Privacy Policy – 123jl Casino Philippines

01 Introduction

This Privacy Policy ("Policy") sets out the basis on which 123jl ("we," "us," "our," or "123jl") collects, processes, stores, and shares personal information about users of the 123jl online gaming platform, accessible at 123jl.one ("the Platform").

This Policy applies to all individuals who visit, register on, or otherwise interact with 123jl, including registered account holders, prospective players, and visitors browsing the platform without a registered account ("Users" or "you").

123jl is committed to processing personal data in compliance with the Republic Act 10173, also known as the Data Privacy Act of 2012 (DPA), and its implementing rules and regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. Our data processing activities are also subject to applicable PAGCOR regulations governing online gaming operators licensed to serve the Philippine market.

By using the 123jl platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of 123jl immediately.

02 Data Controller

For the purposes of the Data Privacy Act of 2012, 123jl acts as the personal information controller (PIC) in respect of personal data collected through the 123jl platform. This means 123jl determines the purposes for which, and the means by which, your personal data is processed.

In circumstances where 123jl engages third-party service providers (such as payment processors, KYC verification providers, and game software providers) to process personal data on its behalf, those parties act as personal information processors (PIPs) and are contractually bound to process data only as directed by 123jl and in accordance with applicable data protection law.

For all data protection inquiries, please contact 123jl's designated Data Protection Officer (DPO) via the contact details provided in Section 14 of this Policy.

03 Information We Collect

123jl collects personal information through several channels: directly from you during registration and ongoing platform use; automatically through your device and browser when you access the platform; and from third-party service providers as part of identity verification and payment processing.

04 How We Use Your Data

123jl processes your personal data for the following purposes:

• Account registration and management — to create, verify, maintain, and administer your 123jl account, including identity verification (KYC) as required under PAGCOR anti-money laundering obligations
• Gaming service delivery — to provide access to all game categories on 123jl, process wagers, settle results, and maintain game history records
• Payment processing — to facilitate deposits via GCash, PayMaya, BPI, BDO, Metrobank, and USDT, and to process withdrawal requests to your registered payment accounts
• Fraud prevention and security — to detect, investigate, and prevent unauthorized account access, money laundering, bonus abuse, identity fraud, and other unlawful activity
• Regulatory compliance — to fulfil obligations under applicable Philippine law, PAGCOR licensing requirements, and anti-money laundering regulations, including the filing of required reports
• Responsible gaming — to monitor player activity for indicators of problem gambling, administer deposit/loss/time limits and self-exclusion requests, and provide cooling-off period functions
• Customer support — to respond to your inquiries, resolve disputes, and provide assistance through live chat and email support channels
• Marketing communications — to send promotional offers, bonus notifications, and platform updates to your registered mobile number or email address, where you have consented to receive such communications
• Platform improvement — to analyze aggregated user behavior data to improve 123jl's features, game selection, loading performance, and overall user experience
• Legal proceedings — to enforce 123jl's Terms & Conditions, defend legal claims, and comply with court orders or regulatory directions

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, 123jl processes your personal data on the following legal bases:

• Contractual necessity — processing required to fulfil the terms of your 123jl account agreement, including identity verification, payment processing, and game access
• Legal obligation — processing required to comply with Philippine law, PAGCOR regulations, Anti-Money Laundering Act (AMLA) obligations, and other applicable regulatory requirements
• Legitimate interests — processing necessary for 123jl's legitimate business interests, including fraud detection, platform security, and service improvement, where those interests are not overridden by your rights and interests
• Consent — processing for marketing communications and non-essential cookies, where you have provided explicit and informed consent, which you may withdraw at any time

06 Data Sharing & Disclosure

6.1 We Do Not Sell Your Data. 123jl does not sell, rent, or trade your personal information to any third party for their independent marketing or commercial purposes.

6.2 Authorized Disclosures. 123jl may share your personal data with the following categories of recipients in the circumstances described:

• Payment Service Providers — GCash (GXchange Inc.), Maya Philippines Inc., and partner banks (BPI, BDO, Metrobank) as required to process deposits and withdrawals in your name
• KYC and Identity Verification Partners — third-party identity verification service providers used to authenticate government-issued IDs and confirm the identity of account holders
• Game Software Providers — licensed game studios such as JILI Gaming, PG Soft, and Pragmatic Play, which may receive anonymized or pseudonymized player data necessary to deliver game functions and RNG certification
• PAGCOR and Regulatory Authorities — as required by law, PAGCOR licensing conditions, or order of a competent Philippine government authority, including Anti-Money Laundering Council (AMLC) reporting obligations
• Law Enforcement — where required by court order, warrant, or mandatory reporting obligation under Philippine criminal law
• Professional Advisers — legal counsel, auditors, and compliance consultants bound by confidentiality obligations who assist 123jl in operating its business lawfully

6.3 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all assets of 123jl, personal data held by 123jl may be transferred to the acquiring entity, subject to the same level of privacy protection required by this Policy and applicable law.

07 Cookies & Tracking Technologies

123jl uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain session authentication, and analyze platform usage. The following types of cookies are used:

• Strictly Necessary Cookies — required for basic platform function, including login session management, OTP device trust tokens, and security features. These cannot be disabled without impairing platform functionality.
• Performance Cookies — collect anonymized data on how users interact with 123jl pages to identify performance issues and optimize loading times, particularly for users on Philippine mobile networks.
• Functionality Cookies — remember your preferences such as preferred game category, language settings, and responsible gaming limit configurations between sessions.
• Analytics Cookies — enable aggregate analysis of user behavior patterns to guide product development decisions. Data collected is pseudonymized and not linked to individual user identities for these purposes.

You may control non-essential cookies through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your 123jl account, as device recognition tokens required for OTP-free login on trusted devices rely on cookie storage.

08 Data Security

123jl implements technical, organizational, and procedural security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 123jl servers
• Encryption of sensitive data fields (including payment credentials and identity document references) at rest using industry-standard encryption algorithms
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need
• OTP-based two-factor authentication for new device logins to prevent unauthorized account access
• Automated account lockout after repeated failed login attempts to prevent brute-force attacks
• Regular security assessments and penetration testing of 123jl platform infrastructure
• Incident response procedures for identifying, containing, and reporting data security breaches within the timeframes required by the NPC under the DPA

09 Data Retention

9.1 Retention Periods. 123jl retains personal data for the periods described below, after which data is securely deleted or irreversibly anonymized:

• Account and identity data — retained for the duration of the active account relationship, plus five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping obligations
• 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 and its implementing rules
• Gaming history — retained for the duration of the active account plus three (3) years following account closure, for dispute resolution and regulatory audit purposes
• Customer support communications — retained for two (2) years from the date of the communication, unless subject to an ongoing dispute or investigation
• Marketing consent records — retained until consent is withdrawn plus two (2) years for compliance audit purposes

9.2 Extended Retention. Notwithstanding the above, 123jl may retain personal data for longer periods where required by a subsisting legal obligation, court order, regulatory direction, or active legal proceeding.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you hold the following rights in relation to your personal data held by 123jl:

• Right to be Informed — the right to know how your personal data is collected, stored, and used, as set out in this Privacy Policy
• Right of Access — the right to request a copy of the personal data 123jl holds about you
• Right to Rectification — the right to request correction of inaccurate or outdated personal data in your 123jl account
• Right to Erasure — the right to request deletion of your personal data where processing is no longer necessary, subject to overriding legal retention obligations
• Right to Object — the right to object to the processing of your personal data for direct marketing purposes; objections to processing based on legitimate interests will be considered against the operational necessity of the processing
• Right to Data Portability — the right to receive your personal data in a structured, commonly used format where technically feasible
• Right to Lodge a Complaint — the right to lodge a complaint with the National Privacy Commission (NPC) if you believe 123jl has processed your personal data in violation of the DPA

To exercise any of the above rights, please contact 123jl's Data Protection Officer using the contact details in Section 14. 123jl will respond to verifiable data subject requests within fifteen (15) business days of receipt. Identity verification will be required before 123jl can process any data access, rectification, or deletion request.

Note that certain rights are subject to limitations where the data is required for ongoing legal compliance (for example, AMLC transaction records cannot be deleted on request during the mandatory retention period).

11 Children's Privacy

The 123jl platform is strictly intended for adults aged twenty-one (21) years and above. 123jl does not knowingly collect personal data from individuals under 21 years of age. Account registration requires confirmation of age eligibility, and 123jl's KYC process is designed to detect and reject registration attempts by underage individuals.

If 123jl becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately, the associated account will be closed without compensation of any balance, and the matter may be reported to PAGCOR in accordance with applicable regulations.

If you are a parent or guardian and believe your child has accessed or registered on 123jl, please contact 123jl support immediately with relevant information so the account can be investigated and closed.

12 International Data Transfers

123jl's primary data processing infrastructure is located in the Philippines and/or jurisdictions providing equivalent data protection. In certain circumstances, personal data may be transferred to, or accessible by, service providers located in other countries — for example, where a game software provider's technical infrastructure is based outside the Philippines.

Where personal data is transferred internationally, 123jl ensures that such transfers are subject to appropriate safeguards, including contractual obligations requiring the recipient to maintain data protection standards consistent with the Philippine Data Privacy Act of 2012 and this Privacy Policy.

13 Changes to This Privacy Policy

123jl reserves the right to update or amend this Privacy Policy at any time. Material changes to the Policy will be communicated to registered account holders via their registered contact details and/or via a prominent notice on the 123jl platform. The effective date at the top of this document reflects the date of the most recent revision.

Your continued use of the 123jl platform following notification of a Policy update constitutes acceptance of the revised Privacy Policy. If you do not agree to the revised Policy, you must discontinue use of 123jl and may request account closure in accordance with Section 13.3 of the Terms & Conditions.

14 Contact the Data Protection Officer

For all data protection inquiries, data subject rights requests, or privacy concerns related to your 123jl account or this Privacy Policy, please contact 123jl's designated Data Protection Officer through the following channels:

• Email (plain text): [email protected] — subject line "DPO — Privacy Inquiry"
• Live Chat: Available 24/7 directly on the 123jl platform — state "Data Protection" at the start of your chat
• Response Time: Data subject rights requests responded to within 15 business days of identity verification

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated. Information on how to file a complaint with the NPC is available through official Philippine government channels.

For responsible gaming tools and support, please visit the Responsible Gaming page on 123jl.