jlqq Privacy Policy

1 Introduction

jlqq ("jlqq," "we," "us," or "our") operates the online gaming platform accessible at jlqq.asia and takes seriously its responsibilities as a personal information controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA") and its Implementing Rules and Regulations ("IRR").

This Privacy Policy ("Policy") sets out how jlqq collects, uses, stores, protects, shares, and otherwise processes personal data obtained from individuals ("you," "Player," or "User") who access or use the jlqq Platform, including its games, account services, financial transaction features, and customer support channels.

This Policy should be read together with jlqq's Terms and Conditions and Responsible Gaming Policy, both of which form part of the agreement between jlqq and each registered player. Defined terms used in this Policy that are not separately defined herein carry the meaning ascribed to them in the Terms and Conditions.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and its IRR, jlqq is the personal information controller in respect of all personal data collected through the Platform. jlqq determines the purposes and means of processing your personal data and is accountable for compliance with applicable Philippine data privacy laws.

jlqq has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with the DPA, responding to data subject requests, and liaising with the National Privacy Commission of the Philippines ("NPC"). Contact details for the DPO are provided in Section 16 of this Policy.

3 Personal Data We Collect

jlqq collects the following categories of personal data in connection with the provision of its Services:

3.1 Identity and Contact Information

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification purposes);
• Residential address, city, province, and postal code;
• Mobile phone number (including country code +63);
• Email address;
• Government-issued identification number and document type (e.g., UMID, SSS, Passport, Driver's License, Voter's ID, PhilHealth, Postal ID).

3.2 Financial Information

• GCash mobile number and account reference;
• PayMaya account reference;
• Bank account details (account name, account number, bank name) where bank transfers are used;
• Credit or debit card details (card type, partial card number, expiry date) where card payments are used — full card numbers are not stored by jlqq;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used.

3.3 Gaming and Account Activity Data

• Account username and account ID;
• Game session history, including games played, bet amounts, win/loss outcomes, and session durations;
• Bonus and promotion participation history;
• Responsible gaming settings, including any deposit limits, session reminders, or self-exclusion records;
• Customer support interaction history, including support tickets and chat transcripts.

3.4 Technical and Device Data

• IP address and approximate geolocation derived therefrom;
• Device type, operating system, and browser type and version;
• Login timestamps and session identifiers;
• Cookies and similar tracking technologies (see Section 10).

4 How We Collect Your Data

jlqq collects personal data through the following means:

• Registration: When you create a jlqq account, you provide identity, contact, and age verification information directly through the registration form;
• KYC Verification: When you submit identity documents or answer verification questions as part of the Know Your Customer process;
• Deposits and Withdrawals: When you conduct financial transactions on the Platform, jlqq collects payment method details and transaction data;
• Platform Use: Automatically, as you use the Platform — your game activity, session data, login events, and device and browser information are recorded;
• Customer Support: When you contact jlqq support via email or chat, the content of those communications and associated account data is collected;
• Cookies and Tracking Technologies: As described in Section 10, jlqq uses cookies and similar technologies to collect technical data about your Platform usage;
• Third-Party Payment Processors: Where you use GCash, PayMaya, or bank transfer, relevant transaction references and confirmation data are shared with jlqq by the payment processor.

5 How We Use Your Personal Data

jlqq processes your personal data for the following purposes:

5.1 Account Management and Service Delivery

To create and manage your jlqq account, authenticate your identity at login, provide access to games and platform features, process deposits and withdrawals, and deliver customer support in English and Tagalog.

5.2 Legal and Regulatory Compliance

To verify your age (21+ requirement under PAGCOR regulations), conduct Know Your Customer checks, comply with anti-money laundering obligations under the Anti-Money Laundering Act of 2001 (RA 9160) and its amendments, respond to lawful requests from PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission, courts, and other competent Philippine authorities.

5.3 Security and Fraud Prevention

To detect and investigate suspicious login activity, unauthorized account access, fraudulent transactions, bonus abuse, and other security threats to the Platform and its users.

5.4 Responsible Gaming

To enforce self-exclusion requests, apply voluntary deposit limits and session controls set by you, monitor gaming patterns for indicators of problem gambling, and comply with PAGCOR responsible gaming requirements.

5.5 Platform Improvement and Analytics

To analyze aggregated, anonymized usage data for the purpose of improving platform performance, game selection, user experience, and customer support quality. Analytics used for this purpose do not identify you individually.

5.6 Communication

To send transactional communications including deposit confirmations, withdrawal notifications, account security alerts, OTP messages, and identity verification requests. Where you have provided separate marketing consent, jlqq may also send promotional communications, which you may opt out of at any time.

6 Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform the agreement between jlqq and you as set out in the Terms and Conditions — including account creation, game access, and financial transaction processing;
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AML obligations, and the Data Privacy Act itself;
• Legitimate Interests: Processing necessary for jlqq's legitimate interests in securing the Platform, preventing fraud, managing risk, and improving its services, provided those interests are not overridden by your rights;
• Consent: Where jlqq processes your data for marketing communications or any other purpose not covered by the above bases, it does so on the basis of your freely given, specific, informed, and unambiguous consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

7 Data Sharing and Disclosure

jlqq does not sell, rent, or trade your personal data to any third party for commercial purposes. jlqq may share your personal data in the following limited circumstances:

7.1 Service Providers and Processors

jlqq engages third-party service providers who process personal data on jlqq's behalf and under jlqq's instructions. These include payment processors (GCash, PayMaya, banking partners), game platform providers, identity verification services, cloud hosting providers, and customer support software vendors. All such providers are subject to data processing agreements requiring them to maintain confidentiality and appropriate security measures.

7.2 Regulatory and Law Enforcement Authorities

jlqq will disclose personal data to PAGCOR, the AMLC, the NPC, courts, and other competent Philippine government authorities where required by applicable law, court order, or legal process. jlqq will make reasonable efforts to notify you of such disclosures unless legally prohibited from doing so.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of jlqq's business or assets, personal data held by jlqq may be transferred to the acquiring or successor entity. jlqq will notify registered players of any such transfer and of any changes to the privacy practices of the successor entity that affect their personal data.

7.4 With Your Consent

jlqq may share your personal data with third parties in circumstances not described above where you have provided explicit, informed consent to such sharing in advance.

8 International Data Transfers

Some of jlqq's service providers and game platform partners operate from outside the Philippines. Where personal data is transferred outside of the Philippines, jlqq ensures that adequate safeguards are in place to protect your data in accordance with the standards of the Data Privacy Act of 2012 and the guidelines of the National Privacy Commission.

Such safeguards may include contractual data protection clauses approved by or consistent with NPC guidance, ensuring the recipient jurisdiction provides an adequate level of data protection, or other legally recognized transfer mechanisms. Where transfers are to jurisdictions without adequate protection frameworks, jlqq implements additional contractual protections to ensure equivalent standards apply.

9 Data Retention

jlqq retains your personal data for as long as is necessary to fulfill the purposes described in this Policy, to comply with legal obligations, and to resolve disputes and enforce agreements. Specific retention periods applicable to jlqq include:

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with Philippine AML obligations;
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship or the last transaction, whichever is later;
• Self-Exclusion Records: Retained indefinitely to prevent circumvention of voluntary exclusion by account re-registration;
• Support Interaction Records: Retained for two (2) years from the date of last interaction, unless a longer period is required for dispute resolution or compliance purposes.

When personal data is no longer required for any lawful purpose, jlqq will securely delete or anonymize it in a manner that prevents re-identification.

10 Cookies and Tracking Technologies

jlqq uses cookies and similar tracking technologies (such as web beacons and local storage) on the Platform. These technologies serve the following purposes:

• Strictly Necessary Cookies: Required for core Platform functionality, including maintaining your logged-in session, remembering your preferences, and securing your account. These cannot be disabled without affecting Platform functionality;
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform — including pages visited, features used, and time spent — to help jlqq improve the user experience;
• Security Cookies: Used to detect and prevent fraudulent access attempts, bot activity, and other security threats to the Platform.

jlqq does not use third-party advertising cookies or share cookie data with external advertising networks. You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will affect your ability to use certain features of the Platform, including remaining logged in across sessions.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012, as a Philippine data subject you have the following rights in respect of your personal data held by jlqq:

• Right to be Informed: The right to know what personal data jlqq holds about you and how it is used, as described in this Policy;
• Right of Access: The right to request a copy of the personal data jlqq holds about you, including the basis for collection and processing;
• Right to Correction: The right to request correction of inaccurate, incomplete, or outdated personal data in your jlqq account;
• Right to Object: The right to object to the processing of your personal data where such processing is not required by law or contract, including the right to object to marketing communications at any time;
• 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, where consent has been withdrawn, or where processing is unlawful, subject to jlqq's legal retention obligations;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format where technically feasible;
• Right to Damages: The right to seek compensation for any actual damage suffered as a result of a violation of your rights under the DPA;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission of the Philippines where you believe jlqq has processed your personal data in violation of the DPA.

To exercise any of the above rights, submit your request to jlqq's Data Protection Officer at the contact details provided in Section 16. jlqq will respond to all data subject requests within fifteen (15) working days of receipt and may request additional verification of your identity before processing a request.

12 Children's Privacy

If you are a parent or guardian and have reason to believe that a minor under your care has provided personal data to jlqq or has accessed the Platform, please contact jlqq's Data Protection Officer immediately at the address provided in Section 16. jlqq takes underage access extremely seriously and will act promptly upon notification.

13 Security Measures

jlqq implements the following technical and organizational security measures to protect your personal data against unauthorized access, loss, misuse, disclosure, alteration, and destruction:

• Encryption in Transit: All data transmitted between your device and the jlqq Platform is protected by 256-bit SSL/TLS encryption;
• Password Hashing: Passwords are stored using one-way cryptographic hashing algorithms and are never stored in plain text or retrievable by jlqq staff;
• Access Controls: Access to personal data within jlqq's systems is restricted to staff who require it to perform their job functions, and is governed by role-based access controls and audit logging;
• OTP Authentication: Account access from new or unrecognized devices requires one-time passcode verification to your registered mobile number;
• Anomaly Detection: jlqq's systems monitor login patterns for unusual geographic or device-based access attempts and trigger automated alerts and account protections;
• Vendor Security: Third-party processors engaged by jlqq are required to maintain security standards no less protective than those applied by jlqq itself.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jlqq will notify the National Privacy Commission within 72 hours of becoming aware of the breach and will notify affected data subjects as required by the DPA and NPC Circular No. 16-03.

14 Third-Party Links

The jlqq Platform may contain references or navigational links to other sections of the jlqq website. This Policy applies only to data collected and processed by jlqq through its own Platform. jlqq is not responsible for the privacy practices of third-party websites, services, or applications that are not operated by jlqq, even where a reference to them appears in jlqq communications or promotional material.

When using third-party payment services such as GCash or PayMaya to fund your jlqq account, you are also subject to the privacy policies of those third-party providers in respect of data they independently collect and process. jlqq encourages you to review the privacy policies of any third-party service providers you interact with.

15 Amendments to This Policy

jlqq reserves the right to update or revise this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, Platform features, or jlqq's data processing practices. When material changes are made, jlqq will notify registered players via the email address or mobile number on file and will update the "Last Updated" date at the top of this Policy.

Your continued use of the jlqq Platform after the effective date of a revised Privacy Policy constitutes acceptance of the revised terms. If you do not agree to the changes, you should cease using the Platform and may request account closure in accordance with the Terms and Conditions.

jlqq recommends that you periodically review this Policy to stay informed of how your personal data is protected. The current version of the Policy is always available on the Platform at jlqq.asia/privacy-policy.

16 Contact and Data Protection Officer

For all privacy-related inquiries, data subject requests, complaints, or concerns regarding this Policy or jlqq's data processing practices, please contact jlqq's Data Protection Officer:

jlqq will acknowledge all data subject requests within five (5) working days of receipt and will complete processing of the request within fifteen (15) working days, except where additional time is required due to the complexity or volume of the request, in which case jlqq will notify you of the expected completion date.

If you believe jlqq has not adequately addressed your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC is the independent regulatory body responsible for administering and enforcing the Data Privacy Act of 2012.