) years following resolution of the relevant interaction;
• Marketing Data: Retained until you withdraw consent or request deletion, subject to retention obligations that may supersede the request.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with jll77's data disposal procedures.

10 Data Security

jll77 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, alteration, disclosure, or misuse. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jll77's servers;
• Encryption at rest for all stored personal data and financial records;
• Multi-factor authentication for jll77 platform administrative access;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Intrusion detection systems and 24/7 security monitoring of jll77's infrastructure;
• Secure, redundant data backup procedures with tested recovery processes;
• Mandatory data protection training for all jll77 staff who handle personal data.

11 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jll77:

To exercise any of the above rights, submit a written request to jll77's Data Protection Officer using the contact information in Section 15. jll77 will respond within fifteen (15) business days of receiving a verifiable request. Identity verification may be required before processing your request.

12 Children's Privacy and Age Restriction

jll77 requires all registering players to confirm they are at least 21 years of age and conducts age verification through the KYC process before enabling withdrawal access. If jll77 discovers that personal data has been collected from an individual under the age of 21 years, the account will be immediately closed and all associated personal data will be securely deleted, subject to any legal retention requirements applicable to the account activity.

If you have reason to believe that jll77 holds personal data belonging to a person under 21 years of age, please contact the jll77 Data Protection Officer immediately using the contact details in Section 15.

13 Responsible Gaming and Data Processing

jll77 processes gaming activity data — including session frequency, duration, wager sizes, and deposit patterns — for the purpose of identifying indicators of problem gambling behavior and fulfilling jll77's responsible gaming obligations under PAGCOR's Responsible Gaming Framework.

This monitoring is carried out in jll77's legitimate interest and in the interest of player welfare. Where risk indicators are detected, jll77 may take actions including contacting the player with responsible gaming information, applying platform-level deposit or session limits, or in serious cases, initiating account review procedures.

Self-exclusion requests submitted to jll77 are processed and recorded. jll77 retains self-exclusion records for a minimum of five (5) years to ensure the exclusion can be enforced if the player later attempts to re-register. Self-exclusion information may be shared with PAGCOR's self-exclusion register as required by applicable regulations.

For further information on jll77's responsible gaming tools, please visit the Responsible Gaming page.

14 Changes to This Privacy Policy

jll77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in Philippine law, NPC guidance, PAGCOR regulatory requirements, or jll77's data processing practices. Material changes will be communicated to registered players via email or prominent notice on the Platform prior to the change taking effect.

The current version of this Privacy Policy is always accessible via the Privacy Policy link in the footer of the jll77 website. The "Last Updated" date at the top of this document indicates when the most recent revision was made. Continued use of the jll77 Platform following the effective date of any update constitutes your acknowledgment of the revised Policy.

15 Contact and Data Protection Officer

For all privacy-related inquiries, requests to exercise data subject rights, complaints relating to jll77's handling of your personal data, or data breach reports, please contact jll77's Data Protection Officer:

If you believe jll77 has not adequately addressed your data privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC) through the NPC's official complaints process.