jl23 Casino Privacy Policy

1.1 This Policy applies to all personal data collected and processed by jl23 through the following channels and activities:

• Registration and maintenance of a jl23 player account;
• Use of the jl23 gaming platform at jl23.club, including all game categories, sportsbook, and live casino services;
• Financial transactions including deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard;
• Interactions with jl23 customer support via live chat or email;
• Participation in jl23 promotions, bonuses, and loyalty programs;
• Browsing jl23.club, including data collected through cookies and analytics tools.

1.2 This Policy does not apply to third-party websites, services, or applications that may be linked from jl23.club. jl23 is not responsible for the privacy practices of any third party, and players are encouraged to review the privacy policies of any third-party services they interact with.

1.3 By registering an account with jl23 or by continuing to use jl23 services after this Policy has been made available to you, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. Where jl23 relies on consent as a lawful basis for specific processing activities, that consent may be withdrawn at any time — see Section 10 for details on exercising your privacy rights.

2.1 jl23 processes personal data only where a lawful basis exists under the Data Privacy Act of 2012 and its Implementing Rules and Regulations. The applicable lawful bases for jl23's data processing activities are:

3.1 jl23 collects personal data across the following categories, depending on the nature of your interaction with the platform:

3.1.1 Identity & Contact Data

• Full legal name as it appears on government-issued identification;
• Date of birth and age verification information;
• Philippine mobile number (used for account verification, OTP delivery, and support contact);
• Email address;
• Residential address within the Philippines.

3.1.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (PhilSys National ID, UMID, Passport, Driver's License, SSS/GSIS/PRC ID);
• Proof of address documentation (utility bills, bank statements, barangay clearance);
• Source of funds documentation where required under PAGCOR or AMLA thresholds;
• Facial photographs or selfie images submitted during identity verification.

3.1.3 Financial & Transaction Data

• GCash mobile number and account identifier;
• PayMaya account identifier;
• Bank account details (BPI, BDO, Metrobank) — account name and masked account number only;
• Payment card details (masked card number, expiry, and billing name — CVV is never stored);
• Complete record of all deposits, withdrawals, bonus transactions, and wagers placed on jl23.

3.1.4 Account & Gaming Activity Data

• Login history including timestamps, device type, and approximate geographic location (region/city level);
• Game session data including games played, stakes, winnings, and session duration;
• Bonus and promotion participation history;
• Responsible gaming settings and limit configurations.

3.1.5 Technical & Device Data

• IP address;
• Device type, operating system, and browser version;
• Cookie identifiers and session tokens (see Section 5);
• Pages visited on jl23.club and navigation path data.

3.1.6 Communications Data

• Records of live chat conversations with jl23 support;
• Email correspondence with jl23;
• Records of complaints and their resolution.

4.1 jl23 uses collected personal data strictly for the following purposes:

4.2 jl23 does not use personal data for automated decision-making that produces significant legal effects — such as automatic account closure or permanent withdrawal refusal — without human review. Where automated systems flag accounts for review (e.g., fraud detection algorithms), a human reviewer confirms the decision before any account action is taken.

5.1 jl23.club uses cookies and similar tracking technologies to deliver, maintain, and improve platform services. The following categories of cookies are used:

• Strictly necessary cookies: Required for the platform to function — session management, security tokens, login state. These cannot be disabled without impairing jl23 functionality.
• Functional cookies: Store your platform preferences such as language settings, responsible gaming configurations, and lobby display preferences across sessions.
• Analytics cookies: Collect aggregated, anonymized data about how players navigate jl23.club, which pages are most visited, and where technical issues occur. Used to improve the platform — not for individual player profiling.
• Marketing cookies: Track whether you arrived at jl23.club via a specific promotion link, for the purpose of crediting promotional sources. Only active where you have provided explicit consent.

5.2 You may manage non-essential cookie preferences through your browser settings. Disabling analytics or marketing cookies will not affect your ability to access your jl23 account or play games. Disabling strictly necessary cookies may impair platform function and is not recommended.

6.1 jl23 does not sell, rent, or commercially license your personal data to third parties under any circumstances.

6.2 jl23 shares personal data with third parties only in the following limited circumstances:

• Payment processors: GCash (Mynt), PayMaya (Voyager Innovations), BancNet, and card network processors receive the minimum data necessary to execute your deposit or withdrawal transaction. All payment providers are contractually bound to handle this data in compliance with Philippine banking regulations and PCI DSS standards;
• KYC and identity verification providers: Where jl23 uses accredited third-party identity verification services to process government ID documents, those providers operate under strict data processing agreements and may not use data for any purpose beyond verification;
• Game software providers: Licensed game providers receive the game session data necessary to operate games you access (e.g., wager amount, game RNG seed). No identity or payment data is shared with game providers;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulatory obligation;
• Law enforcement: Philippine law enforcement agencies where jl23 is required to disclose data by lawful court order, subpoena, or equivalent legal process;
• Professional advisers: Lawyers, auditors, and compliance consultants operating under confidentiality obligations where necessary for jl23's legal and compliance functions.

6.3 Where jl23 engages third-party service providers who process personal data on jl23's behalf (data processors), jl23 ensures that adequate data processing agreements are in place and that processors are bound by obligations equivalent to those jl23 holds under the DPA.

7.1 Some of jl23's technical service providers and game software suppliers operate infrastructure outside the Republic of the Philippines. Where personal data is transferred outside the Philippines, jl23 ensures that such transfers comply with Section 21 of the Data Privacy Act and NPC guidelines on cross-border data transfer.

7.2 jl23 implements the following safeguards for international data transfers:

• Data processing agreements incorporating standard contractual clauses recognized by the NPC;
• Transfer only to countries or organizations that have been assessed to provide an adequate level of data protection;
• Encryption of data in transit using TLS 1.2 or higher for all international transfers;
• Strict data minimization — only data strictly necessary for the service function is transferred internationally.

7.3 jl23 maintains records of all international data transfer arrangements as required by the NPC. Players may request information about applicable transfer safeguards by contacting jl23's Data Protection Officer (see Section 15).

8.1 jl23 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following standard retention periods apply:

8.2 After the applicable retention period expires, jl23 will securely delete or anonymize personal data such that it can no longer be attributed to an identifiable individual. Anonymized aggregate data may be retained indefinitely for analytical purposes.

9.1 jl23 implements a multi-layered data security program designed to protect personal data against unauthorized access, disclosure, alteration, and destruction. Technical and organizational security measures include:

• Encryption in transit: All data transmitted between your device and jl23.club is encrypted using TLS 1.2 / TLS 1.3 with 256-bit encryption;
• Encryption at rest: Sensitive personal data and financial records are encrypted at rest in jl23's database systems;
• Access controls: jl23 employee access to personal data is restricted on a strict need-to-know basis, enforced through role-based access control and multi-factor authentication for system access;
• Payment data security: jl23 does not store full payment card numbers or CVV codes. Payment processing is handled by PCI DSS-compliant payment processors;
• Intrusion detection: Automated monitoring systems detect and alert on unusual access patterns, brute force attempts, and anomalous data access in real time;
• Regular security assessments: jl23 conducts periodic vulnerability assessments and penetration testing of its platform infrastructure.

10.1 As a data subject under the Data Privacy Act of 2012, you hold the following rights with respect to your personal data processed by jl23. These rights may be exercised by contacting jl23's Data Protection Officer (see Section 15):

10.2 jl23 will respond to all privacy rights requests within fifteen (15) business days of receipt. Where a request is complex or relates to a large volume of data, jl23 may extend this period by a further thirty (30) days, with notice provided to you explaining the reason for the extension.

10.3 jl23 may decline requests where compliance would interfere with jl23's legal obligations — for example, a deletion request cannot be honored for KYC and transaction data subject to mandatory AMLA retention periods. In such cases, jl23 will notify you of the applicable retention obligation.

11.1 jl23 implements mandatory age verification as part of the account registration and KYC process. All accounts are required to verify date of birth using a government-issued identification document before withdrawal access is granted.

11.2 If jl23 becomes aware that personal data has been collected from an individual under twenty-one (21) years of age without parental or guardian consent, jl23 will immediately suspend the associated account, delete the collected data to the extent not required to be retained under applicable law, and report the matter to PAGCOR as required by its licensing conditions.

11.3 Parents or guardians who believe a minor has accessed or registered on jl23 are encouraged to contact jl23's support team immediately via live chat or email at [email protected] so that prompt action can be taken.

12.1 jl23 may send promotional communications — including new game announcements, bonus offers, and seasonal promotions — to registered players who have provided explicit opt-in consent to receive marketing communications during the registration process or subsequently through account settings.

12.2 Marketing communications may be delivered via SMS to your registered Philippine mobile number and/or via email to your registered email address. The frequency of marketing communications is limited and jl23 does not engage in aggressive promotional messaging practices.

12.3 You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in your jl23 account settings;
• Clicking the "unsubscribe" link included in any marketing email;
• Contacting jl23 support via live chat or email with an explicit opt-out request.

12.4 Withdrawal of marketing consent does not affect your ability to receive transactional communications necessary for your account — such as deposit confirmations, withdrawal notifications, security alerts, and support responses. These communications are sent on the basis of contractual necessity and cannot be opted out of while your account is active.

13.1 jl23.club may contain references or functional links to third-party services, including payment processors and game provider interfaces that operate within the jl23 platform. Where you interact with a third-party service — for example, completing a GCash authentication flow — you are subject to that third party's privacy policy in respect of data processed by them.

13.2 jl23 is not responsible for the data collection, storage, or processing practices of any third-party service provider, including payment processors, identity verification services, or game software providers. jl23 selects service providers that demonstrate adequate data protection practices, but cannot guarantee or accept responsibility for their independent data handling.

13.3 Players are encouraged to review the privacy policies of all payment providers and third-party services they interact with in connection with their jl23 account.

14.1 jl23 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or jl23's data processing practices. The "Last Updated" date at the top of this Policy will be revised accordingly.

14.2 Where an amendment materially changes the way jl23 processes your personal data — particularly in ways that may affect your rights or the uses to which your data is put — jl23 will provide advance notice to registered players via their registered mobile number or email address at least seven (7) calendar days before the amended Policy takes effect.

14.3 Where an amendment requires fresh consent from you — for example, a new processing purpose for which jl23 relies on consent as the lawful basis — jl23 will seek that consent explicitly before commencing the new processing activity. You may decline to provide such consent without this affecting your existing account or gaming services, unless the new processing is strictly necessary for service delivery.

14.4 The most current version of this Policy is always available at jl23.club/privacy-policy. You are encouraged to review this Policy periodically. Continued use of jl23 services after the effective date of an amended Policy constitutes your acceptance of the amended terms where the amendments do not require fresh consent.

15.1 jl23 has designated a Data Protection Officer (DPO) as required under Section 21(c) of the Data Privacy Act of 2012 and NPC Circular 16-01. The jl23 DPO is responsible for overseeing compliance with the DPA, responding to privacy rights requests, and liaising with the National Privacy Commission.

15.2 All privacy rights requests submitted to jl23 will be acknowledged within twenty-four (24) hours and resolved within fifteen (15) business days, subject to the extension provisions described in Section 10.2.

15.3 If you believe that jl23 has violated your rights under the Data Privacy Act, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. NPC contact details are publicly available at the NPC's official website. jl23 is registered as a personal information controller with the NPC as required under applicable regulations.