Privacy Policy

1. Introduction

jlq ("jlq," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the jlq online gaming platform at jlq.one ("Platform"). We understand that Filipino players trust us with sensitive personal and financial information, and we take that responsibility seriously.

This Privacy Policy ("Policy") describes in detail the categories of personal data we collect from you, the purposes for which we process that data, the legal bases on which we rely, the parties with whom we may share your data, the security measures we employ to protect it, and the rights you have in relation to your personal data under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

This Policy should be read together with jlq's Terms & Conditions, which govern your use of the Platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, jlq is the personal information controller in respect of the personal data collected through the Platform. This means jlq determines the purposes and means of processing your personal data.

jlq has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 15 of this Policy.

3. Categories of Personal Data We Collect

jlq collects the following categories of personal data from players and prospective players:

3.1 Identity Data

• Full legal name as it appears on your government-issued identification
• Date of birth
• Gender
• Nationality
• Government-issued identification number (e.g., PhilSys ID number, passport number, driver's license number)
• Copies of identification documents submitted during KYC verification

3.2 Contact Data

• Philippine mobile number
• Email address
• Residential address (province, city/municipality, barangay)

3.3 Financial Data

• GCash or Maya account details (mobile number associated with the account)
• Bank account details (bank name, account number) for bank transfer transactions
• Debit card details (card number masked, expiry date) where applicable
• Transaction history including deposits, withdrawals, and gaming activity

3.4 Technical Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Session logs, login timestamps, and access records
• Cookie identifiers and similar tracking technologies

3.5 Gaming Data

• Game history, bet amounts, win/loss records, and session duration
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion status)

3.6 Communications Data

• Records of customer support interactions (chat logs, email correspondence)
• Survey responses and feedback submitted to jlq
• Marketing preferences and communication opt-in/opt-out records

4. How We Collect Your Data

jlq collects personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment verification data from payment processors such as GCash, Maya, and partner banks.
• Regulatory Sources: Data received from PAGCOR or other regulatory authorities in connection with licensing, compliance, or investigation requirements.

5. How We Use Your Personal Data

jlq processes your personal data for the following purposes:

• Account Management: To create, maintain, verify, and administer your jlq account, including KYC verification and ongoing account monitoring.
• Service Delivery: To provide access to games, process deposits and withdrawals, apply bonuses, and deliver all features of the Platform.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, Philippine anti-money laundering laws (AMLA), the DPA, and other applicable regulations. This includes mandatory reporting obligations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeover, and other security threats.
• Responsible Gaming: To monitor gaming patterns, enforce responsible gaming tools, and identify players who may be experiencing gambling-related harm.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the Platform.
• Legal Claims: To establish, exercise, or defend legal claims in connection with your use of the Platform.

6. Legal Basis for Processing

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

• Contractual Necessity: Processing necessary to perform the contract between you and jlq (i.e., the Terms & Conditions), including account management, game delivery, and payment processing.
• Legal Obligation: Processing required to comply with jlq's legal obligations under PAGCOR regulations, AMLA, the DPA, and other applicable Philippine laws.
• Legitimate Interests: Processing necessary for jlq's legitimate interests, including fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

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

• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and other payment service providers, solely to process your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification and document authentication services used to fulfil our KYC obligations under PAGCOR regulations.
• AML & Fraud Screening Providers: Compliance technology providers used to screen transactions and player activity against sanctions lists and fraud databases as required by Philippine anti-money laundering law.
• Game Content Providers: Third-party game studios and software providers whose games are hosted on the Platform. These providers may receive limited technical data necessary to deliver game content and verify game outcomes.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law or regulatory mandate.
• Professional Advisers: Legal counsel, auditors, and other professional advisers engaged by jlq, subject to confidentiality obligations.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or other lawful process.

All third-party service providers engaged by jlq are required to process personal data only on jlq's documented instructions and to implement appropriate technical and organisational security measures.

8. Cookies & Tracking Technologies

jlq uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming tool configurations, and display preferences to personalise your experience.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform to help jlq identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Marketing Cookies: Used to deliver relevant promotional content within the Platform based on your gaming activity and preferences. These are only activated where you have provided consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. A full cookie notice is available within your jlq account settings.

9. Data Security

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

• Encryption: All data transmitted between your device and jlq's servers is encrypted using 256-bit SSL/TLS technology. Sensitive data at rest is encrypted using industry-standard algorithms.
• Access Controls: Access to personal data is restricted to jlq personnel and authorised service providers who have a legitimate need to access it. All access is logged and audited.
• Multi-Factor Authentication: jlq employs OTP-based verification for account logins from new devices and for high-value transactions.
• Penetration Testing: jlq's systems undergo regular independent security assessments and penetration testing to identify and remediate vulnerabilities.
• Incident Response: jlq maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, jlq will notify the National Privacy Commission and affected players within the timeframes required by the DPA.

While jlq takes all reasonable steps to protect your data, no security system is completely impenetrable. You are responsible for maintaining the security of your jlq account credentials.

10. Data Retention

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

• Account and KYC Data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and Philippine AML law.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with AMLA requirements.
• Customer Support Records: Retained for three (3) years from the date of the interaction, or longer if the interaction relates to an unresolved dispute or legal claim.
• Marketing Consent Records: Retained for the duration of your account and for three (3) years following account closure or withdrawal of consent, whichever is later.
• Technical Logs: Retained for twelve (12) months from the date of generation, unless required for longer in connection with a security investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jlq's data disposal procedures.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jlq:

To exercise any of the above rights, please contact jlq's Data Protection Officer using the contact details in Section 15. jlq will respond to all verified requests within fifteen (15) business days. We may need to verify your identity before processing your request.

12. Children's Privacy

jlq does not knowingly collect personal data from individuals under the age of 21. If jlq discovers that personal data has been collected from a minor, the account will be immediately suspended, all associated data will be deleted, and any deposits will be returned to the source payment method. If you believe a minor has registered a jlq account, please contact our support team immediately.

13. Cross-Border Data Transfers

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

Such safeguards may include contractual data processing agreements incorporating standard data protection clauses, or transfers to countries recognised by the National Privacy Commission as providing an adequate level of data protection. jlq will not transfer your personal data to a foreign jurisdiction unless such safeguards are in place.

14. Updates to This Privacy Policy

jlq reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material, jlq will notify you via email to your registered address or via an in-platform notification prior to the changes taking effect. Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how jlq protects your personal data.

15. Contact & Data Protection Officer

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 within your jlq account dashboard

If you are not satisfied with jlq's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) through their official channels.