jl12 Privacy Policy

1. Scope and Controller Identity

This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal data by jl12 ("jl12," "we," "us," or "our") in connection with the online gaming platform accessible at https://jl12.cam and all associated subdomains, mobile-optimized pages, and related services (collectively, the "Platform").

jl12 operates under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and complies with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines.

For purposes of the Data Privacy Act, jl12 acts as the Personal Information Controller (PIC) for data processed through this Platform. Any third-party service providers processing data on our behalf operate as Personal Information Processors (PIPs) bound by written data processing agreements.

This Policy applies to all registered users, prospective users, and visitors of the Platform regardless of their location within the Philippines — whether you are accessing jl12 from Metro Manila, Cebu, Davao, or any other region of the country.

2. Information We Collect

jl12 collects personal data in the following categories:

2.1 Registration and Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify the mandatory 21+ age requirement)
• Nationality and country of residence
• Mobile number registered in the Philippines
• Email address
• Username and encrypted account password

2.2 KYC Verification Documents

• Scanned or photographed copy of a Philippine government-issued ID (PhilSys ID, passport, driver's license, SSS card, UMID, or equivalent)
• Selfie or liveness check photograph submitted during identity verification
• Proof of address (utility bill, bank statement, or barangay certificate) where required

2.3 Financial and Transaction Data

• GCash or Maya account reference numbers linked to deposits and withdrawals
• Bank account details (BPI, BDO, Metrobank, or other supported banks) when provided for withdrawal
• Deposit amounts, withdrawal amounts, and transaction timestamps
• Bonus claims, wagering history, and game session records

2.4 Technical and Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser version
• Session duration, pages visited, and features used within the Platform
• Cookie identifiers and similar tracking technologies (see Section 6)

2.5 Communications Data

• Records of customer support interactions via live chat, email, or any other support channel
• Survey or feedback responses submitted voluntarily
• Responsible gaming self-assessment responses where submitted

3. How We Use Your Data

jl12 processes your personal data for the following purposes:

4. Legal Basis for Processing

jl12 processes your personal data under the following legal bases recognized by the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you accepted at registration — including account management, payment processing, and game provision.
• Legal Obligation: Processing mandated by PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws and regulations.
• Legitimate Interest: Processing carried out for fraud prevention, platform security, and system analytics, where our interests do not override your fundamental rights.
• Consent: Processing for direct marketing communications and optional features. You may withdraw consent at any time without affecting prior lawful processing.

5. Data Sharing and Disclosure

jl12 does not sell your personal data. We share data only in the following circumstances:

5.1 Service Providers (PIPs)

We engage third-party service providers acting as Personal Information Processors to operate certain platform functions. These include KYC verification providers, payment gateway operators (GCash, Maya, BancNet-linked institutions), cloud hosting providers, and customer support software vendors. All PIPs are contractually bound to process your data only on jl12's documented instructions and to maintain appropriate security measures.

5.2 Regulatory and Legal Disclosure

jl12 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts when required by law, court order, or regulatory directive. We will not disclose more data than is necessary to comply with the specific legal requirement.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of jl12's business, personal data held by jl12 may be transferred to the acquiring entity, subject to equivalent data protection obligations. Affected users will be notified prior to any such transfer where practicable.

5.4 Aggregate and Anonymized Data

jl12 may share aggregated, anonymized statistical data with game providers, analytics partners, or industry bodies. This data does not identify individual users and is not subject to the same restrictions as personal data.

6. Cookies and Tracking Technologies

jl12 uses cookies and similar technologies to operate the Platform, remember your preferences, maintain your login session, and analyze usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled.
• Functional Cookies: Remember your language preference, display settings, and game lobby filters. Disabling these may reduce Platform functionality.
• Analytics Cookies: Collect aggregated data about how users navigate the Platform — which pages are visited most, session durations, and error occurrences. This data helps jl12 improve the user experience.
• Marketing Cookies: Used only with your consent to track responses to promotional campaigns sent by jl12. These are not used to serve third-party advertisements.

You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in or using the Platform's core features.

7. Data Retention

jl12 retains personal data in accordance with the following schedule:

• Active Account Data: Retained for the duration your account is active plus five (5) years following permanent account closure, to satisfy PAGCOR audit requirements and AML record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification, as required by the Anti-Money Laundering Act.
• Transaction Records: Retained for five (5) years from the date of each transaction.
• Support Communications: Retained for two (2) years from the date of last interaction, unless the subject matter involves an ongoing dispute or regulatory inquiry.
• Marketing Consent Records: Retained until you withdraw consent plus one (1) year thereafter as evidence of prior consent.

Upon expiry of applicable retention periods, personal data is securely deleted, anonymized, or pseudonymized. You may request early deletion of certain data categories where legally permissible — see Section 9 for your rights.

8. Security Measures

jl12 implements a layered security framework to protect personal data against unauthorized access, alteration, disclosure, or destruction. Key measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jl12 servers
• AES-256 encryption for sensitive data at rest, including stored KYC documents and financial records
• Multi-factor authentication (MFA) available for all registered accounts
• Role-based access controls limiting staff access to personal data to only what is necessary for their function
• Regular penetration testing and vulnerability assessments conducted by independent security firms
• 24/7 intrusion detection and monitoring systems on all production infrastructure
• Formal incident response procedures aligned with NPC breach notification requirements

9. Your Rights

Under the Data Privacy Act of 2012, jl12 registered users located in the Philippines have the following rights with respect to their personal data:

• Right to be Informed: The right to know whether jl12 processes your personal data, what data is held, and how it is used — as documented in this Policy.
• Right to Access: The right to request a copy of the personal data jl12 holds about you, including a description of the data categories and processing purposes.
• Right to Rectification: The right to request correction of inaccurate, incomplete, or outdated personal data held in your jl12 account.
• Right to Erasure or Blocking: The right to request deletion or blocking of personal data that is no longer necessary, was processed unlawfully, or where consent has been withdrawn — subject to overriding legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. Objection to processing based on legitimate interest is also available subject to a balancing assessment.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller where technically feasible.
• Right to Damages: The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data.

To exercise any of these rights, contact the jl12 Data Protection Officer (DPO) at the email address listed in Section 13. jl12 will respond to rights requests within fifteen (15) business days of receipt. Identity verification may be required before processing any request.

10. Children and Minors

The jl12 Platform is strictly prohibited to persons under the age of 21 years in accordance with PAGCOR's minimum age requirements for online gambling in the Philippines. jl12 does not knowingly collect personal data from individuals under 21 years of age.

All account registrations require date-of-birth submission, and KYC verification confirms age against government-issued identification. Any account found to have been created by a person under 21 will be immediately suspended, any balance will be refunded net of processing fees where legally permissible, and the account data will be securely deleted.

If you are a parent or guardian and believe a minor has registered on jl12, please contact us immediately at the details in Section 13 so we can investigate and take appropriate action.

11. Cross-Border Data Transfers

jl12's primary data processing infrastructure is located within the Philippines. In limited circumstances, personal data may be transferred to or processed by service providers operating in other jurisdictions — for example, certain cloud infrastructure providers or international KYC verification platforms.

Where such transfers occur, jl12 ensures that the recipient jurisdiction provides an adequate level of data protection, or that appropriate contractual safeguards are in place (such as standard contractual clauses recognized under Philippine data protection law). jl12 does not transfer personal data to jurisdictions that lack adequate privacy protections without first implementing compensating controls.

12. Changes to This Policy

jl12 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material — meaning they significantly affect your rights or how your data is processed — jl12 will provide advance notice via email to your registered address, via a prominent notice on the Platform, or both, at least fourteen (14) days before the changes take effect. Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy.

If you do not agree to the revised Policy, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions. A link to all previous versions of this Policy is available upon request to the DPO.

13. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact the jl12 Data Protection Officer (DPO):

jl12 aims to respond to all privacy-related communications within fifteen (15) business days. For complex or multi-part requests, we may extend this period by an additional fifteen (15) days with prior notice. All requests should be submitted in writing and include sufficient detail for us to identify your account and verify your identity before processing the request.