jlwin Privacy Policy

1. Introduction

jlwin ("we," "us," or "our") is committed to protecting the privacy and personal data of all users ("you" or "your") who access and use the jlwin online gaming platform (the "Platform"). This Privacy Policy describes how jlwin collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). By registering for or using the jlwin 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 with any part of this Privacy Policy, please discontinue your use of the Platform. For questions or concerns about how jlwin handles your personal data, please refer to the contact details in Section 13 of this policy.

2. Personal Data We Collect

jlwin collects personal data that you provide directly, data generated through your use of the Platform, and data received from third parties in connection with the operation of our services. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Registration data: Full name, date of birth, gender, nationality, residential address (including city , province, ZIP code), email address, and mobile number.
• Identity verification (KYC) data: Government-issued ID (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID), selfie or live photo for facial verification, and proof of address documents.
• Payment data: GCash mobile number, Maya account details, bank account information (bank name, account number, account name), and debit card details. jlwin does not store full card numbers — payment data is tokenised by our payment processors.
• Communications data: Messages, emails, and chat transcripts exchanged with jlwin customer support.
• Responsible gaming data: Self-exclusion requests, deposit limit preferences, and cooling-off period elections.

2.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages visited, games played, session duration, bet history, transaction history, login timestamps, and navigation patterns within the Platform.
• Cookie and tracking data: Data collected via cookies, web beacons, and similar technologies as described in Section 7 of this policy.
• Geolocation data: Approximate location derived from your IP address, used to verify eligibility and comply with geographic restrictions.

2.3 Data Received from Third Parties

• Identity verification results from KYC service providers.
• Payment confirmation and transaction data from payment processors (GCash, Maya, banks).
• Fraud and risk signals from anti-fraud and anti-money laundering (AML) screening services.
• Publicly available information used to fulfil regulatory obligations (e.g., sanctions list screening).

3. How We Use Your Personal Data

jlwin processes your personal data for the following purposes:

jlwin will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

4. Legal Basis for Processing

jlwin processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your jlwin account and deliver the services you have requested.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC, AML, and gaming regulatory requirements.
• Legitimate interests: Processing necessary for jlwin's legitimate business interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — for example, for direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

jlwin does not sell your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this policy:

• Payment processors: GCash, Maya, and banking partners, to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist with identity verification and document authentication.
• Fraud prevention and AML screening services: Providers that help jlwin detect and prevent fraudulent activity and comply with anti-money laundering obligations.
• Game software providers: Licensed game developers whose products are integrated into the jlwin Platform, to the extent necessary to deliver gameplay.
• IT and cloud infrastructure providers: Service providers that host and maintain the Platform's technical infrastructure.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where required by law or regulatory obligation.
• Professional advisers: Lawyers, auditors, and accountants, subject to professional confidentiality obligations.

All third-party service providers engaged by jlwin are required to process your personal data only on jlwin's instructions and in accordance with applicable data protection law. jlwin does not transfer your personal data outside the Philippines except where necessary and in compliance with the requirements of the Data Privacy Act.

6. Cookies & Tracking Technologies

jlwin uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage, and support our security and fraud prevention measures. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly. These cannot be disabled without affecting core functionality such as login sessions and security features.
• Performance and analytics cookies: Used to collect anonymised data about how users interact with the Platform, helping us identify areas for improvement.
• Functional cookies: Used to remember your preferences (e.g., language settings, display preferences) to personalise your experience.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and measure the effectiveness of our marketing campaigns.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

7. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jlwin Platform.
• Encryption of sensitive data at rest, including payment information and identity documents.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Incident response procedures to detect, report, and address personal data breaches in accordance with NPC notification requirements.

While jlwin takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your jlwin account credentials and for notifying us immediately of any suspected unauthorised access to your account.

8. Data Retention

jlwin retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account and transaction data: Retained for a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by applicable law.
• Customer support communications: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing data: Retained until you withdraw your consent to receive marketing communications or request deletion, whichever is earlier.
• Cookie and analytics data: Retained in accordance with the specific retention periods applicable to each cookie type, as described in our cookie settings.

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

9. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jlwin:

• Right to be informed: The right to be notified of how your personal data is being collected and processed.
• Right of access: The right to obtain a copy of the personal data jlwin holds about you and information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful.
• Right to object: The right to object to the processing of your personal data, including for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact jlwin's Data Protection Officer using the contact details in Section 13. jlwin will respond to your request within a reasonable timeframe and in accordance with applicable law. Please note that certain rights may be subject to limitations where jlwin has a legal obligation to retain or process your data.

10. Minors & Age Restriction

The jlwin Platform is strictly intended for individuals who are 21 years of age or older, in compliance with Philippine gambling regulations. jlwin does not knowingly collect personal data from individuals under the age of 21.

If jlwin becomes aware that personal data has been collected from a person under 21 years of age, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the jlwin Platform, please contact us immediately using the details in Section 13.

11. Changes to This Privacy Policy

jlwin 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. When material changes are made, jlwin will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the jlwin Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this Privacy Policy periodically to stay informed of how jlwin protects your personal data.

12. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or jlwin's handling of your personal data, please contact our Data Protection Officer (DPO):

• Email: [email protected]
• General support: [email protected]

jlwin will acknowledge your request promptly and endeavour to resolve your concern within thirty (30) days. If you are not satisfied with jlwin's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).