jl411 Privacy
Policy

This Privacy Policy applies to all personal data processed by jl411 in connection with the operation of the jl411 online gaming platform accessible at jl411.co, including all associated sub-domains, mobile-optimised versions, and any other digital properties operated by jl411 under the same brand.

This Policy applies to all individuals whose personal data is processed by jl411, including registered players, visitors to the jl411 website who have not yet registered, and individuals who contact jl411 through its customer support channels. It applies regardless of the device or location from which the jl411 platform is accessed, subject to any applicable jurisdictional restrictions.

This Privacy Policy should be read in conjunction with the jl411 Terms and Conditions, which are available at jl411.co/terms-conditions. In the event of any conflict between this Policy and the Terms and Conditions on a matter relating specifically to data protection, this Privacy Policy shall take precedence.

For the purposes of the Philippine Data Privacy Act of 2012, jl411 acts as the Personal Information Controller (PIC) in respect of all personal data collected through the jl411 platform. As PIC, jl411 determines the purposes and means by which your personal data is processed.

Where jl411 engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification services, or game platform providers — those parties act as Personal Information Processors (PIPs) and are bound by written data processing agreements that impose data protection obligations consistent with RA 10173.

For all data protection enquiries, please contact the jl411 Data Protection Officer (DPO) at the contact details set out in Section 16 of this Policy.

3.1 Registration & Account Data

When you create a jl411 account, we collect the information you provide during the registration process, which includes:

• Full legal name
• Date of birth (for age verification purposes)
• Email address
• Philippine mobile telephone number
• Username chosen for the account
• Residential address in the Philippines
• Password (stored in hashed and salted form — never in plain text)

3.2 Identity Verification (KYC) Data

To satisfy our obligations under Philippine anti-money laundering regulations and gaming rules, and to unlock full account functionality including withdrawals, we collect and verify:

• Copy of a valid Philippine government-issued identity document (e.g., PhilSys National ID, UMID, Driver's Licence, Passport)
• Proof of address documentation where required
• Selfie or liveness verification photograph
• Source of funds documentation for higher-tier account levels

3.3 Transaction & Financial Data

In connection with deposits, wagers, and withdrawals, we process:

• Deposit transaction records including amount, timestamp, and payment channel (GCash, PayMaya, BPI, BDO, Metrobank, etc.)
• Withdrawal requests and their processing status
• GCash or PayMaya account identifiers (mobile number registered to the wallet)
• Bank account details provided for PESONet or direct bank transfers
• Credit or debit card details — processed exclusively through PCI-DSS compliant payment processors; jl411 does not store full card numbers

3.4 Gaming Activity Data

jl411 maintains records of all gaming activity conducted through your account, including individual bet records, game session data, win and loss outcomes, bonus participation history, and responsible gaming settings and changes.

3.5 Technical & Device Data

When you access the jl411 platform, we automatically collect certain technical information, including:

• IP address
• Browser type and version
• Device type, operating system, and screen resolution
• Session timestamps and duration
• Pages and game categories accessed
• Geolocation data (derived from IP address, not GPS)

3.6 Communications Data

When you contact jl411 through its customer support channels — including live chat, email, or any other communication method jl411 may make available — we retain records of those communications and any personal data contained therein. This data is used for support delivery, quality assurance, and fraud investigation purposes.

jl411 collects personal data through the following channels:

• Directly from you — during account registration, KYC submission, payment processing, customer support interactions, or when you update your account profile.
• Automatically through platform usage — via server logs, session tracking, and cookies and similar technologies as described in Section 8.
• From identity verification service providers — who assist jl411 in verifying the authenticity of KYC documents and matching selfie photographs to identity documents.
• From payment processors — who confirm the status of deposits and withdrawals and provide transaction reference data to jl411 for reconciliation purposes.
• From fraud and risk management tools — including device fingerprinting services and IP intelligence providers, which assist jl411 in identifying suspicious account activity, duplicate registrations, and prohibited jurisdictions.

jl411 processes your personal data for the following purposes, each of which is grounded in a legitimate legal basis as described in Section 6:

• Account creation, management, and authentication
• Age verification and enforcement of the 21+ access restriction
• Identity verification (KYC) to comply with anti-money laundering obligations under Philippine law
• Processing deposits, wagers, winnings, and withdrawals in Philippine Peso
• Delivering and improving the gaming products and platform features available through jl411
• Administering bonus offers, promotions, and the jl411 VIP loyalty programme
• Preventing, detecting, and investigating fraud, money laundering, and other prohibited conduct
• Enforcing the jl411 Terms and Conditions and resolving disputes
• Providing customer support through live chat and email channels
• Sending service-related notifications, including account security alerts and transaction confirmations
• Sending promotional communications about jl411 products and offers — subject to your communication preferences and where consent has been obtained
• Complying with applicable Philippine laws, regulatory obligations, and court orders
• Conducting internal analytics to improve platform performance and player experience
• Implementing and monitoring responsible gaming measures

Under the Philippine Data Privacy Act of 2012, jl411 relies on the following legal bases for processing your personal data:

6.1 Performance of a Contract

The majority of jl411's processing activities are necessary for the performance of the contract between jl411 and the registered Player — specifically, the provision of online gaming services pursuant to the jl411 Terms and Conditions. This includes account management, payment processing, game delivery, and customer support.

6.2 Compliance with Legal Obligation

jl411 processes certain personal data because it is required to do so by Philippine law. This includes KYC/AML obligations under the Anti-Money Laundering Act (AMLA) and its amendments, age verification requirements under PAGCOR-aligned gaming regulations, and data retention obligations imposed by Philippine financial and gaming regulations.

6.3 Legitimate Interests

jl411 processes certain data for its legitimate interests in operating a safe, fair, and commercially viable platform — including fraud detection, security monitoring, responsible gaming compliance, platform analytics, and dispute resolution — provided those interests are not outweighed by the interests or rights of the individual player.

6.4 Consent

Where jl411 sends promotional communications by email or SMS, and where such processing is not already justified on another basis, jl411 relies on your consent. You may withdraw consent for marketing communications at any time by updating your communication preferences in your account settings or by contacting jl411 support.

jl411 does not sell, rent, or trade your personal data. We share your data only in the circumstances described below, and only to the extent necessary for the stated purpose:

7.1 Service Providers (Personal Information Processors)

jl411 engages third-party service providers who process personal data on our behalf under formal written data processing agreements. These include:

• Payment processors handling GCash, PayMaya, bank transfer, and card transactions
• Identity verification and KYC service providers
• Game platform providers and content licensors
• Cloud infrastructure and hosting providers
• Customer support platform providers
• Fraud detection and risk management services
• Email and SMS communication service providers

7.2 Regulatory & Law Enforcement Disclosure

jl411 may disclose personal data to Philippine government bodies, regulatory authorities (including PAGCOR and the Anti-Money Laundering Council (AMLC)), law enforcement agencies, and courts where required to do so by applicable law, court order, or regulatory directive. jl411 will notify you of such disclosures where legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a substantial portion of jl411's business assets, personal data held by jl411 may be transferred to the acquirer as part of that transaction. You will be notified of any such transfer and any consequential changes to this Privacy Policy prior to the transfer taking effect where reasonably practicable.

jl411 uses cookies and similar technologies — including session tokens, local storage, and device fingerprinting — on the jl411 platform. These technologies serve the following purposes:

• Strictly Necessary: Session authentication cookies that keep you logged in during an active session. These cannot be disabled without impairing core platform functionality.
• Functional: Cookies that remember your language and display preferences, game lobby settings, and responsible gaming tool configurations.
• Security: Device fingerprinting and IP intelligence tools used for fraud detection, detection of prohibited jurisdictions, and identification of suspicious login attempts.
• Analytics: First-party analytics cookies that help jl411 understand how the platform is used at an aggregate level, in order to improve performance and user experience. These are processed without identifying individual players.

jl411 does not use third-party advertising cookies or tracking pixels that share your browsing behaviour with external advertising networks.

jl411 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• TLS 1.3 encryption for all data transmitted between your browser and jl411 servers
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records
• Passwords stored exclusively as bcrypt-hashed values — never in recoverable plain-text form
• Role-based access controls ensuring staff access to personal data only on a demonstrable need-to-know basis
• Multi-factor authentication for jl411 staff systems that access personal data
• Regular security vulnerability assessments and penetration testing by independent security professionals
• Formal incident response procedures for data security events

While jl411 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You play an important role in keeping your account secure by maintaining a strong, unique password and enabling two-factor authentication on your jl411 account.

jl411 retains personal data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law. The following indicative retention periods apply:

• Account & Registration Data: Retained for the duration of the active account relationship, plus five (5) years following permanent account closure, in accordance with AML record-keeping requirements under the AMLA.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification, as required by AMLA and its implementing regulations. Where a longer period is required by a regulatory directive or court order, the longer period applies.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with AMLA and gaming regulation requirements.
• Gaming Activity Logs: Retained for three (3) years from the date of each gaming session or wager, after which records are anonymised for aggregate statistical analysis.
• Customer Support Records: Retained for three (3) years from the date of the last support interaction, unless a longer period is required in connection with an unresolved dispute.
• Marketing Consent Records: Retained for the duration of the consent and for three (3) years thereafter, to enable jl411 to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, personal data is securely and irreversibly deleted or anonymised such that it can no longer be associated with an identifiable individual.

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data processed by jl411. These rights may be exercised by submitting a written request to the jl411 DPO at the contact details in Section 16.

jl411 will respond to data subject requests within thirty (30) days of receipt. Where a request is complex or voluminous, this period may be extended by a further thirty (30) days, with prior written notification to the requesting party. jl411 does not charge a fee for the exercise of data subject rights except where requests are manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

The jl411 platform is strictly prohibited for individuals under the age of 21. jl411 does not knowingly collect or process personal data belonging to individuals below the age of 21. Age verification is conducted during the KYC process to enforce this restriction.

If jl411 becomes aware that personal data has been collected from an individual who is under 21 years of age, it will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe that jl411 may hold personal data belonging to your minor child, please contact the jl411 DPO at the details in Section 16 immediately.

Some of jl411's third-party service providers — including cloud infrastructure providers and game content licensors — may process personal data outside of the Philippines. Where such cross-border transfers occur, jl411 ensures that appropriate safeguards are in place to protect the transferred data, including:

• Binding contractual clauses that impose data protection obligations on the receiving party consistent with Philippine law
• Transfers only to jurisdictions that the NPC has recognised as providing an adequate level of data protection
• Compliance with the cross-border transfer provisions of RA 10173 and the NPC's implementing rules

jl411 does not transfer player data to parties in jurisdictions where adequate protections cannot be ensured without implementing the safeguards described above.

In the event of a personal data breach that is likely to pose a real risk of serious harm to affected data subjects, jl411 will:

• Notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, to the extent required by RA 10173 and NPC Circular 16-03 on Personal Data Breach Management.
• Notify affected data subjects in a timely manner where the breach is likely to adversely affect their rights and freedoms, including through their registered email address and a prominent notice on the jl411 platform.
• Conduct a thorough internal investigation to identify the cause of the breach and implement remediation measures to prevent recurrence.
• Document the breach, its effects, and the remediation measures taken, in accordance with NPC accountability requirements.

If you suspect that your jl411 account has been subject to unauthorised access or that your personal data has been compromised, please contact jl411 support immediately through the live chat function or by email as set out in Section 16.

jl411 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance. The effective date at the top of this Policy indicates when the current version came into force.

Where amendments are material — meaning they significantly change the manner in which jl411 processes your personal data or affect your rights — jl411 will provide reasonable advance notice to registered players via their registered email address and through a prominent notice on the jl411 platform prior to the changes taking effect.

Your continued use of the jl411 platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the amended Policy, you may close your jl411 account and request deletion of your personal data subject to any applicable legal retention obligations.

jl411 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and with the Philippine Data Privacy Act of 2012. The DPO is responsible for:

• Monitoring compliance with RA 10173 and jl411's internal data protection policies
• Acting as the primary contact point for data subject rights requests
• Liaising with the National Privacy Commission on data protection matters
• Advising jl411 on data protection impact assessments and privacy-by-design initiatives

To exercise your data subject rights, to submit a privacy complaint, or to ask any question about how jl411 handles your personal data, please contact the DPO through the following channels:

• Email: [email protected] — subject line: "Privacy / DPO Request" (plain text — not a clickable link)
• Live Chat: Available daily, 9 AM to 11 PM Philippine Standard Time, via the jl411 platform

jl411 acknowledges all privacy-related communications within forty-eight (48) hours and will respond substantively within thirty (30) days unless the complexity of the request requires a reasonable extension, in which case jl411 will notify you in advance.