jlmm Privacy Policy

1. Introduction

This Privacy Policy applies to all personal data collected by jlmm in connection with your use of the jlmm website, mobile interface, and related services (collectively, the "Platform"). jlmm is committed to handling your personal data responsibly and in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its implementing rules and regulations.

As a platform serving Filipino players across Metro Manila, Cebu, Davao, and beyond, jlmm understands the importance of trust. We collect only the data we need, use it only for the purposes described in this Policy, and take reasonable steps to keep it secure.

This Policy should be read alongside jlmm's Terms & Conditions, which govern your overall use of the Platform.

2. Data We Collect

jlmm collects the following categories of personal data from users of the Platform:

Identity Data:

• Full legal name
• Date of birth
• Government-issued identification number (e.g., Philippine passport number, SSS number, PhilSys national ID number, driver's license number)
• Nationality
• Profile photograph (where submitted for KYC purposes)

Contact Data:

• Email address
• Mobile phone number
• Residential address (including barangay, city/municipality, province)

Financial Data:

• GCash or PayMaya account details (mobile number associated with the account)
• Bank account details (bank name, account number) for withdrawal processing
• Debit card details (card number, expiry date) where applicable
• Transaction history on the jlmm Platform

Technical Data:

• IP address
• Browser type and version
• Device type and operating system
• Time zone and language settings
• Pages visited and features used on the Platform
• Session duration and login timestamps

Gaming Data:

• Game history, wager amounts, and outcomes
• Bonus and promotion usage
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion status)

Communications Data:

• Records of your communications with jlmm customer support
• Feedback and survey responses

3. How We Collect Data

jlmm collects personal data through the following means:

• Direct interactions: Data you provide when registering your jlmm account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the Platform, including through cookies, web beacons, and server logs. See Section 7 (Cookies & Tracking) for more detail.
• Third parties: Data received from payment processors (e.g., GCash, PayMaya, banks) in connection with financial transactions, and from identity verification service providers used for KYC compliance.

4. How We Use Your Data

jlmm uses the personal data we collect for the following purposes:

• Account management: To register and maintain your jlmm account, verify your identity, and manage your account settings.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the core features of the jlmm Platform.
• Regulatory compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, KYC requirements, and PAGCOR-related compliance obligations.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, session timers, and self-exclusion.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Customer support: To respond to your inquiries, 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 analyze usage patterns and improve the performance, features, and user experience of the jlmm Platform.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you (i.e., to provide the jlmm Platform services as described in the Terms & Conditions).
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML, KYC, and gaming regulatory requirements.
• Legitimate interests: Processing for fraud prevention, security, and platform improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing

jlmm does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, and banking partners, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers used to verify your identity in compliance with regulatory requirements.
• Game providers: Software providers whose games are available on the jlmm Platform, to the extent necessary to deliver game services.
• Regulatory authorities: PAGCOR and other Philippine government agencies, where disclosure is required by law or regulatory obligation.
• Law enforcement: Where required by a valid court order, subpoena, or other legal process.
• Service providers: IT infrastructure, hosting, analytics, and customer support providers engaged by jlmm under appropriate data processing agreements.

All third parties with whom jlmm shares personal data are required to handle such data in accordance with applicable data protection laws and jlmm's data security standards.

7. Cookies & Tracking

jlmm uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device when you visit the jlmm website. We use the following types of cookies:

• Essential cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Analytics cookies: Used to collect anonymized data about how users interact with the Platform, helping us improve performance and user experience.
• Preference cookies: Used to remember your settings and preferences (e.g., language, display settings) across sessions.
• Marketing cookies: Used to deliver relevant promotional content where you have consented to receive marketing communications.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the jlmm Platform.

8. Data Retention

jlmm retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the duration of your account registration and for a period thereafter as required by applicable law. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing consent records are retained until you withdraw consent and for a reasonable period thereafter as evidence of consent.

When personal data is no longer required, jlmm will securely delete or anonymize it in accordance with our data retention procedures.

9. Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the jlmm Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of the jlmm Platform.
• Incident response procedures for detecting and responding to data security breaches.

While jlmm takes data security seriously, no system is completely immune to security risks. In the event of a data breach that is likely to result in a risk to your rights and freedoms, jlmm will notify you and the National Privacy Commission (NPC) of the Philippines in accordance with applicable law.

10. Your Rights

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

• Right to be informed: The right to be informed about how your personal data is collected and processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data jlmm holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another data controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact jlmm's Data Protection Officer at the email address provided in Section 14. We will respond to your request within thirty (30) days in accordance with applicable law. We may need to verify your identity before processing your request.

11. Children's Privacy

The jlmm Platform is strictly intended for individuals who are at least 21 years of age, in accordance with the minimum legal age for casino-style gambling in the Philippines. jlmm does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete the data, and report the matter to the appropriate authorities where required.

If you are a parent or guardian and believe that a minor has registered on the jlmm Platform, please contact us immediately at the details provided in Section 14.

12. Third-Party Links

The jlmm Platform may contain links to third-party websites or services for informational purposes. jlmm is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to data collected by jlmm through the jlmm Platform.

13. Policy Updates

jlmm reserves the right to update or modify this Privacy Policy at any time. The most current version will always be available on the jlmm website at jlmm.club/privacy-policy, with the "Last Updated" date revised accordingly. Where changes are material, jlmm will endeavor to notify registered players via email or in-platform notification prior to the changes taking effect.

Your continued use of the jlmm Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the updated Policy, you must stop using the Platform and may request account closure by contacting our support team.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by jlmm, please contact our Data Protection Officer:

Data Protection Officer, jlmm
Email: [email protected]

For general support inquiries, you may also reach our customer support team at: [email protected]

We aim to respond to all data privacy inquiries within thirty (30) days of receipt. Please include your registered account username and a clear description of your request to help us assist you efficiently.