jlwin Privacy Policy

1. Introduction

jlwin ("jlwin," "we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the jlwin platform at jlwin.asia and all associated services (the "Service"). This Privacy Policy ("Policy") describes how we collect, use, disclose, and safeguard personal information in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the applicable issuances of the National Privacy Commission ("NPC").

By registering an account, depositing funds, or otherwise using the Service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, you must not use the Service.

This Policy should be read together with the jlwin Terms & Conditions, which are incorporated herein by reference.

2. Data Controller

For the purposes of the DPA and this Policy, jlwin is the personal information controller responsible for the personal data of its registered players and website visitors. Questions or requests relating to this Policy should be directed to the jlwin Data Privacy Officer via the contact details in Section 14.

3. Information We Collect

3.1 Information You Provide Directly

When you register for a jlwin account, complete KYC verification, contact support, or use other features of the Service, you may provide the following categories of personal information:

• Identity Data: Full name, date of birth, nationality, gender;
• Contact Data: Philippine mobile number, email address, residential address;
• Identity Verification Documents: Government-issued Philippine ID (passport, driver's licence, SSS card, PhilSys National ID, PhilHealth card, or COMELEC Voter's ID), selfie photographs submitted for liveness verification;
• Financial Data: GCash account number, PayMaya account details, bank account details (BPI, BDO, Metrobank), cryptocurrency wallet addresses, transaction history, deposit and withdrawal records;
• Account Credentials: Username and hashed password (plain-text passwords are never stored by jlwin);
• Communications: Live chat transcripts, support ticket content, and any other correspondence you submit to jlwin.

3.2 Information Collected Automatically

When you access the Service, jlwin and its service providers automatically collect the following technical and behavioural data:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, unique device identifiers;
• Usage Data: Pages visited, game sessions played, wager amounts, game outcomes, session durations, clickstream data;
• Location Data: General geographic location derived from IP address (used for regulatory compliance and fraud prevention — jlwin does not collect GPS-level location without explicit consent);
• Cookie Data: As described in Section 7.

3.3 Information From Third Parties

jlwin may receive personal data about you from third-party sources, including:

• Payment providers (GCash, PayMaya, BPI, BDO, Metrobank) confirming transaction details;
• Identity verification and KYC service providers;
• Fraud detection and anti-money laundering screening services;
• PAGCOR and other Philippine regulatory bodies, where required by law.

4. How We Use Your Data

jlwin processes your personal data for the following purposes:

• Account Management: To register, maintain, and manage your jlwin account, verify your identity, and process login requests;
• Service Delivery: To facilitate deposits, withdrawals, game play, and bonus processing in Philippine Peso;
• Legal & Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160 as amended), DPA obligations, and NPC directives, including mandatory transaction reporting;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, money laundering, and prohibited conduct;
• Responsible Gaming: To identify at-risk players, enforce self-exclusion lists, apply deposit limits, and comply with PAGCOR's responsible gaming requirements;
• Customer Support: To respond to your queries, resolve disputes, and provide technical assistance;
• Communications: To send you transactional notifications (deposit confirmations, withdrawal status, security alerts) and, where you have consented, promotional offers and game updates;
• Analytics & Improvement: To analyse usage patterns, improve the platform, personalise game recommendations, and optimise the user experience for Filipino players;
• Legal Claims: To establish, exercise, or defend legal claims in connection with your use of the Service.

5. Legal Basis for Processing

Under the DPA and its IRR, jlwin processes your personal data on the following lawful bases:

• Contractual Necessity: Processing required to perform the contract between you and jlwin (account management, payment processing, game delivery);
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the DPA;
• Legitimate Interest: Processing for fraud prevention, platform security, responsible gaming enforcement, and analytics, where such interests are not overridden by your fundamental rights;
• Consent: Processing for optional purposes such as promotional communications, where consent is obtained separately and may be withdrawn at any time.

6. Sharing Your Data

jlwin does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

6.1 Service Providers

Third-party vendors that process data on behalf of jlwin, including cloud hosting providers, KYC verification services, payment gateway operators (GCash, PayMaya, banking partners), fraud detection services, customer support platforms, and email/SMS delivery providers. These processors are contractually bound to process data only as instructed by jlwin and to maintain appropriate security standards.

6.2 Game Providers

Game software providers (JILI, PG Soft, Pragmatic Play, CQ9, and others) may receive technical session data necessary to deliver game functionality. These providers do not receive your identity or financial data beyond what is technically required to run the game session.

6.3 Regulatory & Legal Authorities

jlwin will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and courts where required by law, regulation, or valid legal process. jlwin is legally required to file Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) with the AMLC as mandated by RA 9160.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of assets involving jlwin, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments and notification to you in advance where required by the NPC.

7. Cookies & Tracking Technologies

jlwin uses cookies and similar tracking technologies on jlwin.asia to enable core platform functionality, maintain session state, prevent fraud, and analyse usage. The categories of cookies used include:

• Strictly Necessary Cookies: Required for the platform to function (login sessions, security tokens, payment state). Cannot be disabled without impairing Service functionality.
• Analytics Cookies: Used to understand how players navigate and use the platform, enabling improvements to the user experience. Anonymised aggregate data only.
• Functional Cookies: Remember your preferences such as language, currency display, and game lobby filters.
• Marketing Cookies: Used only where you have expressly consented to receive personalised promotions.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent you from logging into your jlwin account.

8. Data Retention

jlwin retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law. Specific retention periods include:

• Account and KYC Data: Retained for a minimum of five (5) years after account closure, as required by PAGCOR regulations and RA 9160;
• Financial Transaction Records: Retained for a minimum of five (5) years, consistent with AMLC record-keeping requirements;
• Customer Support Communications: Retained for three (3) years after the closure of the relevant support interaction;
• Analytics and Usage Data: Retained in aggregated, anonymised form indefinitely for platform improvement purposes;
• Marketing Consent Records: Retained for the duration of the consent and for two (2) years thereafter as evidence of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard methods.

9. Security Measures

jlwin implements technical and organisational security measures appropriate to the risk level of the data we process, including:

• Transport Layer Security (TLS/HTTPS) for all data transmitted between your device and jlwin servers;
• AES-256 encryption for sensitive data stored at rest;
• Bcrypt hashing for all stored passwords — jlwin staff cannot read your password;
• Multi-factor authentication options for account access;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing by independent third parties;
• Intrusion detection and real-time fraud monitoring systems;
• Incident response procedures compliant with NPC breach notification requirements (mandatory notification within 72 hours for high-risk breaches).

While jlwin employs industry-standard security practices, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials.

10. Your Rights Under the DPA

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by jlwin:

• Right to be Informed: The right to know whether jlwin holds personal data about you and how it is being used — as documented in this Policy;
• Right to Access: The right to request a copy of your personal data held by jlwin, along with information on how it has been processed;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data in your jlwin account;
• Right to Erasure / "Right to be Forgotten": The right to request deletion of your personal data where processing is no longer necessary, subject to jlwin's legal retention obligations under PAGCOR regulations and RA 9160;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller, where technically feasible;
• Right to Object: The right to object to the processing of your personal data for direct marketing or where processing is based on legitimate interest;
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), the right to withdraw that consent at any time without affecting the lawfulness of prior processing;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jlwin has violated your data privacy rights.

To exercise any of these rights, contact the jlwin Data Privacy Officer as described in Section 14. We will respond to verified requests within fifteen (15) business days in accordance with NPC guidelines.

11. Minors

The jlwin Service is strictly for individuals who are 21 years of age or older, in compliance with PAGCOR requirements. jlwin does not knowingly collect personal data from individuals under 21 years of age. If jlwin becomes aware that personal data has been submitted by a person under 21, that account will be closed and all associated data deleted or retained only to the extent required by law. If you believe a minor has registered on jlwin, please notify the Data Privacy Officer immediately.

12. International Data Transfers

jlwin's primary operations and data infrastructure are located within the Philippines. Where personal data is transferred to service providers or game providers operating in other jurisdictions (for example, game servers located in Asia-Pacific data centres), jlwin ensures that such transfers are subject to appropriate safeguards consistent with the DPA's cross-border data transfer requirements, including contractual clauses approved by the NPC or equivalent data protection standards in the destination country.

13. Changes to This Policy

jlwin reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Material changes will be communicated to registered account holders via the mobile number or email address associated with their jlwin account, and this page will be updated with a revised "Last Updated" date.

Your continued use of the Service after the effective date of any updated Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically. Where a change materially affects your rights, we will provide at least fourteen (14) days' prior notice before the change takes effect.

14. Contact & Complaints

For any questions about this Privacy Policy, to exercise your DPA rights, or to report a potential privacy concern, please contact the jlwin Data Privacy Officer:

Email: [email protected]

Support is available in English and Tagalog, 24 hours a day, 7 days a week. For the fastest response to account-specific privacy requests, use the live chat function within your jlwin account dashboard and identify your message as a Data Privacy Request.

If you are not satisfied with jlwin's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC's contact information and complaint procedures are published on the official NPC website.