jl115 Privacy Policy

1. Introduction

jl115 ("we", "us", "our", or "jl115") operates an online gaming platform accessible at jl115.net, offering live dealer games, slots, fishing games, sports betting, bingo, and related services to players in the Philippines. As a data controller, jl115 is responsible for the personal data you provide when you register, play, or otherwise interact with the Platform.

This Privacy Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC) of the Philippines. It also reflects our obligations under applicable PAGCOR regulations concerning player data management.

By registering an account on jl115 or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the jl115 Platform.

2. Personal Data We Collect

jl115 collects the following categories of personal data from players and visitors to the Platform:

2.1 Registration and Identity Data

• Full legal name;
• Date of birth (for age verification purposes);
• Philippine mobile number;
• Email address;
• Username and encrypted password;
• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence) submitted during KYC verification.

2.2 Financial and Transaction Data

• GCash or PayMaya (Maya) account details linked to your jl115 account;
• Philippine bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) used for deposits or withdrawals;
• Debit card details where applicable;
• Transaction history, including deposit amounts, withdrawal requests, and bonus credits, all denominated in Philippine Peso (₱ / PHP).

2.3 Gaming Activity Data

• Game session logs, including games played, wagers placed, and outcomes;
• Betting history across all game categories (live dealer, slots, fishing, sportsbook, bingo);
• Responsible gaming tool usage, including deposit limits and self-exclusion requests.

2.4 Technical and Device Data

• IP address and approximate geographic location;
• Device type, operating system, and browser version;
• Session timestamps and duration;
• Cookie identifiers and similar tracking technologies.

2.5 Communications Data

• Records of your communications with jl115 customer support, including live chat transcripts and support ticket history;
• Responses to surveys or feedback requests, where voluntarily provided.

3. How We Collect Your Data

jl115 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey;
• Automatically — through cookies, web beacons, and server logs when you access and navigate the Platform;
• From third-party payment processors — GCash, PayMaya, and Philippine banking partners may share transaction confirmation data with jl115 to facilitate deposits and withdrawals;
• From identity verification providers — where jl115 uses third-party KYC services to verify the authenticity of identification documents submitted by players;
• From regulatory authorities — PAGCOR or the Anti-Money Laundering Council (AMLC) may share information with jl115 in connection with regulatory compliance obligations.

4. How We Use Your Data

jl115 uses the personal data we collect for the following purposes:

jl115 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by applicable law or regulation.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, jl115 processes your personal data on the following legal bases:

• Consent — you have given your informed, freely given, specific, and unambiguous consent to the processing of your personal data for the purposes described in this Policy, as indicated at the point of registration;
• Contractual necessity — processing is necessary for the performance of the contract between you and jl115, including account management, game delivery, and payment processing;
• Legal obligation — processing is required to comply with applicable Philippine laws, including the Data Privacy Act, the Anti-Money Laundering Act (RA 9160 as amended), and PAGCOR regulatory requirements;
• Legitimate interests — processing is necessary for jl115's legitimate interests in fraud prevention, Platform security, and responsible gaming monitoring, provided such interests are not overridden by your rights and freedoms.

Where jl115 relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. To withdraw consent, please contact jl115 customer support.

6. Data Sharing & Disclosure

jl115 does not sell, rent, or trade your personal data to third-party marketers. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

6.1 Service Providers and Processors

jl115 engages third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, Philippine banks), KYC and identity verification providers, cloud hosting and infrastructure providers, customer support platform operators, and fraud detection and cybersecurity vendors. All such providers are contractually bound to process your data only on jl115's instructions and in accordance with applicable data protection law.

6.2 Game Content Providers

Third-party game studios whose content is made available on jl115 may receive limited technical and session data necessary to deliver their games. These providers do not receive your full identity or financial data.

6.3 Regulatory and Law Enforcement Authorities

jl115 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Philippine National Police (PNP), or other competent authorities where required by law, court order, or regulatory directive. Such disclosures are made in good faith and do not constitute a breach of this Privacy Policy.

6.4 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets involving jl115, your personal data may be transferred to the relevant successor entity, subject to the same data protection obligations set out in this Policy. You will be notified of any such transfer in accordance with applicable law.

6.5 With Your Consent

jl115 may share your personal data with other third parties where you have given your explicit prior consent to such sharing.

7. Cookies & Tracking Technologies

jl115 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. The following categories of cookies are used:

You can manage or disable cookies through your browser settings. Please note that disabling strictly necessary cookies may impair your ability to log in and use the Platform. jl115 does not use cookies to serve third-party advertising.

8. Data Retention

jl115 retains your 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 retention periods apply:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements;
• Financial and transaction data — retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act;
• Gaming activity data — retained for a minimum of three (3) years from the date of each session, for regulatory audit and responsible gaming purposes;
• Customer support communications — retained for two (2) years from the date of the last interaction;
• Technical and device data — retained for up to twelve (12) months from collection, unless required for longer periods for fraud investigation purposes.

Upon expiry of the applicable retention period, jl115 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Data Security

jl115 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) — all data transmitted between your device and jl115 servers is encrypted in transit;
• Password hashing — account passwords are stored using industry-standard one-way cryptographic hashing algorithms and are never stored in plain text;
• Access controls — access to personal data within jl115 is restricted to authorised personnel on a strict need-to-know basis, with role-based access controls enforced;
• Infrastructure security — jl115 servers are hosted in secure data centre environments with physical access controls, intrusion detection systems, and regular security audits;
• Incident response — jl115 maintains a data breach response procedure and will notify affected players and the National Privacy Commission within the timeframes required by the Data Privacy Act in the event of a personal data breach.

10. Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl115. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

jl115 will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with the Data Privacy Act. We may request proof of identity before processing your request to protect against unauthorised access to your data.

11. Children's Privacy

jl115 is strictly an adult gaming platform. Access is limited to individuals who are at least 21 years of age, in compliance with Philippine gaming regulations. jl115 does not knowingly collect personal data from individuals under the age of 21.

If jl115 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on jl115, please contact us immediately using the details in Section 14.

12. Cross-Border Data Transfers

jl115 primarily stores and processes your personal data within the Philippines. In certain circumstances, your data may be transferred to or accessed from servers or service providers located outside the Philippines, including cloud infrastructure providers and game content studios operating in other jurisdictions.

Where such cross-border transfers occur, jl115 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual clauses approved by the National Privacy Commission, adequacy determinations, or other legally recognised transfer mechanisms.

By using the jl115 Platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

13. Updates to This Policy

jl115 reserves the right to update or amend 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, jl115 will notify registered players via the Platform or by message to the mobile number or email address registered on your account, providing reasonable advance notice before the changes take effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how jl115 protects your personal data.

14. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to raise a complaint about jl115's handling of your personal data, please contact our Data Protection Officer:

If you are not satisfied with jl115's response to your complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint with the NPC is available through official Philippine government channels.