jll16 Privacy Policy

This Privacy Policy ("Policy") is issued by jll16 ("jll16," "we," "us," or "our") and applies to all personal information collected from individuals who visit, register on, or use the services available at jll16.club ("the Platform").

jll16 operates as a PAGCOR-regulated online gaming platform serving registered players in the Republic of the Philippines. As part of our operations, jll16 collects and processes personal data for purposes including account management, identity verification, financial transaction processing, fraud prevention, regulatory compliance, and the delivery of a safe, enjoyable gaming experience.

jll16 is fully committed to upholding your rights as a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). This Policy describes in plain language exactly what data we collect, why we collect it, how long we keep it, and what rights you have over it.

By creating a jll16 account or using any service on jll16.club, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform and contact support to close your account.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, the personal information controller responsible for your data is:

jll16 has designated a Data Protection Officer (DPO) as required by the National Privacy Commission. The DPO oversees jll16's data protection compliance program and is the primary point of contact for data subject rights requests, privacy complaints, and regulatory inquiries from the NPC.

jll16 collects only the personal data necessary to provide its services, comply with legal obligations, and maintain platform security. The categories of data collected are described below.

jll16 does not intentionally collect sensitive personal information (as defined under Section 3(l) of RA 10173) except where directly required by law — for example, collecting nationality for AMLA compliance purposes.

jll16 collects personal data through the following channels:

4.1 Directly From You

• When you register a jll16 account — name, mobile number, email, and date of birth.
• When you complete KYC verification — government ID documents and supporting identity documents.
• When you make a deposit or withdrawal — GCash number, bank account details.
• When you contact jll16 support — information provided in live chat or email correspondence.
• When you update your account profile or configure responsible gaming tools.

4.2 Automatically

• Device and connection data — IP address, browser fingerprint, device type — collected automatically when you access jll16.club.
• Gaming activity data — every bet placed, game launched, win or loss recorded is logged automatically by jll16's gaming systems.
• Session data — login times, session duration, page views, and feature usage patterns.
• Cookies and similar tracking technologies — as described in Section 10 of this Policy.

4.3 From Third Parties

• Payment processors (GCash, PayMaya, BDO, BPI) — transaction confirmation data to verify deposit and withdrawal status.
• Identity verification services — data matching against Philippine government ID databases for KYC purposes.
• PAGCOR exclusion registers — to verify that you are not on a voluntary or involuntary self-exclusion list.
• Fraud prevention services — risk signals and device reputation data from security providers.

jll16 processes your personal data for the following specific, legitimate purposes:

• Account Creation and Management: Creating, maintaining, and securing your jll16 account, including authentication and access control.
• Identity Verification (KYC): Verifying your identity and age eligibility as required by PAGCOR licensing and AMLA compliance obligations.
• Payment Processing: Processing your GCash deposits and withdrawals, reconciling transactions, and maintaining financial records.
• Game Delivery: Operating the jll16 gaming platform, tracking game results, awarding winnings, and maintaining the integrity of all games.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, multi-accounting, and unauthorized access.
• Regulatory Compliance: Meeting obligations under PAGCOR licensing, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and other applicable Philippine laws.
• Responsible Gaming: Monitoring gameplay patterns for signs of problem gambling; operating deposit limits, self-exclusion tools, and player protection features.
• Customer Support: Responding to your enquiries, resolving disputes, and improving service quality.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates — only where you have provided valid consent and only via channels you have opted into.
• Platform Improvement: Analysing aggregated usage data to improve game selection, platform performance, and user experience.

Under the Data Privacy Act of 2012, jll16 relies on the following legal bases for processing your personal data:

• Contractual Necessity (Section 12(b), RA 10173): Processing required to fulfil jll16's obligations under the Player Account Agreement — including account management, payment processing, and game delivery.
• Legal Obligation (Section 12(c), RA 10173): Processing required to comply with PAGCOR licensing conditions, AMLA reporting obligations, NPC regulations, and other mandatory Philippine legal requirements.
• Legitimate Interest (Section 12(f), RA 10173): Processing carried out to pursue jll16's legitimate interests in platform security, fraud prevention, service improvement, and responsible gaming — provided such interests are not overridden by your data subject rights.
• Consent (Section 12(a), RA 10173): Processing for marketing communications and optional analytics, where jll16 has obtained your explicit, informed, freely given, and specific consent.

jll16 does not sell, rent, or share your personal data with third parties for their own commercial purposes. Personal data is shared only in the following circumstances:

7.1 Service Providers

jll16 engages third-party service providers who process personal data on jll16's behalf under written data processing agreements. These include payment processors (GCash / Maya / BDO / BPI / Metrobank), KYC identity verification providers, fraud detection services, cloud infrastructure providers, and customer support software platforms. All processors are required to process personal data only as instructed by jll16 and to maintain security standards equivalent to those applied by jll16.

7.2 Game Providers

Game studios and live casino content providers whose games are hosted on jll16 may receive technical session data (e.g., player session tokens, game round IDs) required to operate their games. These providers do not receive your full personal profile.

7.3 Regulatory and Law Enforcement Authorities

jll16 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government authorities where required by law — including in response to lawfully issued orders, subpoenas, or regulatory directives. jll16 will not notify you of such disclosures where doing so is prohibited by law or where notification would impede an ongoing investigation.

7.4 Corporate Transactions

In the event of a merger, acquisition, reorganization, or sale of jll16's business assets, personal data may be transferred to the acquiring entity. Affected players will be notified prior to any such transfer, and the receiving entity will be required to honour the commitments made in this Policy.

jll16 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. The following retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized such that it can no longer be attributed to an identifiable individual.

jll16 implements industry-standard technical, organizational, and administrative security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and jll16 servers is encrypted using 256-bit SSL/TLS, consistent with the standards applied by Philippine banks and BSP-regulated e-money issuers.
• Password Hashing: Your jll16 account password is stored only as a one-way cryptographic hash. jll16 staff cannot read your password and do not have access to it.
• Two-Factor Authentication (2FA): SMS-based 2FA is available and recommended for all jll16 accounts, adding a second layer of protection beyond your password.
• Access Controls: Access to personal data within jll16's systems is restricted on a need-to-know basis. All internal access is logged and subject to regular review.
• Intrusion Detection: jll16 operates continuous monitoring systems that detect and respond to unauthorized access attempts, suspicious login patterns, and anomalous account activity.
• Data Segmentation: Player funds are held in segregated accounts separate from jll16's operational funds. Financial and personal data systems are logically separated with strict access controls.
• Vendor Security: All third-party processors are assessed for data security standards before engagement. Ongoing compliance monitoring is maintained throughout the vendor relationship.

jll16 uses cookies and similar tracking technologies on jll16.club to operate the platform, improve user experience, and detect fraud. A cookie is a small text file placed on your device when you visit a website. The following categories of cookies are used on jll16.club:

• Strictly Necessary Cookies: Essential for the operation of jll16.club — including session management, authentication tokens, and security tokens. These cookies cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences — such as language settings, remembered devices, and account configuration choices — to deliver a more personalized experience.
• Analytics Cookies: Collect aggregated, anonymized data about how players use jll16.club — including page load times, navigation paths, and feature usage — to help jll16 improve the platform.
• Security and Fraud Prevention Cookies: Used to detect bot activity, credential stuffing attempts, and fraudulent account behavior.

jll16 does not use third-party advertising cookies. No cookie data from jll16.club is shared with advertising networks or used to serve targeted advertisements on other websites.

You may control cookie settings through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use jll16.club. For browsers on Philippine mobile networks (Globe, Smart, DITO), mobile browser cookie settings are typically accessible through the browser's privacy or settings menu.

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 jll16:

To exercise any of the above rights, submit a written request to jll16's Data Protection Officer via live chat or email at [email protected] (displayed as plain text — not a clickable link). jll16 will respond to verified data subject requests within fifteen (15) working days of receipt, as required by NPC Circular No. 2022-01.

jll16 is strictly prohibited from knowingly collecting personal data from, or providing services to, any person under 21 years of age. This restriction aligns with PAGCOR's minimum age requirement for access to regulated online gaming in the Philippines.

During account registration, jll16 collects date of birth and requires confirmation that the registrant is aged 21 or older. KYC identity verification — which includes submission of a government-issued Philippine ID — is used to independently confirm the age of every player before any withdrawal is processed.

If jll16 becomes aware that personal data has been collected from a person under 21, the account will be immediately suspended, all funds held pending investigation, and the data will be securely deleted following completion of any mandatory reporting obligations to PAGCOR. Parents or guardians who believe a minor has registered on jll16 should contact jll16 support immediately.

Some of jll16's service providers — including cloud infrastructure providers and game studios — may process data outside the Philippines. Where personal data is transferred to a recipient in a country other than the Philippines, jll16 ensures that such transfers are subject to appropriate safeguards as required by Section 21 of the Data Privacy Act and NPC regulations, including:

• Standard Contractual Clauses approved by or consistent with NPC guidance on cross-border data flows.
• Adequacy assessments confirming that the recipient country provides a level of data protection substantially equivalent to Philippine standards.
• Data Processing Agreements binding recipients to process personal data only as instructed by jll16 and to maintain equivalent security standards.

jll16 maintains a register of all third-party recipients of personal data, including the country of processing, the legal basis for transfer, and the safeguards applied. This information is available to data subjects upon request.

jll16 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or regulatory guidance from the NPC or PAGCOR. When material changes are made, jll16 will:

• Post a notice on the jll16.club homepage or a prominent banner within the platform.
• Send a notification to your registered email address or via SMS to your registered Philippine mobile number.
• Update the "Last Updated" date at the top of this Policy.

Your continued use of jll16 after the effective date of any amended Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you must stop using jll16 and may request account closure with data deletion as applicable under Section 11 of this Policy.

Where changes involve a new purpose for processing your personal data that requires fresh consent — and where jll16's existing legal basis does not cover that new purpose — jll16 will obtain your explicit consent before commencing the new processing activity.

For all privacy-related enquiries, data subject rights requests, or concerns about how jll16 handles your personal data, please contact jll16's Data Protection Officer through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly on jll16.club. For data subject requests, please select "Privacy / Data Request" from the support menu.
• Email: [email protected] — subject line: "Data Privacy Request" (displayed as plain text, not a clickable link).
• Response Commitment: jll16's DPO acknowledges all data subject requests within 3 working days and provides a substantive response within 15 working days.

For complaints that remain unresolved following jll16's response, you may contact the National Privacy Commission of the Philippines through their official channels. The NPC's complaint process and contact information are available on the NPC's official government website.