jl 16 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how jl 16 ("jl 16," "we," "us," "our") collects, processes, stores, and protects the personal information of users ("you," "Player") who access or use the jl 16 website, mobile platform, and related services (collectively, the "Platform").

jl 16 is committed to protecting the privacy and personal data of all Filipino players in accordance with the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). By registering an account or using the jl 16 Platform, you consent to the collection and processing of your personal data as described in this Policy.

This Policy should be read alongside the jl 16 Terms & Conditions and Responsible Gaming Policy, which together govern your use of the Platform.

2. Personal Data We Collect

jl 16 collects personal data through several channels — directly from you during registration and account use, automatically through your interaction with the Platform, and from third-party service providers where necessary for compliance and payment processing.

jl 16 does not collect sensitive personal information (as defined under RA 10173) beyond what is strictly required for identity verification and regulatory compliance purposes.

3. How We Use Your Personal Data

jl 16 uses your personal data only for legitimate, specified purposes. We do not process your data in ways that are incompatible with the purposes for which it was collected. The primary purposes for which jl 16 processes your personal data include:

• Account Management: To create, verify, maintain, and secure your jl 16 account, including identity verification (KYC) and age verification (21+ compliance).
• Service Delivery: To provide access to jl 16 games, sports betting, live casino, bingo, slots, and all other Platform features.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Regulatory Compliance: To fulfil our obligations under Philippine gaming regulations, anti-money laundering (AML) laws, and PAGCOR-related compliance requirements.
• Responsible Gaming: To monitor gaming behaviour, enforce deposit limits, process self-exclusion requests, and identify players who may need support.
• Customer Support: To respond to your enquiries, resolve disputes, and improve the quality of our support services.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and abuse of the Platform.
• Platform Improvement: To analyse usage patterns and improve the jl 16 user experience, game offerings, and technical performance.
• Marketing Communications: To send you promotional offers, bonus notifications, and updates about jl 16 — only where you have provided consent or where permitted by applicable law. You may opt out at any time.

4. Legal Basis for Processing

jl 16 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 a specific processing purpose, such as receiving marketing communications.
• Contractual Necessity: Where processing is necessary to perform our obligations under the jl 16 Terms & Conditions, including account management and payment processing.
• Legal Obligation: Where processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR requirements, and the Data Privacy Act.
• Legitimate Interests: Where processing is necessary for jl 16's legitimate business interests — such as fraud prevention, platform security, and service improvement — provided those interests are not overridden by your rights and freedoms.

5. Data Sharing & Disclosure

jl 16 does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your personal data only in the following limited circumstances:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers receive the minimum data necessary to process your transactions securely.
• Identity Verification Providers: Third-party KYC and age verification services may receive identity documents to fulfil our regulatory obligations.
• Game Software Providers: Licensed game providers may receive anonymised or pseudonymised gaming data necessary to deliver their games on the jl 16 Platform.
• Regulatory Authorities: jl 16 may disclose personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other Philippine government authorities where required by law or court order.
• Professional Advisers: Legal, accounting, and auditing firms engaged by jl 16 may access personal data on a strictly confidential, need-to-know basis.

6. Cookies & Tracking Technologies

jl 16 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data that helps us improve our services. A cookie is a small text file stored on your device when you visit the jl 16 Platform.

The types of cookies jl 16 uses include:

• Essential Cookies: Required for the Platform to function correctly. These include session authentication tokens, security cookies, and load-balancing cookies. You cannot opt out of essential cookies without affecting Platform functionality.
• Analytics Cookies: Used to collect anonymised data about how players interact with the jl 16 Platform — such as pages visited, time spent, and navigation paths — to help us improve the user experience.
• Preference Cookies: Store your Platform preferences, such as language settings and display options, so you do not need to re-enter them on each visit.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of jl 16 marketing campaigns. These are only set where you have provided consent.

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the jl 16 Platform. For full details on how to manage cookies, refer to your browser's help documentation.

7. Data Retention

jl 16 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. The following general retention periods apply:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with AML and gaming regulatory requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act of 2001 (RA 9160) and its amendments.
• KYC Documents: Retained for the duration of your account and for five (5) years after account closure or the completion of the relevant transaction.
• Support Communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

When personal data is no longer required, jl 16 will securely delete or anonymise it in accordance with NPC-approved data disposal procedures.

8. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl 16:

• Right to Be Informed: You have the right to know what personal data jl 16 collects about you and how it is processed — which is the primary purpose of this Privacy Policy.
• Right to Access: You may request a copy of the personal data jl 16 holds about you at any time by contacting our Data Protection Officer.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where your rights override those interests.
• Right to Data Portability: You may request that jl 16 provide your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: If you believe jl 16 has not handled your personal data in accordance with the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

9. Data Security

jl 16 implements robust technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes:

• Encryption: All data transmitted between your device and the jl 16 Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorised jl 16 personnel on a strict need-to-know basis. All staff with access to personal data undergo regular data privacy training.
• Two-Factor Authentication: jl 16 supports two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorised access.
• Regular Security Audits: jl 16 conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities in the Platform.
• Incident Response: In the event of a personal data breach, jl 16 will notify affected players and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

While jl 16 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying jl 16 immediately if you suspect any unauthorised access to your account.

10. Children's Privacy

The jl 16 Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming regulations. jl 16 does not knowingly collect personal data from individuals under the age of 21.

If jl 16 becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and return any deposited funds in accordance with applicable regulations.

If you are a parent or guardian and believe that a minor has registered with jl 16, please contact us immediately at [email protected] so that we can take prompt action.

11. Changes to This Privacy Policy

jl 16 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. When material changes are made, we will:

• Post the updated Policy on this page with a revised "Last Updated" date.
• Send a notification to your registered email address where practicable.
• Display a prominent notice on the jl 16 Platform upon your next login.

Your continued use of the jl 16 Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how jl 16 protects your personal data.

12. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way jl 16 handles your personal data, please contact our designated Data Protection Officer:

• Email: [email protected]
• Response Time: We aim to acknowledge all privacy-related enquiries within two (2) business days and resolve them within fifteen (15) business days.
• NPC Complaints: If you are not satisfied with our response, you may escalate your complaint to the National Privacy Commission of the Philippines.

For responsible gaming concerns, self-exclusion requests, or deposit limit adjustments, please visit our Responsible Gaming page.