jll4 Privacy Policy

1. Who We Are and How to Contact Us

jll4 is an online gaming platform operating under the regulatory authority of PAGCOR (Philippine Amusement and Gaming Corporation) and accessible at jll4.app. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), jll4 acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players and visitors.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way jll4 handles your personal data, you may contact our Data Protection Officer (DPO) at:

2. What Personal Data We Collect

jll4 collects the following categories of personal data, depending on how you interact with the platform:

jll4 does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect data relating to racial or ethnic origin, political opinions, religious beliefs, or health information except where directly relevant to responsible gaming assessments.

3. How We Collect Your Data

jll4 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access the jll4 platform;
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering (AML) screening services; payment confirmation data from GCash, Maya, and banking partners; and regulatory data from PAGCOR's exclusion registry.

4. Why We Process Your Data (Legal Bases)

Under the Philippine Data Privacy Act, jll4 must have a lawful basis for processing your personal data. We rely on the following legal bases:

• Contractual necessity: Processing required to create and manage your jll4 account, process transactions, and deliver gaming services under our Terms and Conditions;
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, anti-money laundering (AML) laws, the Philippine Data Privacy Act, and other applicable Philippine regulations;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5. How We Use Your Personal Data

jll4 uses your personal data for the following specific purposes:

• Creating, verifying, and managing your jll4 player account;
• Processing deposits and withdrawals via GCash, Maya, bank transfer, and debit card;
• Conducting KYC identity verification as required by PAGCOR and Philippine AML regulations;
• Detecting, investigating, and preventing fraud, money laundering, and other illegal activity;
• Monitoring gameplay for responsible gaming purposes, including identifying signs of problem gambling;
• Administering bonuses, promotions, and loyalty rewards;
• Providing customer support and responding to your inquiries;
• Sending transactional communications (account confirmations, withdrawal notifications, security alerts);
• Sending promotional communications where you have opted in to receive them;
• Improving the jll4 platform through analytics, A/B testing, and user research;
• Complying with PAGCOR reporting obligations and other legal requirements;
• Enforcing our Terms and Conditions and protecting jll4's legal rights.

6. Sharing Your Data with Third Parties

6.1 jll4 does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances and only to the extent strictly necessary:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and other payment partners, solely to process your financial transactions;
• KYC and AML providers: Third-party identity verification and anti-money laundering screening services engaged by jll4 to fulfil regulatory obligations;
• Game providers: Software providers whose games are hosted on the jll4 platform, who may receive anonymised or pseudonymised gameplay data for technical and fairness purposes;
• Regulatory authorities: PAGCOR and other Philippine government agencies, where disclosure is required by law, court order, or regulatory directive;
• IT and security service providers: Cloud hosting, cybersecurity, and fraud prevention vendors operating under strict data processing agreements with jll4;
• Professional advisers: Lawyers, auditors, and accountants, where necessary for legal or compliance purposes, under obligations of confidentiality.

6.2 All third parties with whom jll4 shares personal data are required to handle that data in accordance with the Philippine Data Privacy Act and are bound by contractual data processing agreements that prohibit them from using your data for any purpose other than the specific service they provide to jll4.

7. Cookies and Tracking Technologies

7.1 jll4 uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyse usage patterns, and deliver a personalised experience. The types of cookies we use include:

• Strictly necessary cookies: Essential for the platform to function. These cannot be disabled as they are required for login sessions, security, and core functionality;
• Performance and analytics cookies: Help us understand how players use jll4 so we can improve the platform. Data collected is aggregated and anonymised where possible;
• Functional cookies: Remember your preferences such as language settings and display options to provide a more personalised experience;
• Marketing cookies: Used only where you have given explicit consent, to deliver relevant promotional content about jll4 services.

7.2 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jll4 platform. Withdrawing consent for non-essential cookies will not affect your ability to use core platform features.

8. Data Retention

8.1 jll4 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by PAGCOR and AML regulations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with Philippine AML and tax laws;
• Gaming history: Retained for three (3) years from the date of each gaming session, or longer if required for dispute resolution or regulatory purposes;
• Customer support communications: Retained for two (2) years from the date of the last communication;
• Marketing consent records: Retained until you withdraw consent, plus one (1) year for compliance documentation purposes;
• Technical and usage data: Retained for up to thirteen (13) months from collection, after which it is aggregated or deleted.

8.2 When personal data is no longer required, jll4 will securely delete or anonymise it in accordance with industry best practices and the requirements of the National Privacy Commission (NPC).

9. Data Security

9.1 jll4 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jll4 platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Multi-factor authentication (MFA) for player accounts and all internal jll4 systems;
• Role-based access controls ensuring that only authorised personnel can access personal data, on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments conducted by independent security firms;
• 24/7 automated monitoring for suspicious activity, intrusion attempts, and data anomalies;
• Secure, geographically redundant data centres with physical access controls.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jll4 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the DPA and NPC Circular No. 16-03.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jll4. You may exercise any of these rights by contacting our Data Protection Officer at [email protected]:

11. Children and Minors

If you are a parent or guardian and believe that a minor in your care has accessed jll4 or provided personal data to us, please contact our support team immediately at [email protected]. We will take prompt action to address the situation.

12. Cross-Border Data Transfers

12.1 Some of jll4's service providers and game technology partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, jll4 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine Data Privacy Act.

12.2 Such safeguards may include contractual data processing agreements incorporating standard data protection clauses, or transfers to countries that the National Privacy Commission has recognised as providing an adequate level of data protection.

12.3 jll4 will not transfer your personal data to jurisdictions that do not provide adequate data protection without your explicit consent, except where required by Philippine law or PAGCOR regulatory directive.

13. Changes to This Privacy Policy

13.1 jll4 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. Material changes will be communicated to registered players via email or in-platform notification at least fourteen (14) days before the changes take effect.

13.2 The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how jll4 protects your personal data.

13.3 Your continued use of the jll4 platform after the effective date of any amendment constitutes your acknowledgement of the updated Privacy Policy. If you do not agree with the changes, you may request account closure by contacting our support team.

14. Complaints and the NPC

14.1 If you have a concern about how jll4 has handled your personal data, we encourage you to contact our Data Protection Officer first so we can attempt to resolve the matter directly and promptly.

14.2 If you are not satisfied with our response, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines, the independent authority responsible for enforcing the Data Privacy Act of 2012. The NPC can be reached through its official government channels.

14.3 jll4 cooperates fully with NPC investigations and is committed to resolving any data privacy concerns in a fair, transparent, and timely manner consistent with our obligations under Philippine law.