Privacy Policy — jlibet

jlibet ("jlibet," "we," "our," "us") is the data controller responsible for personal data collected through jlibet.club and associated services. As data controller, jlibet determines the purposes and means of processing your personal data. Our Data Protection Officer (DPO) is responsible for overseeing jlibet's compliance with the Philippine Data Privacy Act of 2012 (RA 10173) and its implementing rules and regulations, as well as PAGCOR's applicable data governance standards.

By creating an account with jlibet, using any of our services, or accessing jlibet.club, 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 to this Privacy Policy, you must cease use of jlibet immediately.

When you register a jlibet account, we collect: full legal name; date of birth; Philippine mobile number; email address (where provided); residential address; and government-issued identification document details (e.g., Philippine passport number, driver's license number, PhilSys national ID number, SSS ID). This data is required to create your account and fulfill our KYC obligations under PAGCOR regulations.

jlibet collects financial information necessary to process deposits and withdrawals, including: GCash account identifiers; Maya account identifiers; bank account numbers (BPI, BDO, Metrobank, or other linked banks); transaction history; deposit and withdrawal amounts; and source of funds documentation as may be requested for AML compliance. jlibet does not store full payment card numbers and does not process credit or debit card payments directly.

jlibet collects comprehensive records of your gaming activity, including: wagers placed; game titles and outcomes; session durations; win and loss histories; bonus usage; and responsible gaming tool activations (e.g., deposit limits set, self-exclusion requests). This data is used for account management, dispute resolution, regulatory reporting, and responsible gaming monitoring.

jlibet automatically collects technical data when you access our platform, including: IP address; device type, model, and operating system; browser type and version; network carrier (Globe, Smart, DITO, or other); approximate geographic location derived from IP address; session timestamps; and pages or game screens accessed. This data is used for security, fraud prevention, and platform optimization.

Where you contact jlibet's customer support — via live chat, email, or any other channel — jlibet retains records of those communications, including the content of your messages, timestamps, and resolution outcomes. These records are used to manage support requests and maintain service quality.

jlibet collects personal data through the following means:

• Direct submission: Information you actively provide during registration, KYC verification, deposit and withdrawal requests, or support interactions;
• Automated collection: Technical data collected automatically when you access jlibet.club, including through cookies, web beacons, and server logs (see Section 7);
• Payment processors: Transaction confirmation data received from GCash, Maya, InstaPay, PesoNet, and other payment service providers when you make deposits or withdrawals;
• Third-party verification services: Identity and document verification data from KYC service providers used to authenticate government-issued identification;
• Regulatory bodies: Information received from PAGCOR or other Philippine government agencies in the course of regulatory compliance activities.

jlibet processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your jlibet account;
• Service delivery: Enabling access to games, processing deposits and withdrawals, and delivering bonuses and promotions;
• Identity verification (KYC): Verifying your identity and age in compliance with PAGCOR requirements and Philippine anti-money laundering laws;
• Regulatory compliance: Meeting obligations under PAGCOR's online gaming license conditions, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act (RA 10173);
• Fraud and security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and money laundering;
• Responsible gaming: Monitoring gaming behaviour to identify potential problem gambling, enforcing self-exclusion requests, and administering responsible gaming tools;
• Customer support: Responding to your enquiries, resolving disputes, and managing account-related requests;
• Communications: Sending account notifications, transaction confirmations, and — where you have consented — promotional communications about jlibet offers;
• Platform improvement: Analysing aggregate usage data to improve jlibet's product, games, and user experience.

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

• Consent: Where you have given explicit consent for specific processing activities, such as receiving promotional communications;
• Contractual necessity: Where processing is required to fulfill the agreement between you and jlibet (the Terms and Conditions), including account management and payment processing;
• Legal obligation: Where processing is required to comply with applicable Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act;
• Legitimate interests: Where processing is necessary for jlibet's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided those interests are not overridden by your privacy rights.

jlibet is required to share personal data with PAGCOR and other Philippine government agencies (including the Anti-Money Laundering Council, the National Privacy Commission, and law enforcement) where required by law or pursuant to a valid lawful order. jlibet cannot withhold data from authorized Philippine regulatory bodies.

jlibet shares personal data with carefully selected third-party service providers who process data on our behalf, including: payment processing partners (GCash, Maya, and banking partners); KYC and identity verification providers; fraud detection and security service providers; cloud infrastructure and hosting providers; and customer support platform providers. All service providers are bound by data processing agreements that restrict their use of your data to the purposes specified by jlibet.

jlibet shares limited technical and gameplay data with game content providers (such as JILI Gaming) as necessary to deliver game services. Game providers receive only the data required to operate the specific game and are not permitted to use such data for independent marketing or profiling purposes.

jlibet does not sell, rent, or trade your personal data to any third party for their independent marketing or commercial purposes. We do not share your personal data with third-party advertisers or data brokers.

jlibet uses cookies and similar tracking technologies on jlibet.club to operate the platform and enhance your experience. The types of cookies we use include:

• Strictly necessary cookies: Required for core platform functionality including login session management, security token verification, and payment flow continuity. These cannot be disabled without impairing the platform's operation;
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations;
• Analytics cookies: Collect aggregate, anonymized data about how users interact with jlibet.club to help us improve the platform. No personally identifying information is included in analytics data;
• Security cookies: Used to detect fraudulent activity, identify unusual login patterns, and protect your account.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to log in and use jlibet. jlibet does not use third-party advertising cookies or share cookie data with marketing networks.

jlibet retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC data: Retained for a minimum of five (5) years after account closure, as required by PAGCOR's record-keeping requirements and Philippine AML regulations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act (RA 9160 as amended);
• Gaming activity data: Retained for a minimum of three (3) years after account closure for dispute resolution and regulatory reporting purposes;
• Customer support records: Retained for two (2) years from the date of the last interaction;
• Technical and device data: Retained for up to twelve (12) months from collection for security and fraud investigation purposes.

Data may be retained beyond these periods where required by law, ongoing regulatory inquiry, or active dispute proceedings.

jlibet implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jlibet's servers;
• Encryption of sensitive data at rest, including passwords (hashed using industry-standard algorithms) and financial identifiers;
• Two-factor authentication (2FA) available for all player accounts;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of jlibet's platform infrastructure;
• Incident response procedures and data breach notification protocols in compliance with the NPC's Circular on Personal Data Breach Management.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, jlibet will notify the National Privacy Commission and affected data subjects within the timeframes required by Philippine law.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by jlibet:

• Right to be informed: The right to know what personal data jlibet collects and how it is processed — which this Privacy Policy fulfills;
• Right to access: The right to request a copy of the personal data jlibet holds about you;
• Right to rectification: The right to request correction of inaccurate or outdated personal data;
• Right to erasure/blocking: The right to request deletion or blocking of personal data that is no longer necessary, was unlawfully processed, or where consent has been withdrawn — subject to jlibet's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing or other purposes based on legitimate interest;
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to damages: The right to claim compensation for damages sustained due to inaccurate, incomplete, outdated, false, or unlawfully obtained personal data.

To exercise any of these rights, please contact jlibet's Data Protection Officer at the details provided in Section 14. jlibet will respond to verified requests within fifteen (15) business days. Identity verification will be required before jlibet can fulfill data access, rectification, or erasure requests.

jlibet's services are strictly restricted to individuals aged 21 years and above, in compliance with PAGCOR's online gaming age requirements. jlibet does not knowingly collect personal data from individuals under 21 years of age. Account registration requires age declaration and is subject to KYC verification — any account found to belong to a person under 21 years will be immediately closed and all personal data associated with that account will be deleted, except where retention is required by law.

If you believe that jlibet has inadvertently collected personal data from a person under 21 years of age, please notify our Data Protection Officer immediately at the contact details in Section 14.

jlibet may transfer your personal data to countries outside the Philippines where our service providers or game content partners are located. Such transfers are only undertaken where the recipient country provides an adequate level of data protection, or where appropriate safeguards are in place (such as data processing agreements incorporating standard contractual clauses approved by the National Privacy Commission).

Where personal data is transferred internationally, jlibet ensures that the recipient is bound by obligations equivalent to those under RA 10173, and that your privacy rights remain protected. jlibet does not transfer personal data to jurisdictions that do not provide adequate data protection without implementing appropriate contractual safeguards.

jlibet reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR's regulatory requirements. Material changes to this Privacy Policy will be communicated to registered players via the mobile number or email address on file, or through a prominent notice on jlibet.club, at least seven (7) days prior to the effective date.

The date of the most recent update to this Privacy Policy is displayed at the top of this page. Your continued use of jlibet following the effective date of any update constitutes your acknowledgment and acceptance of the revised policy. If you do not accept the updated Privacy Policy, you must cease use of jlibet and may request account closure in accordance with our Terms and Conditions.

For any queries, complaints, or requests relating to this Privacy Policy or your personal data rights, please contact jlibet's Data Protection Officer:

• Data Protection Officer: jlibet Data Privacy Team
• Email: [email protected]
• Response time: jlibet aims to acknowledge all data privacy requests within five (5) business days and provide a full response within fifteen (15) business days

If you are not satisfied with jlibet's response to a data privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.