Contents
- 1. Introduction
- 2. Who We Are
- 3. Data We Collect
- 4. How We Collect It
- 5. Why We Use Your Data
- 6. Legal Basis
- 7. Sharing Your Data
- 8. Data Security
- 9. Data Retention
- 10. Cookies
- 11. Your Rights
- 12. Children's Privacy
- 13. Third-Party Links
- 14. Policy Changes
- 15. Contact Our DPO
01 Introduction
Welcome to jlll1. We operate the online gaming platform at jlll1.best, designed specifically for players in the Philippines. We understand that when you create an account with us, you're trusting us with personal information — and that's not something we take lightly.
This Privacy Policy sets out exactly what data jlll1 collects from members and visitors, the reasons we collect it, how long we keep it, who we may share it with, and what controls you have over your own information. It is written in plain English so that every Filipino player can understand it — not just lawyers.
This policy applies to all personal data processed by jlll1 in connection with your use of jlll1.best, including account registration, transactions, gameplay, communications, and marketing where you have given consent. It should be read alongside the jlll1 Terms and Conditions.
Plain language summary: We collect what we need to run your account safely. We don't sell your data. You can ask us to access, correct, or delete your information at any time. If you have questions, our Data Protection Officer is available — see Section 15.
02 Who We Are
jlll1 operates jlll1.best, an online gaming platform serving players in the Philippines. For the purposes of the Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations, jlll1 is the Personal Information Controller responsible for the personal data you provide when using our platform.
Our designated Data Protection Officer (DPO) can be contacted directly for any privacy-related queries. Contact details are provided in Section 15 of this policy.
03 Personal Data We Collect
jlll1 collects only the personal data necessary to provide our services, comply with legal obligations, and protect the safety of all members. Below is a full breakdown of the data categories we may hold about you.
| Data Category | Specific Data Points | Required? |
|---|---|---|
| Identity Data | Full legal name, date of birth, government ID type and number | Yes |
| Contact Data | Mobile number, email address, residential address | Yes |
| Account Data | Username, hashed password, account preferences, notification settings | Yes |
| Financial Data | Payment method type, last 4 digits of card/account, transaction history | Yes |
| Verification Data | Government ID image, selfie with ID (for KYC) | Yes (for withdrawal) |
| Usage Data | IP address, device type, browser, session duration, pages visited, games played | Automatic |
| Communications Data | Support chat transcripts, email correspondence, feedback submitted | When submitted |
| Marketing Data | Communication preferences, promotional opt-in/opt-out status | Optional |
jlll1 does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health records, or biometric data beyond what is strictly required for identity verification under applicable regulations.
04 How We Collect Your Data
jlll1 collects personal data through the following channels:
Directly from You
- When you register an account on jlll1
- When you complete KYC (Know Your Customer) verification
- When you make a deposit or request a withdrawal
- When you contact our customer support team
- When you complete any form, survey, or promotion entry on jlll1
- When you update your account preferences or communication settings
Automatically
When you visit and interact with jlll1.best, certain technical data is collected automatically by our servers and analytics systems. This includes your IP address, device and browser information, session timestamps, and the pages or games you accessed. This data is used for platform security, fraud prevention, and improving the user experience.
From Third Parties
In some cases, jlll1 may receive data about you from third-party sources, including:
- Payment processors (GCash, Maya, your bank) confirming transaction details
- Identity verification service providers used for KYC checks
- Fraud detection and anti-money-laundering compliance services
jlll1 only receives data from these third parties to the extent necessary to fulfil our legal obligations and protect our platform from financial crime.
05 Why We Use Your Personal Data
jlll1 processes your personal data for specific, legitimate purposes. We do not use your data for any purpose not listed below without first obtaining your explicit consent.
- Account management — To create and maintain your jlll1 account, including authentication and security
- Transaction processing — To handle deposits, withdrawals, and maintain an accurate transaction record in PHP
- Identity and age verification — To confirm you meet the minimum age requirement (21 years) and comply with KYC regulations
- Fraud and security monitoring — To detect and prevent unauthorised access, bonus abuse, money laundering, and other prohibited activities
- Regulatory compliance — To meet obligations under Philippine law, including the Anti-Money Laundering Act and Data Privacy Act
- Customer support — To handle your queries, complaints, and service requests
- Platform improvement — To analyse usage patterns and improve jlll1's features and performance
- Responsible gaming — To monitor for signs of problem gambling and apply account controls where appropriate
- Marketing (with consent) — To send you promotions, offers, and news about jlll1 where you have opted in
06 Legal Basis for Processing
Under the Data Privacy Act of 2012 (RA 10173), jlll1 processes your personal data based on the following legal grounds:
- Contractual necessity — Processing required to fulfil our agreement with you (your jlll1 account and the services you use)
- Legal obligation — Processing required to comply with Philippine law, including anti-money-laundering, tax, and gaming regulations
- Legitimate interest — Processing for fraud prevention, platform security, and improving our services, where those interests are not overridden by your rights
- Consent — Processing for optional purposes such as marketing communications, where we have obtained your explicit opt-in
Where we rely on consent, you have the right to withdraw that consent at any time — see Section 11 for details on how to do so.
07 Sharing Your Personal Data
jlll1 does not sell, rent, or trade your personal data to any third party. We share your data only in the limited circumstances described below, and always under conditions that protect your privacy.
Service Providers
jlll1 uses a small number of trusted service providers to help operate our platform. These include payment processors, KYC verification providers, cloud hosting providers, and fraud detection services. These providers access your data only to perform specific functions on our behalf and are contractually required to keep it secure and confidential.
Legal and Regulatory Authorities
jlll1 may disclose personal data to Philippine government agencies, law enforcement, or regulatory bodies where required by law or in response to a valid legal order. This includes compliance with the Anti-Money Laundering Council (AMLC) reporting requirements.
Business Transfers
In the event that jlll1 undergoes a merger, acquisition, or sale of assets, member data may be transferred as part of that transaction. You will be notified in advance if this occurs and a new privacy policy will be issued by the acquiring entity.
Important: When jlll1 shares data with service providers, we require them to sign data processing agreements that bind them to the same privacy standards we uphold. They cannot use your data for their own purposes.
08 How We Protect Your Data
jlll1 takes the security of your personal data seriously. We implement a combination of technical, organisational, and physical safeguards designed to protect your information against unauthorised access, disclosure, alteration, or destruction.
- Encryption in transit — All data transmitted between your device and jlll1.best is protected by TLS (HTTPS). We do not operate over unencrypted connections.
- Encryption at rest — Sensitive data stored in our systems — including passwords and ID document images — is encrypted at the storage layer.
- Access controls — jlll1 staff access to member data is governed by role-based access controls. Only authorised personnel handling specific functions have access to relevant data.
- Regular security assessments — Our platform and infrastructure undergo regular penetration testing and vulnerability assessments.
- Incident response — We have a data breach response procedure in place. If a breach occurs that poses a risk to your rights, jlll1 will notify you and the National Privacy Commission (NPC) within the timeframes prescribed by RA 10173.
While we implement robust security measures, no online system is completely immune to threats. We encourage all jlll1 members to use strong, unique passwords and to enable two-factor authentication on their accounts where available.
09 Data Retention
jlll1 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Our retention periods are as follows:
- Active account data — Retained for the lifetime of your jlll1 account plus 5 years after account closure, to comply with financial record-keeping obligations
- Transaction records — Retained for a minimum of 5 years after each transaction in accordance with anti-money-laundering regulations
- KYC / identity documents — Retained for the duration of account activity plus 5 years
- Support communications — Retained for 2 years from the date of the last interaction
- Usage and technical data — Typically retained for 12 months in identifiable form; anonymised data may be retained longer for analytics
- Marketing consent records — Retained until you withdraw consent or your account is closed
When data is no longer required, jlll1 deletes it securely or anonymises it so it can no longer be associated with any individual.
10 Cookies and Tracking Technologies
jlll1 uses cookies and similar technologies on jlll1.best to make the platform function correctly and to improve your experience. A cookie is a small data file stored on your device when you visit a website.
Types of Cookies We Use
- Essential cookies — Required for the platform to function. These handle authentication, session management, and security features. You cannot opt out of these without stopping your use of jlll1.
- Functional cookies — Remember your preferences such as language settings, preferred game categories, and notification choices.
- Analytics cookies — Help us understand how members use jlll1 — which pages they visit, how long they stay, and where they encounter problems. This data is aggregated and used to improve the platform.
- Security cookies — Support fraud detection by identifying unusual patterns in browser and session behaviour.
You can manage non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of your jlll1 account.
jlll1 does not use third-party advertising cookies or share cookie data with external advertising networks. Your browsing data on our platform stays with us.
11 Your Rights as a Data Subject
Under the Data Privacy Act of 2012 (RA 10173), you have specific rights regarding your personal data held by jlll1. These rights are summarised below. To exercise any of them, contact our Data Protection Officer using the details in Section 15.
Right to Access
Request a copy of the personal data jlll1 holds about you, along with information on how it is used and where it was sourced.
Right to Correction
Request correction of any inaccurate or incomplete personal data held by jlll1. You can update most basic data directly from your account dashboard.
Right to Erasure
Request deletion of your personal data in certain circumstances — for example, where it is no longer necessary for the purpose it was collected, and no legal obligation requires us to keep it.
Right to Object
Object to the processing of your personal data for direct marketing purposes. You can also object to processing based on legitimate interest, though this right may be limited in some cases.
Right to Portability
Request your personal data in a structured, commonly used, machine-readable format so you can transfer it to another service if you choose.
Right to Complain
Lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jlll1 has violated your data privacy rights.
jlll1 will respond to data subject requests within 15 business days of receipt. Complex requests may take longer — we will notify you if that is the case. We may need to verify your identity before processing any request to ensure we disclose or modify data only to the authorised account holder.
12 Children's Privacy
jlll1 is a real-money gaming platform intended for adults aged 21 and above. We do not knowingly collect personal data from anyone under the age of 21. Our registration process includes an age declaration and age verification step to enforce this requirement.
If jlll1 becomes aware that personal data has been collected from a person under 21, we will delete that data promptly and close the associated account. If you have reason to believe a minor has registered on jlll1, please contact us immediately via the details in Section 15.
13 Third-Party Links
jlll1.best may contain links to pages or services operated by third parties. This Privacy Policy applies only to data processed by jlll1 in connection with our platform. We are not responsible for the privacy practices of any external websites or services you may visit through links on jlll1.
We recommend reviewing the privacy policy of any third-party service you use independently from jlll1, including payment providers like GCash and Maya, whose privacy practices are governed by their own policies.
14 Changes to This Privacy Policy
jlll1 may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or platform features. When we make material changes, we will notify you via the email address registered on your account and post a prominent notice on jlll1.best at least 14 days before the changes take effect.
Your continued use of jlll1 after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. The date at the top of this document always reflects the most recent revision. Previous versions are available on request by contacting our DPO.
15 Contact Our Data Protection Officer
If you have any questions about this Privacy Policy, want to exercise your data subject rights, or have a concern about how jlll1 handles your personal data, please contact our Data Protection Officer:
Email: privacy@jlll1.best
General support: support@jlll1.best
Live chat: Available in your jlll1 account dashboard 24/7
Help centre: jlll1.best/faq
We aim to acknowledge all privacy enquiries within 2 business days and resolve them fully within 15 business days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC).