jll8 Privacy Policy

1Overview and Data Controller

jll8 is the operator of the online gaming platform accessible at jll8.app and acts as the Personal Information Controller (as defined under the Philippine Data Privacy Act of 2012) in respect of personal data collected from players and visitors of the Platform.

As Personal Information Controller, jll8 determines the purposes and means of processing your personal data. jll8 is registered with and subject to oversight by the National Privacy Commission (NPC) of the Philippines. jll8 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and with the DPA 2012. Contact details for the DPO are set out in Section 14 of this Policy.

This Policy governs personal data collected: (i) when you visit the jll8 website or use the jll8 mobile application; (ii) when you register a jll8 account; (iii) when you make deposits or withdrawals; (iv) when you participate in games, promotions, or the loyalty program; (v) when you contact jll8 customer support; and (vi) through cookies and similar tracking technologies as described in Section 8.

2Personal Data We Collect

jll8 collects personal data in the following categories:

3How jll8 Uses Your Personal Data

jll8 uses your personal data for the following specific purposes:

3.1 Account Registration and Management

To create, maintain, verify, and manage your jll8 account — including processing your registration, verifying your identity and age (21+), and enabling account login and security features such as two-factor authentication.

3.2 Provision of Gaming Services

To provide access to jll8's full platform including slots, bingo, crash games, Go Rush, live casino tables, and the sportsbook. Gameplay data is used to process bets, calculate winnings, credit bonuses, and maintain your game history.

3.3 Payment Processing

To process deposits via GCash, Maya, BPI, BDO, Metrobank, and other accepted Philippine payment methods; to verify payment ownership; to process withdrawal requests; and to maintain financial transaction records as required by applicable law.

3.4 Legal and Regulatory Compliance

To comply with applicable Philippine laws including the DPA 2012, PAGCOR regulatory requirements, Anti-Money Laundering Act (AMLA) obligations, and any orders or requests from competent Philippine government authorities including the NPC, PAGCOR, and AMLC.

3.5 Responsible Gaming and Player Protection

To monitor gameplay patterns for signs of problem gambling; to enforce deposit limits, session timers, and self-exclusion settings chosen by the Player; to comply with self-exclusion registries where applicable; and to enforce the 21+ age requirement.

3.6 Fraud Prevention and Security

To detect, investigate, and prevent fraudulent transactions, bonus abuse, account manipulation, money laundering, and other prohibited activities; to monitor login sessions for unusual patterns; and to maintain the security and integrity of the jll8 platform.

3.7 Customer Support

To respond to your enquiries, complaints, and support requests via live chat, email, and other support channels; to maintain records of communications for quality assurance and dispute resolution.

3.8 Marketing and Promotions

With your consent, to send you promotional offers, bonus notifications, and information about new games or features via email, SMS, or in-app notifications. You may withdraw marketing consent at any time through your account settings or by contacting support.

3.9 Platform Improvement and Analytics

To analyze aggregated, anonymized usage data for the purpose of improving Platform performance, game selection, user experience, and product development. This analysis does not involve profiling of individual players for automated decision-making purposes.

4Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, jll8 processes your personal data on the following legal grounds:

• Contract: Processing is necessary for the performance of the contract between you and jll8 — specifically, to provide the online gaming services you have registered to use, to process financial transactions, and to manage your account.
• Legal Obligation: Processing is necessary for jll8 to comply with its legal obligations under the DPA 2012, PAGCOR regulations, AMLA, and other applicable Philippine laws.
• Legitimate Interests: Processing is necessary for jll8's legitimate interests in fraud prevention, security monitoring, platform integrity, responsible gaming enforcement, and business analytics — provided these interests are not overridden by your fundamental rights.
• Consent: Where processing is based on your consent — including consent to receive marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing that took place before withdrawal.

5Disclosure and Sharing of Personal Data

jll8 does not sell, rent, or commercially license your personal data to third parties. jll8 may disclose your personal data only in the following limited circumstances:

5.1 Service Providers (Personal Information Processors)

jll8 engages trusted third-party service providers who act as Personal Information Processors under data processing agreements that bind them to data protection standards consistent with the DPA 2012. These providers assist with:

• Payment processing: GCash, Maya, bank partners, and other Philippine payment gateway operators;
• Identity verification: KYC and document verification service providers;
• Game software: licensed third-party game providers whose titles appear in the jll8 Platform;
• Customer support infrastructure: live chat and ticketing system providers;
• Fraud prevention and cybersecurity: security monitoring and threat detection vendors;
• Email and SMS communications platforms for transactional and promotional messages.

Service providers are permitted to access personal data only to the extent required to perform their specific functions and may not use it for any other purpose.

5.2 Legal and Regulatory Authorities

jll8 will disclose personal data to competent Philippine government authorities, including PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and law enforcement agencies, where required to do so by applicable law, court order, or legitimate regulatory request.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of jll8's assets, personal data held by jll8 may be transferred to the acquiring entity as part of the transaction, subject to appropriate data protection safeguards and notification to affected players where required by law.

6Data Retention

jll8 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents re-identification.

7Security Measures

jll8 implements organizational, technical, and physical security measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction, consistent with the security standards required by the DPA 2012 and its Implementing Rules and Regulations.

7.1 Technical Measures

• 256-bit TLS/SSL encryption for all data transmitted between your device and jll8's servers;
• Encryption of sensitive data fields (including financial and identity data) at rest in jll8's databases;
• Multi-factor authentication available for all player accounts;
• Automated session expiry and concurrent session controls;
• Regular penetration testing and vulnerability assessments by qualified security professionals;
• Intrusion detection and real-time security monitoring systems.

7.2 Organizational Measures

• Access to personal data is restricted on a strict need-to-know basis among jll8 personnel;
• All jll8 staff who handle personal data are trained on data protection obligations under the DPA 2012;
• Third-party service providers are required to adhere to jll8's data security standards under contractual data processing agreements;
• jll8 maintains a documented Personal Data Breach Response Plan in accordance with NPC requirements.

8Cookies and Similar Technologies

jll8 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file stored on your device that helps jll8 recognize your browser, maintain session state, and understand how the Platform is being used.

8.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the operation of the Platform — including maintaining your login session, processing transactions, and enabling security features. These cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies: Enable enhanced functionality such as remembering your language preference, interface settings, and last game played. Disabling these may reduce your experience but will not prevent access.
• Analytics Cookies: Used to collect aggregated, anonymized information about how visitors use the Platform — including page visit counts, session durations, and navigation paths. This data helps jll8 improve the Platform.
• Security Cookies: Used to detect and prevent fraud, account takeover, and other security threats by identifying unusual session or login patterns.

8.2 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the jll8 Platform. Most modern browsers allow you to view, delete, and block cookies — refer to your browser's help documentation for specific instructions.

jll8 does not use third-party advertising cookies or allow external ad networks to track your activity across the Platform for commercial advertising purposes.

9Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jll8:

• Right to be Informed: You have the right to be told what personal data jll8 collects about you and how it is used. This Policy fulfils that obligation.
• Right to Access: You have the right to request a copy of the personal data jll8 holds about you, together with information on how it is processed.
• Right to Correction (Rectification): You have the right to request correction of inaccurate or incomplete personal data held about you. For most data fields, correction can be made directly through your account settings.
• Right to Erasure (Right to be Forgotten): You have the right to request deletion of your personal data, subject to jll8's legal obligations to retain certain data under Philippine law (including AMLA retention requirements).
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time through your account settings or by contacting the DPO.
• Right to Data Portability: You have the right to receive a structured, commonly-used copy of your personal data that you have provided to jll8, in a format that allows you to transmit it to another controller.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Right to Complain: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jll8 has not complied with its obligations under the DPA 2012.

To exercise any of these rights, please contact jll8's Data Protection Officer using the contact details in Section 14. jll8 will respond to data subject requests within 30 calendar days of receipt, consistent with NPC guidelines.

10Processing of Data Relating to Minors

11Cross-Border Data Transfers

Some of jll8's third-party service providers — including cloud infrastructure providers, game software licensors, and security vendors — may process personal data in jurisdictions outside the Philippines. Where such transfers occur, jll8 ensures that appropriate safeguards are in place to protect your personal data, including:

• Data processing agreements incorporating data protection clauses consistent with DPA 2012 standards;
• Transfer to jurisdictions that have been assessed as providing an adequate level of data protection;
• Standard contractual clauses or equivalent mechanisms approved for cross-border data transfers under DPA 2012 guidelines issued by the NPC.

jll8 does not transfer personal data to jurisdictions that lack adequate data protection frameworks without implementing compensating safeguards as required by the NPC.

12Third-Party Links and Integrated Services

The jll8 Platform may contain links to third-party game provider platforms, payment processor interfaces, or other services. This Privacy Policy applies only to jll8's own data collection and processing activities. jll8 is not responsible for the privacy practices of third-party websites or services accessed through or integrated with the Platform.

When you interact with a payment processor interface (such as the GCash or Maya payment gateway), data you submit to that interface is governed by the privacy policy of the respective payment provider. jll8 receives only the transaction confirmation and reference data necessary to credit your jll8 account.

13Changes to This Privacy Policy

jll8 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, or jll8's data processing practices. The date of the most recent update is displayed at the top of this Policy.

Where changes are material — for example, where jll8 introduces a new purpose for processing your data or a new category of data sharing — jll8 will notify registered players by email or through an in-platform notification at least 14 days before the changes take effect, and will seek fresh consent where required by the DPA 2012.

Your continued use of the jll8 Platform after the effective date of any updated Policy constitutes your acknowledgment of the updated terms. The current version of this Privacy Policy is always accessible at jll8.app/privacy-policy.

14Contact Us / Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by jll8, please contact our Data Protection Officer (DPO):