Privacy Policy

jl45 ("we", "us", "our") operates an online gambling platform serving players in the Philippines. As part of delivering our services — including account registration, deposits, withdrawals, gameplay, customer support, and promotions — we necessarily collect and process personal information about our registered players and website visitors.

This Privacy Policy sets out what personal data we collect, the purposes for which we process it, how long we retain it, with whom we share it, and what rights you hold in relation to that data. It applies to all personal data collected through jl45.org and any related services operated by jl45.

By registering an account, making a deposit, or using any service on the jl45 Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, you must not use the Platform.

This Policy should be read alongside jl45's Terms and Conditions, which form the full legal framework governing your use of the Platform.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules, jl45 is the personal information controller ("PIC") responsible for the personal data processed through the jl45 Platform. jl45 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data privacy law.

Contact details for the jl45 DPO are provided in Section 14 of this Policy. All data subject rights requests, privacy inquiries, and complaints should be directed to the DPO in the first instance.

jl45 collects personal data in several ways: directly from you when you register or use the Platform, automatically through your use of the Platform, and from third parties such as payment processors and identity verification providers. The categories of personal data we process are set out in the table below.

jl45 does not knowingly collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect health, religious, or political data unless required by a specific regulatory obligation.

jl45 processes your personal data for the following purposes:

• Account Registration and Management: To create and maintain your jl45 account, authenticate your identity at login, and manage account settings;
• Service Delivery: To provide access to games, process deposits and withdrawals, credit bonuses, and maintain your balance;
• Identity Verification (KYC): To verify your age (21+ requirement), identity, and source of funds in compliance with PAGCOR regulations and Anti-Money Laundering Act obligations;
• Fraud Prevention and Security: To detect and prevent unauthorised account access, fraudulent transactions, money laundering, bonus abuse, and other prohibited conduct;
• Regulatory Compliance: To fulfil jl45's obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies;
• Customer Support: To respond to your enquiries, resolve disputes, process complaints, and improve support quality;
• Responsible Gaming: To monitor gaming patterns for indicators of problem gambling and to administer self-exclusion, deposit limit, and cooling-off requests;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have not opted out. You may opt out at any time via account settings;
• Platform Improvement: To analyse aggregated, anonymised usage data to improve game selection, platform performance, and user experience;
• Legal Proceedings: To establish, exercise, or defend legal claims involving jl45 or our players.

jl45 does not sell your personal data to third-party marketers or data brokers. We do not use your personal data for automated decision-making that produces legal or similarly significant effects without human oversight.

jl45 processes personal data under the following lawful bases recognised by the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform our contract with you — specifically, to operate your jl45 account and deliver gambling services;
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR regulatory requirements, the Anti-Money Laundering Act, and the Data Privacy Act;
• Legitimate Interests: Processing for fraud prevention, platform security, abuse detection, and service improvement, where those interests are not overridden by your privacy rights;
• Consent: Processing for direct marketing communications, where we have obtained your consent at registration or subsequently. You may withdraw consent at any time.

jl45 does not share your personal data with third parties except in the following circumstances:

• Payment Processors: We share financial transaction data with GCash, PayMaya (Maya), BDO, BPI, Metrobank, and other payment infrastructure providers to process your deposits and withdrawals. These providers are bound by their own privacy policies and Philippine financial regulation;
• Identity Verification Providers: We share identity documents with licensed KYC service providers who perform document authentication and liveness verification on our behalf under data processing agreements;
• Game Providers: Anonymised game session data is shared with licensed game studios (such as JILI, Pragmatic Play, PG Soft) for the purpose of game performance monitoring and RNG certification audits;
• Regulatory Authorities: We are legally required to disclose personal data and transaction records to PAGCOR, the AMLC, the National Privacy Commission, the Bureau of Internal Revenue, and other Philippine government agencies upon lawful request or as part of mandatory reporting obligations;
• Law Enforcement: We may disclose personal data to Philippine law enforcement agencies where required by law, court order, or where we believe disclosure is necessary to prevent fraud, money laundering, or other criminal activity;
• Professional Advisers: We may share personal data with our legal counsel, auditors, and compliance consultants where strictly necessary for legal advice or audit purposes, under appropriate confidentiality obligations;
• Business Transfers: In the event of a merger, acquisition, or sale of jl45's business or assets, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

jl45 retains 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:

At the end of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Anonymised data may be retained indefinitely for aggregate analytics purposes.

jl45 uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function correctly, including maintaining your login session, remembering your language preferences, and processing transactions. These cannot be disabled without disrupting Platform functionality;
• Analytics Cookies: Used to collect anonymised data about how visitors use the Platform — pages visited, session duration, game preferences — to help us improve the service;
• Security Cookies: Used to detect and prevent fraudulent access attempts, bot activity, and other security threats;
• Functional Cookies: Used to remember preferences you have set, such as your preferred game category or responsible gaming settings.

jl45 does not use third-party advertising or cross-site tracking cookies. You can manage cookie preferences through your browser settings. Disabling essential cookies may prevent you from accessing certain Platform features, including your account.

jl45 implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jl45's servers;
• Encryption of sensitive data fields (including passwords, which are stored as salted hashes and never in plain text) at rest;
• Role-based access controls limiting staff access to personal data to those with a legitimate operational need;
• Regular internal and external security audits and penetration testing;
• Multi-factor authentication for all jl45 staff systems that handle personal data;
• Physical and environmental controls at data hosting facilities;
• Formal data breach response procedures aligned with NPC notification requirements.

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, jl45 will notify the National Privacy Commission within 72 hours of becoming aware and will notify affected players without undue delay where required by law.

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to the personal data jl45 holds about you:

• Right to Be Informed: To be told what data we hold, why we hold it, and how it is processed — as set out in this Privacy Policy;
• Right to Access: To obtain a copy of the personal data jl45 holds about you, together with information about how it is processed;
• Right to Correction: To have inaccurate, incomplete, or outdated personal data corrected;
• Right to Erasure / Blocking: To have personal data deleted or processing suspended where jl45 no longer has a lawful basis for retention, subject to overriding legal obligations;
• Right to Object: To object to the processing of your personal data for direct marketing, automated processing, or processing based on legitimate interests;
• Right to Data Portability: To receive a copy of your personal data in a structured, commonly used format where technically feasible;
• Right to Complain: To lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jl45 has violated your data privacy rights.

To exercise any of the above rights, submit a written request to the jl45 DPO using the contact details in Section 14. jl45 will verify your identity before processing any data subject rights request and will respond within 15 business days.

Please note that some rights are subject to limitations — for example, data that jl45 is legally required to retain cannot be deleted upon request. Where a limitation applies, we will explain the reason in our response.

If you believe that jl45 has inadvertently collected personal data from a minor, please notify our DPO immediately using the contact details in Section 14. We will investigate and take appropriate action within 72 hours of receiving such a notification.

Some of jl45's service providers and game studio partners are located outside the Philippines. Where personal data is transferred outside the Philippines, jl45 will ensure that appropriate safeguards are in place in accordance with the Data Privacy Act and NPC regulations, including:

• Contractual data processing agreements requiring the recipient to maintain equivalent privacy and security standards;
• Transfer only to jurisdictions or entities with adequate data protection frameworks as recognised by the NPC;
• Limiting the scope of data transferred to only what is necessary for the specific processing purpose.

You may request details of the specific safeguards applicable to any cross-border transfer by contacting our DPO.

jl45 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or our services. When we make material changes, we will notify registered players via their mobile number or email address and update the "Last Updated" date at the top of this page.

We encourage you to review this Privacy Policy periodically. Your continued use of the jl45 Platform after any update constitutes your acceptance of the revised Policy. If you do not agree with any change, you may close your account and request deletion of your data to the extent permitted by our retention obligations.

For any questions about this Privacy Policy, to exercise your data subject rights, or to raise a privacy concern, please contact the jl45 Data Protection Officer through the following channels:

• Live Chat: Available 24/7 on the jl45 Platform. For urgent data security concerns, live chat is the fastest route — average response time 3–5 minutes;
• Email (DPO): [email protected] — please include "Data Privacy Request" or "DPO" in the subject line;

All privacy-related communications are treated as confidential. The DPO will acknowledge your request within 5 business days and provide a full response or substantive update within 15 business days.

If you are not satisfied with jl45's response to a privacy complaint, you have the right to escalate to the National Privacy Commission (NPC) of the Philippines through their formal complaint process. The NPC's contact details and complaint procedures are available on the NPC's official website.